Criminal incidental civil complaint (1) Plaintiff of incidental civil action: Kang, male, 2 1 year old, a worker of X flour mill in X city, living at No.20, X Road, X District, A city.
Legal Representative: Kang Momin, male, 64 years old, retired cadre of Bureau of Retired Veteran Cadres in X City, X Province, with the same address, is the father of the plaintiff.
Defendant in incidental civil action: Yang, male, 29 years old, a flour mill worker, lives in our dormitory.
Claim: The defendant was ordered to compensate the plaintiff for medical expenses and other economic losses caused by his criminal acts +038+0 yuan. 36380.8886888666 1
Facts and reasons:
I work in the same unit as the defendant. 10: 00 am on July 29th, 999 165438+ I'm sitting on the windowsill of the workshop to have a rest. The defendant took a small bucket full of diluent from a foreign workshop and put it in front of me, saying that he would brush the bucket and take it home for fishing. I sincerely told the defendant. Let me help you burn the bucket. ? Immediately, I struck a match and put it in the bucket, and the diluent in the bucket began to burn. I jumped down from the windowsill at once. At this time, the defendant saw that his bucket was on fire, and in a rage, he spilled the thinner in the bucket on me. Suddenly, I was on fire and the pain was unbearable. Fortunately, my colleagues present saved me from further harm.
After the burn, he went to a hospital of the People's Liberation Army and a hospital affiliated to a medical college for treatment. * * * I spent 183 15.76 yuan on medical expenses. The plaintiff A_T lost 245 yuan a month, and I only gave 76.20 yuan for sick leave a month. It has been 13 months * * 2 194.40. 40 days), that is, the daily wages of the plaintiff's father, mother and brother are 10 yuan, that is, 1200 yuan. Other expenses: the accommodation fee for nursing staff is 264 yuan, the fare for escorting patients is 330 yuan, 9 people for escorting patients, doctors and drivers, the hospitality fee is 85 yuan, the photocopying and photographing fee is 40 yuan, the round-trip fare for nursing staff is 152. 10 yuan, and the telephone fee is 44.55 yuan.
1999, 10. According to the judicial technical appraisal of this Municipality's Public Security Bureau, the function of wrist and finger joints was seriously damaged after burns, and the function was lost by more than 50%, and the burned area of the whole body was 40%. Finally concluded that it was a serious injury. The defendant has been prosecuted by the People's Procuratorate of X City according to law. According to Article 77 of the Criminal Procedure Law, the plaintiff filed an incidental civil action in accordance with the law, demanding that the defendant be ordered to compensate the plaintiff for the economic losses caused by his criminal behavior, and pay himself a disability allowance of 24,000 yuan and a cosmetic fee of 5 0 yuan. The above expenses totaled 53,626 yuan1l, less 1000 yuan paid by the defendant.
Evidence and sources of evidence:
1. Judicial expertise of a city public security bureau 1 copy;
2. Medical expenses 93;
3.48 round-trip tickets to the hospital.
I am here to convey
Xx people's court
Plaintiff in incidental civil action: Kang Mou (signature and seal)
1999 September
Attachment: this complaint 1 copy.
Civil Indictment Attached to Criminal Cases (II) 1995 12 14 In the evening, the defendant Wang Shouman and the victim Mao Yuanshu decided to kill the victim because of a dispute, so they attacked the victim with a weapon. In the case of the victim's death, the defendant brutally strangled the victim with a rope, dragged the victim outside the house with a rope, and threw the victim's body in the mountains. Three days after the incident, it was discovered by the masses.
Criminal incidental civil indictment
Plaintiff in criminal incidental civil action: Wang Shouzhen, female, 6 1 year-old, Han nationality, from Zhongxian, Chongqing, living in Group 13, Shang Ping Village, Shanguang Township, Zhongxian, and the mother of the victim Mao Yuanshu.
Authorized Agent: Wu, lawyer of Chongqing Taiyuan Law Firm.
Authorized Agent: Mao, male, Han nationality, 37 years old, from Zhongxian County, Chongqing, now living in Shanguang Village 13 Group, now living in Lane 6, Renmin Road, Zhongzhou Town, Zhongxian County 12. 2#, the son of the plaintiff Wang Shouzhen, is brother and sister with the victim Mao Yuanshu. Tel: 15909355336.
Defendant: Wang Shouman, male, about 39 years old, Han nationality, from Zhongxian County, Chongqing, living in Group 6 of Yanghe Village, Shanguang Township, Zhongxian County, Chongqing, is now detained in Zhongxian Detention Center on suspicion of intentional homicide.
Litigation request:
1. Request the people's court to investigate the criminal responsibility of the defendant Wang Shouman for intentional homicide, sentence the defendant Wang Shouman to death and deprive him of political rights for life.
2. Request the people's court to order the defendant to compensate the plaintiff for death compensation of 82,520 yuan, funeral expenses of13,492.5 yuan, maintenance of 34,620 yuan, transportation expenses of 800 yuan, mental damages of10,000 yuan and other losses of10,000 yuan.
Facts and reasons:
1995 14 On the evening of February 14, the defendant Wang Shouman and the victim Mao Yuanshu had a dispute and had the motive to kill the victim, so they used a weapon to beat the victim. In the case of the victim's death, the defendant brutally strangled the victim with a rope, dragged the victim outside the house with a rope, and threw the victim's body in the mountains. Three days after the incident, it was discovered by the masses. After absconding for more than ten years, the defendant was finally arrested and brought to justice by the public security organs in May this year. Because of the defendant's criminal behavior, the plaintiff's family was ruined: because the victim was unfortunately killed, the victim's father died in March because of grief; The victim's mother is still suffering from schizophrenia; The victim's daughter was homeless because of the defendant's behavior, and there is no news of her now; The victim's son also failed to get a good education because of the defendant's criminal behavior, and embarked on the road of crime as an adult.
The plaintiff believes that because the defendant constitutes the crime of intentional homicide, and the circumstances are very bad, the consequences are extremely serious, the social impact is extremely bad, and the public is extremely angry, the people's court should sentence the defendant to death according to law. At the same time, the two children of the victim Mao Yuanshu were minors at the time of the incident. The defendant's criminal behavior caused the ruin and displacement of the victim's family, and he suffered irreparable mental and economic losses. According to the Criminal Procedure Law, the General Principles of the Civil Law and the Interpretation of the Supreme People's Court on Several Issues Concerning the Trial of Personal Injury Compensation Cases, the defendant shall bear the civil liability for all the losses of the victim according to law. Therefore, in order to safeguard the legitimate rights of the plaintiff, according to the provisions of Article 77 of the Criminal Procedure Law of People's Republic of China (PRC), we hereby file a lawsuit in your hospital, and please make a judgment according to law.
I am here to convey
Chongqing No.2 Intermediate People's Court
Tangible person: Wang Shouzhen
June 5(th), 2009