Applicant: lawyer of law firm, attorney of criminal suspect XX.
Object on bail pending trial (criminal suspect): XX, male, has been put on file for investigation by XXX People's Procuratorate for suspected bribery, and is now in custody.
Application: Yang XX, a suspect suspected of accepting bribes, applied for bail pending trial.
Main facts and reasons:
I am the attorney entrusted by the criminal suspect Yang XX. At present, according to the request of the criminal suspect Yang XX and his family, combined with the practical difficulties faced by his personal physical condition and the specific social harm of his crime, and in accordance with Articles 5 1 and 96 of the Criminal Procedure Law of People's Republic of China (PRC) and relevant laws and regulations, I hereby apply for bail pending trial. The legal basis and reasons are as follows:
First, the criminal suspect Yang XX has been in poor health, suffering from hypertension and fatty liver for a long time. On February 20/0/0, Kloc went to the hospital for dizziness and limb weakness (the relevant medical records are attached).
Second, the criminal suspect Yang XX has no social harm, and his family members are willing to provide guarantee for the criminal suspect Yang XX in the form of personal insurance or financial insurance.
The criminal suspect Yang XX is suspected of bribery, which is a non-violent crime and has no social harm. It belongs to Article 51 of China's Criminal Procedure Law. "It may be sentenced to more than fixed-term imprisonment, and taking bail pending trial and residential surveillance will not cause social danger." According to Articles 53, 54, 55, 56 and 57 of China's Criminal Procedure Law, Yang XX's family members are willing to take out insurance or financial insurance.
The guarantor promises to report the situation of the guarantor to the executing agency at any time and supervise the criminal suspect to strictly abide by the relevant regulations, so as to ensure that the criminal suspect Yang XX can: (1) abide by the law; (2) ensure that you are on call; (3) Do not interfere with the testimony of witnesses; (four) shall not destroy or forge evidence or collude with others; (5) Make sure not to leave the county and city where you live.
To sum up, the suspect Yang XX has been in poor health, suffering from hypertension and fatty liver for a long time. Moreover, the criminal suspect Yang XX is not harmful to society. Therefore, I urge the people's procuratorate to consider the practical difficulties of the criminal suspect Yang XX and approve his application for bail pending trial.
This demonstration
XX Municipal People's Procuratorate
Applicant:
Date of application: