Contract fraud accessory defense statement should be written, what are the specific provisions of the content?

Defense speech respected presiding judge, people's jurors: xxx law firm accepts the defendant in this case Zhangxx close relatives entrusted, according to the law assigned me to serve as his defender. The defender through the reading of the case file and meet the parties, as well as the court investigation and the proof of evidence has been a comprehensive understanding of the case, is now published the following defense opinions for the collegiality of reference. The defense for the indictment alleges that Zhangxx and others suspected of contract fraud qualification does not dispute. But that the defendant Zhangxx has mitigating circumstances. First, Zhangxx played a limited role in this case, should be recognized as an accessory status. Reduce its punishment according to the law (1) the intention of the crime is not caused by Zhang xx, it is only invited by others to come, the occurrence of this case has a certain degree of serendipity Zhang xx originally in Yunnan Lincang City to do the business of medicinal herbs, has a legitimate occupation, only by Li xx invitation and temptation to participate in the crime of a moment of delirium. Zhang xx is an occasional offender, if it is not Li xx's invitation, he will not go to the road of crime. For this point can be through the public security organs of the defendant's interrogation transcripts to be corroborated, (see the interrogation transcripts of Zhang xx's confession see side 38 lines 2-4, Pang xx's confession see side 49 lines 9-11, Zhang's confession see side 62 lines 6-7) and the court investigation of the defendant's are confessed. During the court investigation of the defendants have confessed to confirm this objective fact, Li xx itself is Hubei people, the scope of its activities basically in Wuhan generation, and several people's meeting and also in the arrangement of Li xx to Wuhan to meet, the books used in the first crime is also in Wuhan to buy, these are also to a certain extent confirms that in this case, Li xx is to play the biggest role in the. The defense begs the panel to take note of this point and reduce the punishment of Zhangxx according to the law. (2) The organizer and planner of this case was not responsible for Zhang xx In this case, both Zhang xx and Pang xx, Wang xx, Ling, Zhang, the people involved in the case were invited by Li xx, they originally had formal jobs. As mentioned above, the persons involved in the case were all invited by Li XX, and the division of labor and the planning of criminal means were all controlled by Li XX. All the persons involved in the crime were under the command of Li XX. (3) Zhang xx in this case played a limited role in the specific, mainly Li xx in playing an important role in this case, Li xx is the most important role, not only to invite the people involved in the crime, but also to organize the planning of the entire criminal process, and in this case, it also played a very large role. The books were purchased by Li XX; he contacted the bookstore, made direct contact with the victims, posed as a government employee, and managed to trick the victims into a trap, all of which were carried out by Li XX alone. These facts were not only corroborated by the statements of the defendants, but also further confirmed by the victims' identification and confessions. Zhang XX's role was only to fill out the business list, accompanied Li XX to the bookstore door "release". Throughout the case Zhangxx role is very limited, and therefore should be recognized as an accessory. (4) Zhang xx's share of the spoils of profit is small according to the statements of the defendants, the spoils are divided by Li xx to carry out, and each time it is Li xx share the most. Zhang xx due to the limited role in the whole case, so its profit is also smaller. Second, Zhang xx pleaded guilty to a better attitude, with obvious repentance, I implore the panel to reduce its punishment according to law after the return of Zhang xx frankly confessed all the way through the confession of guilt has always been very comprehensive and stable, there is no any deliberate concealment and avoidance of the performance of the light. From the interrogation transcripts can also be seen, after the crime, Zhang xx pleaded guilty and repentant attitude is relatively good, its confession coherent, mutual corroboration, so that the investigation and trial of the case is always in a proactive environment, and in the trial Zhang xx voluntarily pleaded guilty, and actively cooperated with the court's trial. According to the supreme people's court, the supreme people's procuratorate, the ministry of justice, "on the application of ordinary procedures for hearing "defendant pleads guilty" cases of the provisions of article 9, the people's court of the defendant voluntarily pleads guilty, may be discretionary mitigating punishment. Third, the defendant Zhangxx has surrendered to the statutory mitigating circumstances in the investigation stage truthfully confessed to the public security organs have not yet grasped the facts of the crime, in accordance with the law to explain the facts of cheating in Henan, Zhejiang Province. Fourth, the amount of money involved in this case should be should be 774094.7 yuan, and should be characterized as a larger amount (1) the defense that the amount of money involved in this case is 774094.7 yuan (2) the amount of money involved in this case should be a larger amount of money at present, our country for the amount of the crime of contract fraud, large, huge, there is no corresponding provisions, according to the principle of favoring the defendant should be found that the amount of the defendant's fraud for the The amount is large. According to the 2010 "supreme people's procuratorate, the ministry of public security on the jurisdiction of the public security organs of the criminal case prosecution standard provisions (ii)" article 77 for contract fraud prosecution standard positioning more than 20,000 yuan, due to the special nature of the contract fraud prosecution standard is higher, the indictment alleges that the amount involved in this case is 869,600 yuan, and the defense believes that the actual amount is 774,094.7 yuan. In summary, the defense believes that Zhang xx has mitigating circumstances, requesting the court in its conviction and sentencing, give full consideration to its status and role in this case, as well as its obvious repentance, give full play to the criminal law of the educational and penitentiary role of the law to mitigate its punishment.