How to sue the property company in the procuratorate?

Give you a model for your reference. The main thing is to write several main parts clearly and try to be concise and clear.

XX Municipal People's Procuratorate

accuse

XX prosecution [20 10] No.xx

Defendant Liu XX, male, born on 19XX, Han nationality, junior high school education, office clerk of XX Company in XX City, a native of XX County, XX Province, and now lives in XX District. Row 3 13 of the dormitory bungalow of XX Company. 20 10 in may, 10 was criminally detained by XX public security bureau on suspicion of intentional homicide. On May 15 of the same year, with the approval of our hospital, the arrest was carried out by XX Public Security Bureau on the same day.

The case was investigated by the Public Security Bureau of XX City, and the defendant Liu XX was suspected of intentional homicide. 20 10 was transferred to our hospital for review and prosecution on May 20th. After accepting the case, our hospital informed the defendant of the right to entrust a defender on the same day, interrogated the defendant according to law, and reviewed all the case materials.

According to this law, it is hereby determined that:

Defendant Liu XX bears a grudge against the victim Xu XX(XX-year-old, manager of XX company) for work reasons, and plans revenge and murder. On may 20 10, 65438+3010, the defendant Xu XX entered the manager's office on the third floor of the company with a claw hammer and a woodworking chisel prepared in advance. While the victim Xu XX was sleeping in bed, he slammed the victim Xu XX's head for twenty or thirty times with a claw hammer, and then hit the victim Xu's face, neck and chest with a claw hammer. Defendant Liu XX fled the scene after committing the crime and was arrested and brought to justice by the public security organs at 8 pm that day.

The evidence for ascertaining the above facts is as follows:

1, claw hammer of material evidence, woodworking chisel;

2, the defendant's confession and defense;

3. Testimony of witnesses Zhu XX and Hou XX;

4. Records of on-site investigation;

5, forensic expert conclusion.

We believe that the defendant Liu XX intentionally killed people, and his behavior violated the provisions of Article 232 of the Criminal Law of People's Republic of China (PRC). If the facts of the crime are clear and the evidence is true and sufficient, he should be investigated for criminal responsibility for intentional homicide. According to the provisions of Article 141 of the Criminal Procedure Law of People's Republic of China (PRC), the defendant Liu XX was prosecuted in your hospital, so please sentence him according to law.

I am here to convey

XX intermediate people's court

Inspector: XXX

20 10 June XX

Attachment: 1 Defendant Liu XX is currently detained in XX Detention Center;

2 evidence list, witness list and a copy of the main evidence.