Now suppose you are the public prosecutor of this case, please write an indictment according to the above facts.
Requirements for answering this question:
1. The format is correct and the required items are complete;
2. The request is valid and accurate;
3. The text is fluent and concise, without grammatical errors and typos;
4. The natural situation of the parties and the name and document number of the judicial organ not involved in the questions can be compiled by themselves, but the names of candidates are not allowed, otherwise this paper will not score.
"Reference answer"
Chishan people's procuratorate
letter of complaint
Chi Jian Criminal Procedure Law Zi (2000)No. * * *
Defendant Li Yushu, male, born on August 2, 1970, Han nationality, farmer, native of Chishan City, living in Long 'an Village, Chishan City, was criminally detained by Chishan Public Security Bureau on September 8, 2000 for attempted murder and theft, and was arrested by Chishan People's Procuratorate on September 5, 2000.
The case of the defendant's forced (attempted), intentional homicide and theft was investigated by Chishan County Public Security Bureau and transferred to our hospital for review and prosecution. We received it on * * in 2000, and upon examination, the defendant's criminal facts are as follows:
On the morning of September 7, 2000, the defendant passed through the suburb of Chishan, saw the victim Xu (female, 34 years old) herding sheep on the grass beach, and went forward to talk. During the conversation, the defendant had a strong evil thought, so he pulled Xu into a nearby ditch and fell to the ground, forcibly pulling Xu's pants to be strong. Xu Guizhen strongly resisted and shouted for help. Afraid of exposure, he pulled out a dagger and stabbed Xu in the abdomen. Xu continued to cry for help. One hand stuck Xu's neck, and the other hand stabbed Xu in the abdomen several times, causing Xu to die on the spot. Then Xu's watch and 80 yuan money were taken away, and Xu's body was moved to a nearby place for burial. Subsequently, Li Yushu rushed 125 sheep herded by the victim to the nearby Gaojiadian village to sell the stolen goods.
The above-mentioned criminal facts include the defendant's confession, physical evidence, inspection records and other evidence. The facts are clear and the evidence is indeed sufficient.
To sum up, firstly, the defendant tried to have sex with the victim by violent means against the will of women, but failed because of the strong resistance of the victim. His behavior has violated the provisions of Articles 236 and 23 of the Criminal Law of People's Republic of China (PRC), which constitutes a serious crime (attempted).
Second, the defendant killed the victim with a dagger for fear that his crime would be exposed after the attempted coercion. His behavior has violated the provisions of Article 232 of the Criminal Law of People's Republic of China (PRC), which constitutes the crime of intentional homicide.
Thirdly, for the purpose of illegal possession, the defendant Li Yushu took the sheep 125, the victim's watch and the stolen money 80 yuan as his own. His behavior has violated the provisions of Article 264 of the Criminal Law of People's Republic of China (PRC), which constitutes theft.
Defendant Li Yushu's criminal circumstances are extremely serious, and his social impact is extremely bad, causing extremely serious harm. In order to safeguard the dignity of the law, maintain social order and protect the interests of the broad masses of the people, our hospital initiated a public prosecution in accordance with the provisions of Article 14 1 of the Criminal Procedure Law of People's Republic of China (PRC). Please severely punish according to law.
I am here to convey
Chishan intermediate people's court
Inspector: XXX
X year x month x day
(Seal of Institute)
1. evidence list
2. Copy of main evidence