accuse
X indictment [20XX]XX
The first part: the defendant's name, gender, age (year, month, day), native place, nationality and language.
Education level, unit, position, address, criminal punishment, and year, month and day of detention and arrest.
The second part: the cause and source of the case.
Part III: Criminal facts and evidence.
Part IV: Reasons and legal basis for prosecution.
Defendant Guo XX, male, 3 1 year old.
The case was investigated by XX People's Public Security Bureau, and the defendant was transferred to our hospital for examination and prosecution on suspicion of illegal medical practice. After accepting the case, our court has informed the defendant that he has the right to entrust a defender and the victim's legal representative has the right to entrust an agent ad litem, interrogated the defendant according to law, listened to the opinions of the victim's agent ad litem, listened to the opinions of the defendant's defense lawyer Sun XX, and reviewed all the case files.
According to this law, it is hereby determined that:
Describe the facts of the case.
The evidence of the above facts includes: the testimony of witness villager XXX, the prescription issued by defendant Guo XX, and the appraisal report of appraiser XXX.
Our hospital believes that the defendant Guo XX ignored the law and discipline and illegally practiced medicine without obtaining a doctor's qualification certificate and practice license, causing the patient to die of poisoning. His behavior violated the first paragraph of Article 336 of the Criminal Law of People's Republic of China (PRC). The facts of the crime are clear and the evidence is true and sufficient, so he should be investigated for criminal responsibility for the crime of illegal medical practice. According to Article 141 of the Criminal Procedure Law of People's Republic of China (PRC), the defendant in this case was prosecuted and sent to our court for trial. Please punish him according to law.
I am here to convey
XX people's court
Inspector XX
XX year XX month XX day
Attached:
1, the defendant XX is now detained in XX detention center.
2, the list of evidence, witness list and a copy of the main evidence.