Applicant (victim, legal representative, near relative, lawyer):
State the basic information such as name, gender, date of birth, nationality, native place, occupation or work unit, position and address. A lawyer only needs to give his name and the name of his law firm.
Defendant (criminal suspect):
State the basic information such as name, gender, date of birth, nationality, native place, occupation or work unit, position and address.
Criminal facts of the defendant (criminal suspect):
Indicate the time, place, object, purpose, motivation, means and consequences of the criminal suspect.
Reasons and legal basis for application:
Indicate the legal basis for the criminal suspect's criminal behavior to constitute a crime.
Evidence and sources of evidence, names and addresses of witnesses.
Indicate the main evidence and its source, and the name and address of the main witness.
I am here to convey
_ _ _ _ Public Security Bureau (or _ _ _ People's Procuratorate or _ _ _ People's Court)
Applicant: _ _ _ _ _ _ _
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _
202 1 mode application filing 2
Applicant: liquidation group of Shanxi Jiexiu Guo Xin Coal Chemical Co., Ltd.
Address: East of Shihe Bridge in Wencun Village, Sanjia Township, Jiexiu City, Shanxi Province
Legal Representative: Feng Zhiqiang Tel:1523xxxxx.
Requested items:
Request the People's Procuratorate of Jiexiu City to exercise the power of supervision according to law, and order the 3A police station of Jiexiu City Public Security Bureau to file an investigation on the case of explosion, destruction and looting of property of Jiexiu Guo Xin Coal Chemical Co., Ltd., find out the real culprits and bring them to justice.
Facts and reasons:
In 20**, Feng Zhiqiang, Feng Zhili and Feng Zhigang * * * established Jiexiu Guo Xin Coal Chemical Co., Ltd., which is located in Wencun, Sanjia Town. Covering an area of 5 1 mu, with a building area of 2265. 96 square meters, with a distribution room worth more than one million yuan,160kw transformer, weighing room, bricks, sand, steel, cement (No.425), stones, office desks and chairs, filing cabinets, safes, account books, company seals and other property. At 3 o'clock in the afternoon of February 18, 20 * *, a group of people, with the cooperation of four loaders, blew up and damaged the fixed facilities of our company, and looted our company's movable property worth more than one million yuan. After learning the news, they immediately reported the case, but Zhang Jian, He Yan and other police officers rushed to the scene and watched our property being destroyed and robbed without taking any measures. Shortly after the incident, our company's land was forcibly occupied, and the company 10000 square meters of gravel hardened ground and nearly 3000 square meters of cement hardened ground were all destroyed. We have repeatedly reported to the Jiexiu Public Security Bureau, asking the Public Security Bureau to find out the real culprits of the explosion, robbery and occupation and bring them to justice, but what we got was an inexplicable reply (Gong Jiebrizi [20 * *] No.2, Gong Jiefu Zi [20 * *] 1 No.
We believe that:
1. We reported the case on February 18, March 3 1 day and May 4, 20**, but we didn't report the case on July 7, 20**. The reporting time stated in the Notice of Not Filing a Case by Jiexiu Public Security Bureau is inconsistent with the actual situation.
2. In the report materials, we asked to investigate the legal responsibility of the relevant actors, but did not specify that the village committee of Wencun Village in Sanjia Township pushed down the factory. Jiexiu City Public Security Bureau failed to perform its investigation duties.
3.20 * * On February 18, the personnel who damaged our company's property used zh medicine to blow up our company's fixed assets, and the perpetrators were suspected of explosion. Organizers and participants who destroy or rob our company's property are all suspected of intentionally destroying property and gathering people to rob. This is a crime of exploding, destroying property and robbing property in broad daylight, but Jiexiu City Public Security Bureau lightly thinks that it does not constitute a crime. Therefore, I reflect to your company, please urge Jiexiu Public Security Bureau to file a case for investigation according to law, and investigate the responsibilities of relevant personnel, so as to safeguard the legitimate rights and interests of our company.
I am here to convey
Jiexiu people's procuratorate
Jiexiu Guo Xin coalification co., ltd. liquidation zu
20xx March 18
202 1 filing application form 3
Applicant: xxxxx, female, Han nationality, born in xxx year1October 22nd, 165438, living in xx, Santai County, Sichuan Province.
Requested items:
Request your bureau to file an investigation on xxxx's alleged xx case and investigate its criminal responsibility according to law.
Facts and reasons:
Xxxx, female, Han nationality, now lives in xxxxxx, Sichuan Province.
On the afternoon of xx 1xx, xxX came to the applicant's home on the grounds that the mobile phone was lost and the respondent thought it was found. As soon as the applicant opened the door, xxxX pushed him to the ground and asked him for his mobile phone. After the applicant denied it, xxx beat the applicant with xx and left after venting. However, after leaving the applicant's residence for about 15 minutes, xxx returned to the applicant's home, attacked the applicant again, and forcibly snatched a pair of gold earrings worth more than 2,000 yuan from the applicant, trying to leave. The applicant seized xxxxx and wouldn't let him leave. In this case, XXXXX forcibly dragged the applicant out of the hospital about15m. At this time, the neighbors xxx, xxx and xxx where the applicant is located saw the criminal act and stopped the criminal act of xxxx in time. Then xxx ordered xxx to return the stolen earrings to the applicant. After xxx gave xxxx the earrings, she left directly. And language threats, if the applicant does not return the phone, it is necessary to xx the applicant's family. After hospitalization, the applicant was diagnosed with moderate concussion and multiple soft tissue injuries.
To sum up the basic facts of the case, xxxxx subjectively imagined that the applicant had picked up the mobile phone, thus making trouble without reason and hurting others by violence. In particular, XXXXX returned to the crime scene after violently beating the applicant for the first time. Obviously, he was puzzled by the first beating and thought that his loss could not be satisfied, so he used violent means to hurt the applicant again, stole the applicant's finance on the spot, and wanted to leave after he succeeded. The criminal act has been completed, which constitutes a completed crime, and xxxxx subjectively has the purpose of illegal possession, and its nature is bad, which fully conforms to the constitutive requirements of People's Republic of China (PRC) Robbery and Article 263 of the Criminal Law of People's Republic of China (PRC). In accordance with the relevant provisions of the Criminal Law of People's Republic of China (PRC) and the Criminal Procedure Law of People's Republic of China (PRC), we request your bureau to file an investigation, investigate the criminal responsibility of Xie Li according to law, and safeguard the normal social order and the legitimate rights and interests of citizens.
I am here to convey
Xxxxx bureau of public security
Applicant: xxx
Xx year xx month xx day