letter of complaint
X. Criminal Inspection [20 14]No. XX
Defendant Zhang xx, male, born on 19xx, ID No.51082419820323xxxxx, lives in xx County, Sichuan Province. Xx county, xx town, xx community, x group, x. On June 28th, 20 13, 17 was criminally detained by xx County Public Security Bureau on suspicion of intentional homicide. On June 28th of the same year, he was arrested with the approval of xx County People's Procuratorate, and was executed by xx County Public Security Bureau on the same day.
The case was investigated by xx County Public Security Bureau, and the defendant Zhang xx was suspected of intentional homicide and transferred to xx County People's Procuratorate for review and prosecution. Xx County People's Procuratorate reported on August 22nd, 20 13 to our hospital for examination and prosecution. After accepting the case, our court has informed the defendant that he has the right to entrust a defender and the victim's relatives have the right to entrust an agent ad litem, and interrogated the defendant according to law and reviewed all the case files. During the period, he was returned to the public security organ twice for supplementary investigation, and the review period was extended by 45 days.
According to this law, it is hereby determined that:
On April 20 1 1 year, the defendant Zhang xx knew the victim Chen xx, and the latter two had an improper sexual relationship. At the beginning of 20 12, Zhang xx and Chen xx*** mortgaged an excavator to jointly operate. On August 20 12, at the request of Chen xx, Jaco handed over all the excavator management rights to Chen xx. On March 20 13, Chen xx demanded to break off the relationship and return the shopping money, cash, excavator shares, mortgage and other related expenses since they met, but Chen xx refused. On the afternoon of June 8, 20 13, Chen xx made an appointment to ask him to return the borrowed car and invited two friends to persuade him to break off relations with him. I mistakenly thought that Chen xx was looking for someone to threaten him. In the afternoon, Jaco bought a fruit knife in a store in xx Road, xx County, and hid it on the stairs on the fifth floor of 2 1 Chen xx's house, hoping to clarify their economic disputes in front of Chen xx's parents and get back the shares of the excavator. At about 23 o'clock that night, Zhang xx dragged Chen xx, who was about to go home to open the door, into the room and locked the door. Chen's mother, Luo xx, was in the house and came forward to hold it. Chen xx picked up the fruit knife on the coffee table in the living room and was caught by Zhang xx. Zhang xx took out the fruit knife he bought and poked Luo xx twice in a row. At the same time, he grabbed the knife in Chen xx's hand and stabbed Chen xx with the grabbed knife. During this period, Luo xx pulled forward and was stabbed several times. Then go to the kitchen and take out a kitchen knife, and cut off the back of Luo xx's head and Chen xx's face. After the police arrived, Zhang xx attempted suicide with a kitchen knife.
Appraised by the physical evidence appraisal room of xx County Public Security Bureau, Chen xx died of hemorrhagic shock after internal carotid artery rupture and maxillary artery rupture caused by sharp instrument injury. Luo xx suffered multiple skin lacerations and minor injuries.
The main evidences for ascertaining the above facts are:
On-site inspection record, identification record, victim Luo xx's statement, witness Chen xx and Zhang xx's testimony, documentary evidence such as rescue record and hospitalization medical record, kitchen knife, fruit knife and other physical evidence, expert opinion, defendant's confession and defense, synchronous audio and video recording.
We believe that the defendant Zhang xx intentionally and illegally deprived others of their lives, and his behavior violated Article 232 of the Criminal Law of People's Republic of China (PRC). If the facts of the crime are clear and the evidence is true and sufficient, he should be investigated for criminal responsibility for intentional homicide. According to Article 172 of the Criminal Procedure Law of People's Republic of China (PRC), if a public prosecution is initiated, please be sentenced according to law.
Zhezhi
Xx intermediate people's court
20 14 year x month x day
Attached:
1. Defendant Zhang xx is currently detained in xx Detention Center.
2. The case transferred two files.