DECLARATION PETITION – NO PENALTY DUE TO COMMERCIAL RELATIONSHIP
TO ISTANBUL CHIEF PUBLIC PROSECUTOR’S FORGERY AND FRAUD BUREAU
FILE NO:2013/….. Preparatory Investigation
SUSPECT :
DEFENDANT Av..
COMPLAINANT
EXPLANATIONS
I- The complainant ……………….. has a commercial relationship. With our client …………. He gave four cheques in return for various goods purchased from our client. However, when the cheques were presented to the bank, it was understood that there was no equivalent. So the back of the cheques were printed (Annex-1 Cheque Photocopies). Later, during the negotiations with the complainant debtor. The complainant declared that he would demand the return of the bounced. Cheques and give new cheques instead, and gave the cheque dated ………………….. with a value of ………………….TL.
Which is the subject of the complaint. To our client on ……………….. in relation to his debt. And the cheque receipt report regarding the cheques. Was issued between the client suspect and the complainant on ………………… The cheque was entered into the records of the company of. Which our client is an officer.
2-The client gave his statement about the incident at the Istanbul Chief Public Prosecutor’s Office. Where he resides and submitted the relevant pages of the journal book. Invoices and delivery notes showing the purchase of goods. Photocopies of the bounced cheques returned at the request of the complainant and the cheques issued for previous purchases. Showing that there is a commercial relationship between them and the complainant.
3- As stated above and as it can be understood from the current account statements submitted. By us together with the annexes submitted by the client. With his statement to the prosecutor’s office, there is a commercial relationship.
Between the complainant and the client, and as a result of the shopping made between them. The cheques subject to this complaint were given by the complainant to the company owned by the client with his own consent. Therefore, there is no offence as claimed by the complainant and the client. Has not committed this offence tried to be imposed on him.
CONCLUSION and REQUEST.
As a result of the reasons presented and explained above. We submit to your tensip and opinions that the client should be decided. That there is no prosecution against the client since the client has not committed the offence attributed. To him.
Sincerely…
Defence Counsel
You can access our other article examples and petition examples by clicking here.