Defending the crime of dangerous driving Dear presiding judge and judge, xxxx Law Firm accepted the entrustment and appointed lawyer xxx as the first-instance defender of the case of defendant xxx suspected of dangerous driving. After accepting the entrustment, the lawyer carried out a series of work; Combined with today's trial, the defender has no objection to the characterization of the defendant xxx accused of dangerous driving in the indictment of the public prosecution agency. Combined with the court investigation just now, according to the facts and laws, he made the following defense opinions and asked the court to consider and adopt them. First, the defendant xxx was given a lighter punishment. First of all, subjectively speaking, the defendant, who has always been low-key and cautious, never drinks too much, and he has no motive to "take the initiative" to commit crimes. Secondly, the defendant's personal danger is small, and it has not caused any harm to society. The defendant's blood alcohol concentration is only slightly higher than the normal standard. Moreover, the xxxx traffic police brigade confirmed that the defendant was mainly responsible for the accident, and xxx was secondary. Thirdly, the defendant has a good attitude of pleading guilty. (explain the details of confession in detail) 2. The defendant is an occasional offender and a first-time offender. The defendant always abides by the law, behaves well and is honest. Third, the defendant actively compensated the victim and obtained the victim's understanding. The defendant actively negotiated compensation with the victim, obtained the understanding of the victim, and requested the court to consider it. Four. It is suggested that the people's court exempt the defendant from criminal punishment or give him a lighter sentence or suspended sentence (analyze the request from social morality, laws and regulations, etc.) In view of the above reasons, we urge the people's court to consider the specific circumstances of this case, exempt the defendant from criminal punishment or give him a lighter sentence or suspended sentence, so that the defendant can feel the care of the country, the generosity of society and the humanity of the law, and let him consciously reform himself and sincerely give back to our society while fulfilling his social and family responsibilities. I urge the court to fully consider and adopt the above defense opinions. Xxxx law firm xxxx year x month x day
legal ground
People's Republic of China (PRC) Civil Procedure Law
Article 125 The people's court shall send a copy of the indictment to the defendant within five days from the date of filing the case, and the defendant shall submit a reply within fifteen days from the date of receiving the indictment. The defense shall specify the defendant's name, gender, age, nationality, occupation, work unit, residence and contact information; The name and domicile of the legal person or other organization and the name, position and contact information of the legal representative or principal responsible person. The people's court shall send a copy of the defense to the plaintiff within five days from the date of receiving the defense.
If the defendant fails to submit the defense, it will not affect the trial of the people's court.