Classical criminal incidental civil indictment

Classic model criminal incidental civil indictment 1 Plaintiff of incidental civil action: Kang Mou, male, 2 1 year old, 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. 36380.6886868866 1

Facts and reasons:

I work in the same company as the defendant. On the morning of July 29th, xxx, 1 1, I was 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 kindly said to the defendant, "Let me help you burn the barrel." 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 threw the thinner in the bucket at me in a rage. Suddenly, I was on fire and the pain was unbearable. Fortunately, my colleagues present saved me from further injury.

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.

On September 10, xxx, the radial nerve caused serious dysfunction of wrist and finger joints, with more than 50% loss of function and 40% burn area. 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 53,626.1l yuan, less 1000 yuan paid by the defendant, which should be borne.

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

September Xxx 16

Plaintiff in incidental civil action: Kang Mou (signature and seal)

Classic criminal incidental civil indictment model II Plaintiff of incidental civil action: Wu x x, male, 40 years old, Han nationality, native of X city, university culture, general manager of XX limited liability company, living in XX street, XX district, XX city.

Defendant in incidental civil action: Chen×, male, 27 years old, Han nationality, from X city, with junior high school education, unemployed, living in X street, X district, X city.

ask

Ask the court to order the defendant:

1. compensate the plaintiff for medical expenses, appraisal fees, etc. That's RMB 6500.

2. Return all looted property.

Facts and reasons

On April 6th, xxx, defendant Chen X took advantage of the victim's absence to break into the house in No.1 Hospital. The plaintiff sued for the theft of XX Street in XX District, XX City, stealing cash 1000 yuan and a XX brand mobile phone, with a value of 20xx yuan. It happened to the victim when he stole the property and tried to escape. The victim suffered a head injury. The defendant smashed the victim and ran away with the stolen goods. After forensic identification, the plaintiff was slightly injured. The robbery case of the defendant Chen Moumou was investigated by the Public Security Bureau of Xx District, xxx City, and the People's Procuratorate of XXX District filed a public prosecution with the People's Court of XX District on May 17, 2007.

The defendant's criminal behavior caused the plaintiff the following material losses:

(1) Defendant Chen Xx snatched RMB 1000 from the plaintiff's home; A xx brand mobile phone, worth RMB 20xx.

(2) The plaintiff spent 6,500 yuan on hospitalization expenses, medical expenses, nursing expenses, nutrition expenses, appraisal fees and transportation expenses. Treat the wound.

To sum up, the plaintiff's above-mentioned economic losses were entirely caused by the defendant's criminal behavior. Therefore, according to the relevant provisions of the Criminal Procedure Law, we hereby file an incidental civil action with your hospital, please try it together.

Names and addresses of witnesses, names and sources of other evidence.

Original medical records, medical expenses, hospitalization expenses, nursing expenses, tickets, etc. of Xx District People's Hospital *** 12.

I am here to convey

Xx District People's Court

Plaintiff in incidental civil action: Wu×

May xxx 19

Attachment: 1 65438+ 0 copies of this complaint;

2. 12 pieces of evidence.