How to write a criminal complaint

Plaintiff of the indictment: Xu Moumou Plaintiff: Li Defendant: Zhang Moumou Defendant: 1. Investigate the defendant's alleged fraud and investigate his criminal responsibility according to law; 2. Order the defendant to return the money owed by the plaintiff respectively. Facts and reasons: In May 2009, the plaintiff Xu Moumou learned through the introduction of his classmate Ye Moumou that the defendant could arrange to attend an employment interview, and the job content was airport ground handling, but Zhang Moumou said that he had to pay 36,000 yuan to attend the interview. Xu believes that Zhang Moumou is a teacher in the school admissions office and should not cheat students. In May 2009, China Agricultural Bank, located near Ma Po, Shunyi District, Beijing, credited 36,000 yuan to the bank account of the defendant Zhang Moumou. When paying, Zhang Moumou accompanied him and wrote a receipt, promising to refund all the fees within one week if he failed the interview. From the end of June to the beginning of July, 2009, Xu participated in the interview, but failed, and Zhang Moumou did not refund any fees. Until the end of 2009, Zhang Moumou recommended Xu to attend an interview. The job content turned out to be to apply for a membership card, but Xu refused to attend. 20 10 Zhang Moumou introduced another person, Xu Moumou, to attend the interview. Although the work place is really the airport, the work content still does not belong to the ground crew. From July, 20 10, the plaintiff Xu asked the defendant Zhang Moumou to refund the fee, but it was shirked by him for various reasons such as illness of the elderly at home. Within two months of 20 10,1,12, the defendant Zhang Moumou returned 1000 yuan every month, totaling 2,000 yuan, and the remaining 33,000 yuan has not been returned yet. It is understood that Zhang Moumou cheated the plaintiff Li Moumou in the same way. In mid-September, 2009, Defendant Li received a phone call from Defendant Zhang Moumou, saying that she could be arranged as a flight attendant of Spring Airlines, but asked her to pay120,000 yuan, and promised a full refund if she failed to perform. In view of Zhang Moumou's work in the Admissions Office and his trust in Zhang Moumou, in June 2009, Li remitted RMB120,000 yuan to Zhang Moumou account. Zhang Moumou concealed the property of Li, the plaintiff for his illegal purpose, by signing an agreement. After the remittance, Zhang Moumou informed Li to fill in the information on the recruitment website of Spring Airlines, and then asked Li to wait for the interview notice. Li Wei received an interview notice from Spring Airlines, and Zhang Moumou insisted that Li attend the interview. From the middle and late June, 5438 to February, 2009, Li participated in the interview of Spring Airlines, but was rejected in the preliminary examination stage and could not attend the interview at all. Later, Li asked Zhang Moumou to return the full amount as agreed, but Zhang Moumou refused, claiming that he could arrange work by introducing him to other interviews, but Li did not receive any interview notice since then. At Li's repeated urging, it was 85 thousand. 20 10 in June, Li again asked Zhang Moumou to return the expenses. Zhang Moumou claimed that it would be returned by the end of September, but it was still not returned by the end of September. During this period, Zhang Moumou's phone was down for a time, which caused Li to lose contact with him. After many twists and turns, he contacted Zhang Moumou through the school, but it was still delayed. Only in February 2065,438+00, 65,438+0,000 yuan was returned, and 36,000 yuan was still outstanding. Defendant Zhang Moumou used his status as a teacher in the Admissions Office of his school and the plaintiff's eagerness to graduate and get employment to defraud the plaintiff's trust, falsely claiming that he could arrange an employment interview for him, and demanded huge fees from the plaintiff. But the reality is that the defendant simply has no ability to arrange the required work for him. When the plaintiff asked for a refund, the defendant tried every means to deny it, used various reasons to shirk, play hooliganism, stop calling and deliberately avoided the plaintiff, which shows that he illegally occupied the plaintiff's money and refused to return it. Accusing Xu and Li of facing graduation, but eager to find a satisfactory job, they were cheated by school teachers before entering the society. Defendant Zhang Moumou, as a people's teacher, not only failed to set an example, but also extended the evil criminal means to the inexperienced students. This is unforgivable. If not severely punished, the purity of people's teachers will be seriously affected, and the legitimate rights and interests of students will be difficult to be guaranteed. The defendant Zhang Moumou's behavior fully conforms to the constitutive requirements of the crime of fraud stipulated in the criminal law. Therefore, the plaintiff specially requests your bureau to file a case according to law and investigate the defendant's criminal behavior, expecting that the sacred sword of law can severely punish the defendant Zhang Moumou, investigate his criminal responsibility for fraud according to law, and order him to refund the unpaid fees and safeguard the defendant's legitimate rights and interests. Plaintiffs of Shunyi Branch of Beijing Public Security Bureau: Xu Moumou and Li Mou, August 20 1 1.

Legal objectivity:

Criminal procedure law

Article 110

Any unit or individual who discovers criminal facts or suspects has the right and obligation to report to the public security organ, the people's procuratorate or the people's court. Victims have the right to report and accuse criminal facts or criminal suspects who infringe their personal and property rights to public security organs, people's procuratorates or people's courts. Public security organs, people's procuratorates or people's courts shall accept reports, complaints and reports. If it does not belong to its own jurisdiction, it shall be transferred to the competent authority for handling, and the informant, complainant and informant shall be notified;

For those who are not under their jurisdiction and must take emergency measures, they should take emergency measures first and then transfer them to the competent department.