Model defense words in criminal cases?

Dear presiding judge and member of collegiate bench, our firm accepts the entrustment of the defendant in this case and appoints this lawyer as its defender. After meeting the defendant, meeting witnesses, hearing and cross-examination, the defender put forward the following defense opinions: the defender believes that the facts of the defendant accused by the public prosecution agency are unclear and the evidence is insufficient. The reasons are as follows: 1. The main evidence of the defendant's guilt in this case is unclear and insufficient. 1. There are the following problems with the traffic accident certificateNo. 1 issued by the traffic detachment of the Public Security Bureau: 1. The basic facts of traffic accidents; 2. The analysis of the causes of traffic accidents is wrong; 3. Wrong application of the law: Article 45 of the Regulations on Handling Traffic Accidents stipulates that "traffic of public security organs" According to Article 3 of the Interpretation of the Supreme People's Court on Several Issues Concerning the Specific Application of Laws in the Trial of Criminal Cases of Traffic Accidents, escape refers to the act of evading legal investigation after traffic accidents. 2. There are the following problems in the authenticity of witness testimony: 3. There are the following problems in the corpse inspection certificate issued by the forensic examination and appraisal of the public security bureau: first, the existing evidence cannot prove that the defendant's driving behavior has constituted a traffic accident crime. The defendant was neither intentional nor negligent subjectively. Objectively, the defendant did not violate the law. From the aspect of causality, the existing evidence cannot prove that the death of the victim was caused by the defendant dragging it away by car. According to the provisions of article 133 of China's criminal law, traffic accident crime belongs to negligence crime and consequential crime. The existing evidence in this case cannot prove the result of the defendant's contact with the victim while driving the vehicle. That is, there is no causal relationship in criminal law. Article 46 of China's Criminal Procedure Law stipulates: "In sentencing all cases, we must attach importance to evidence, investigation and research, and do not trust confessions. If there is no other evidence, the defendant cannot be found guilty and sentenced. " Three. Other main plots of this case: 1. After the traffic accident, the defendant took the initiative to report the case; 2. The defendant has always performed well and has no violations of law and discipline; 3. After the traffic accident, the defendant actively made civil compensation to the victim's family. Please ask the collegial panel to find out the above defense opinions in combination with the evidence and specific circumstances of this case. Defender: Lawyer of law firm: On the basis of the above, the defense is particularly important for a case, but it can only be implemented if it meets the conditions stipulated by law. Therefore, when the defendant writes, it must be handled in accordance with the procedures prescribed by law, so that the court can make a judgment according to the actual situation of the case.