Applicant: lawyer of law firm.
Application: apply for bail pending trial for the criminal suspect.
Reason:
The people's procuratorate approved (or decided) the arrest and detention of criminal suspects on. At the request of the criminal suspect (or his legal representative or near relative), I apply for bail pending trial. The guarantor is (or the deposit is). According to the provisions of Article 5 1 and Article 96 of the Criminal Procedure Law of People's Republic of China (PRC), it is hereby submitted for approval.
I am here to convey
Public security bureau or (people's procuratorate, people's court)
Applicant: (signature)
Law Firm (Seal)
date month year
Description:
The people's courts, people's procuratorates and public security organs take measures to obtain bail pending trial according to the circumstances of the case. One of the compulsory measures taken against criminal suspects and defendants. People's courts, people's procuratorates and public security organs may obtain bail pending trial for the following persons: (1) Those who may be sentenced to public surveillance, criminal detention or independently apply supplementary punishment; (2) can be sentenced to more than fixed-term imprisonment, and bail will not cause social danger; (three) according to the law should be arrested quickly, but suffering from serious illness; (4) Women who should be arrested according to law but are pregnant or nursing babies; (5) Arrest is required after detention, but the evidence is insufficient; (6) being detained, but unable to close the case within the statutory time limit, and there is no social danger of applying detention for trial. Bail pending trial shall be executed by the public security organ. Criminal suspects, defendants and their legal representatives in custody. Close relatives and entrusted lawyers have the right to apply for bail pending trial. The people's court, the people's procuratorate, the criminal suspect and the defendant put forward a guarantor or pay a deposit. The guarantor must have no connection with the case, have the ability to fulfill the obligation of guarantee, enjoy political rights, have no limit to his personal location, and have a fixed residence and income.
Model application for bail pending trial II
Applicant: female, Han nationality, 65438+, born on October 3rd, 2005/kloc-0.
Address: Haidian District, Beijing
ID number: 2
Tel: 826xxxxxxxx
Mobile phone:136xxxxxxxxx
Respondent: Chen, male, born on March 3rd, 19, the husband of the applicant.
Address: Haidian District, Beijing
Application: Chen was released on bail pending trial.
Fact reason:
On October 20th, xxx/KLOC-0, Beijing Municipal People's Procuratorate criminally detained Chen on suspicion of corruption, and was later arrested. Now detained in Beijing detention center. Both the applicant and Chen Ben have applied to your hospital for bail pending trial, but they have not been approved.
Article 10 of the Regulations of People's Republic of China (PRC) Detention Center stipulates that criminals detained in detention centers shall undergo health examination, and shall not be put in prison under any of the following circumstances: ……………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………………… But; Except for crimes that are extremely harmful to society. "
Article 19 of the Measures for the Administration of Prisoners in Detention Centers stipulates that the inability to take care of oneself in daily life means that getting up, eating, walking and going to the toilet cannot be done by oneself due to illness, disability or old age and infirmity, and must be done with the assistance of others.
The applicant believes that Chen's current situation is obviously unable to take care of himself and meets the conditions of non-detention and bail pending trial.
Chen Yu 1937 was admitted to the hospital twice in May and June. The retinal pigment variation in both eyes has been diagnosed, and the eyes have been blurred for more than 2 years. It is difficult to take care of yourself at home and need long-term uninterrupted medication. Moreover, Chen also suffers from binocular senile cataract, diabetes, essential hypertension, gout and hyperlipidemia, and also needs long-term medication and nursing. At the same time, Chen was detained and continued to take drugs without interruption, and needed help in his daily life in the detention place.
Before and after the incident, Kerwin Chen was able to cooperate with the inspection authorities to explain the situation and actively cooperate with the investigation, so that he was released on bail pending trial, and there was no social danger. According to the provisions of Article 5 1 and Article 52 of the Criminal Law of People's Republic of China (PRC), an application is made to change the criminal law, and Chen is released on bail pending trial.
Therefore, the applicant and the voluntary guarantor shall perform the guarantor's obligations according to law.
I am here to convey
Beijing Municipal People's Procuratorate
Applicant:
Xxx9 9 year month day