Civil indictment format version 1
Plaintiff: Name, nationality, date of birth, position, address and telephone number:
Defendant: same as above (if it is an organization, please specify the name and address of the organization and the position and name of its legal representative).
Request for action:
Facts and reasons: _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
Zhezhi
_ _ _ _ People's Court
Plaintiff: _ _ _ _ _ _ (seal)
Legal Representative: _ _ _ _ _ _ (signature and seal)
_ _ _ _ _ _ _ _ _ _ _ _ _
Attached:
Copy of the contract.
_ _ _ copies of this complaint.
_ _ other supporting documents.
note:
(1) After the contract is signed, the facts and reasons, specific contents, causes of disputes, claims and relevant laws and policies shall be clearly stated.
(2) The plaintiff shall list all the evidence to the court.
The name and domicile of the witness, the source and custodian of documentary evidence and physical evidence, and provide copies for court investigation.
(3) This complaint applies to the fact that the defendant is a legal person or other organization.
Indictment 2
No.818 [2009] of the Criminal Procedure Law of the Northern Procuratorate
Defendant Li Zhuang, male, born on June 23rd, 196 1, ID number130105106231265438, Han nationality, master's degree, from Shijiazhuang, Hebei. Address: No.202, Unit 2, Building 40, No.3 Berlin South Road, Xinhua District, Shijiazhuang, Hebei, and No.702, Shang Feng International Apartment, Haidian District, Beijing. In June 5438+February 2009, he was criminally detained by Jiangbei Branch of Chongqing Public Security Bureau in June 5438+February 2009.
The case was arrested by Jiangbei Branch of Chongqing Public Security Bureau.
The case was investigated by Jiangbei Branch of Chongqing Public Security Bureau, and the defendant Zhuang Li was transferred to our hospital for examination and prosecution on June 65438+February 65438+June 6, 2009 for the crime of perjury and obstruction of testimony.
After the court accepted the case, on June 5438+February 65438+July 2009, the defendant was informed that he had the right to entrust a defender, and the defendant was questioned according to law, and all the case materials were reviewed.
According to the legal review, on October 20th, 2009, Gong Gangmo and other 34 people were prosecuted for organizing, leading and participating in underworld organizations.
1October 22nd and 25th, 2009 165438+ Gong Gangmo's wife, Cheng Qi, and cousin Gong successively signed the Criminal Case Agency Agreement with Beijing Kangda Law Firm. Beijing Kangda Law Firm appointed the defendant Li Zhuang and lawyer Ma Xiaojun as the first-instance defenders, and Gong Gangmo's relatives paid the lawyer's agency fee of 6,543.8 yuan+5,000 yuan.
On June 24th, 2009,165438+1October 24th, 65438+1October 26th, 65438+February 4th, 2009, when the defendants met in Jiangbei District Detention Center in Chongqing, they lured and abetted the public security organs to help exonerate themselves.
Defendant Li Zhuang lured the witness to commit perjury in order to gain the court's acceptance of Gong Gangmo's confession fabricated by the public security organs under torture.
From the end of June, 5438+0 1 year to the beginning of February, 2009, he fabricated the fact that he was blackmailed by Fan and others, and asked Cheng Qi to testify in court.
165438+2009124 October, in a teahouse in Nanfang Garden, Chongqing High-tech Zone, Gong was instructed to arrange for members of Chongqing Poly Tianyuan Entertainment Co., Ltd. to commit perjury, denying that he was the actual investor or controller of Chongqing Poly Tianyuan Entertainment Co., Ltd.
Gong arranged for Wang Ling, Li, employees of Chongqing Poly Tianyuan Entertainment Co., Ltd. to make false certificates.
June 5438+February 3, 2009, in Yubei District, Chongqing? Wuzhou Hotel? Li Zhuang instructed Gong Gangmo's other defender, lawyer Wu Jiayou of Chongqing Crete Law Firm, to bribe the police to extort a confession from Gong Gangmo by torture.
On June 5438+February 1 day, 2009, he applied to the people's court for Cheng Qi, Gong and others to testify in court.
The above behavior of the defendant Li Zhuang interfered with the normal work of Gong Gangmo and other 34 people in organizing, leading and participating in the trial of organized crime cases.
On June 5438+February 10, 2009, Gong Gangmo reported the criminal behavior of the defendant Li Zhuang to the public security organ. On June 5438+February 12, 2009, Li Zhuang was arrested and brought to justice by the public security organs in Beijing.
The evidence for ascertaining the above facts is as follows:
1, criminal case agency agreement, People's Republic of China (PRC) lawyer's practice certificate, etc. ;
2. Testimony of witnesses Gong, Wu Jiayou, Cheng Qi, Wang Ling, Li and others;
3. The confession and defense of the defendant Li Zhuang.
Our court believes that the defendant Li Zhuang fabricated false facts about Gong Gangmo's confession by torture, forged evidence, and induced witnesses to commit perjury in the process of performing criminal defense duties. His behavior has violated the first paragraph of Article 306 of the Criminal Law of People's Republic of China (PRC), and the facts of the crime are clear and the evidence is indeed sufficient. Therefore, the criminal responsibility of the defender should be investigated for the crime of falsifying evidence and obstructing testimony.
According to Article 141 of the Criminal Procedure Law of People's Republic of China (PRC), the defendant Li Zhuang was prosecuted and sentenced according to law.
I am here to convey
Jiangbei District People's Court of Chongqing Municipality
Authorized Agent: He Beibei.
Yao Ning
December 18th, 2009
How to write a letter of complaint 3
When the plaintiff files a lawsuit, he should prepare a complaint, which is a complaint.
The complaint shall include the following contents:
1. Basic information of both parties (original defendants).
Including name, gender, age, nationality, work unit and address.
If yes, the name and location of the unit and the name and position of the legal representative shall be stated.
2, the request and the facts and reasons on which it is based.
The so-called litigation request is a problem that needs to be solved, such as asking for a divorce or asking for compensation.
3, indicate the evidence and the source of evidence, the name and address of the witness.
In addition to the above contents, the complaint shall also indicate the name of the people's court that submitted the complaint and the year, month and day of the complaint, and the complaint shall be signed and sealed by the plaintiff.
Copies corresponding to the number of defendants should also be provided (in addition to the original, one defendant should be added, that is, two copies for one defendant and three copies for two defendants).