Simple Appeal Petition with Request for Extension of Time and Hearing

To be submitted to the relevant Criminal Division of the Regional Court of Justice , via the High Criminal Court, Ankara.

APPEAL AND TIME LIMITATIONS

DEFENDANT REQUESTING THE RULING: Name and Surname (Turkish Republic Identity Number: …), Address
DEFENSE ATTORNEY: Lawyer's Name and Surname, Address, Telephone
Number CRIME: Sexual assault, Deprivation of liberty
DATE OF NOTIFICATION: …/…/…

SUBJECT OF REQUEST: We request that our appeal and request for extension of time be accepted, that this judgment be overturned, that our client be released, and that the appeal review be conducted orally.

EXPLANATIONS:

1. 1. The court's ruling is contrary to procedure and law. The decision did not fully evaluate the defendant's defenses and the evidence presented. In particular, the testimonies of the witnesses presented by my client while describing the incident, and the technical investigations conducted regarding the location where the incident occurred, were disregarded. Our witnesses clearly stated that my client was completely innocent of the accusations and was elsewhere at the time of the incident. These witness testimonies, which could have altered the course of the trial, were not taken into account by the court.
   2. The technical investigation report regarding the incident stated that our client had no connection whatsoever to the crime scene, however, the findings of this report were not adequately addressed in the court's decision. Furthermore, examinations of our client's social media accounts and digital data clearly demonstrated no connection to the crime. This situation highlights shortcomings in the court's evidence gathering and evaluation process.
   3. The court rendered its decision without considering the defendant's behavior and circumstances at the time the alleged crime was committed. My client was at work on the date of the crime, and his colleagues can testify to this. This can be confirmed with written documents from the workplace and witness statements. However, the court disregarded these facts and found the defendant guilty.
   4. Since the reasoned judgment has not yet been served to us, we request an extension of time to prepare our grounds for appeal. Upon receiving the reasoned judgment, we will provide detailed information regarding the deficiencies and legal irregularities in the decision. During this process, we need to prepare to take the necessary legal steps to protect our client's rights.
   5. Our client's current detention is creating significant difficulties, both personally and within his family. Considering his health and the needs of his family, we believe he should be released. Furthermore, we request that both existing and newly obtained evidence be carefully evaluated to prove our client's innocence. For these reasons, we request that our client be released and that the appeal be heard in court.

LEGAL GROUNDS: Articles 286, 291, 299 of the Code of Criminal Procedure and related legislation.

CONCLUSION AND REQUEST: For the reasons briefly explained above, I respectfully request and demand that this judgment be overturned, that my client be released, that our request for an extension of time until the reasoned judgment is served upon us be granted, and that the appeal review be conducted orally. …/…/…

Defendant's Counsel
Attorney Name and
Surname