二审辩论意见书范文

二审辩论意见书范文
（中英文版）
English:
Dear Honorable Judges,
I am writing to present my second-instance oral argument regarding the case at hand.Firstly, I would like to emphasize that the appeal is based on new evidence that was not available during the first trial.This evidence is crucial in proving the innocence of my client and merits a rehearing of the case.
Furthermore, I would like to address the procedural errors that occurred during the first trial.It has come to light that the presiding judge failed to consider the testimonies of key witnesses, thereby denying my client a fair trial.Additionally, the evidence presented by the prosecution was insufficient and did not meet the burden of proof required by law.
Moreover, I would like to highlight the lack of credibility of the witness testimonies.Several witnesses have recanted their testimonies, stating that they were coerced into providing false statements.This casts doubt on the reliability of the evidence presented against my client.
In conclusion, I urge the court to reverse the judgment of the first instance and acquit my client based on the new evidence and procedural errors.I firmly believe that a fair and just trial is necessary in this case to ensure that the truth prevails.
中文：
尊敬的法官们，
我谨以此书面意见书就本案提出二审辩论。

首先，我想强调，本上诉是基于一审期间未获得的新证据。

这些证据对于证明我的委托人的清白至关重要，并足以引起本案的重审。

此外，我想针对一审期间出现程序错误发表意见。

经查明，主审法官未考虑关键证人的证言，从而剥夺了我的委托人公正审判的权利。

另外，公诉方提供的证据不足，未达到法律规定的证明标准。

此外，我想强调的是，证人证言的真实性存在问题。

有几名证人已经撤回了他们的证言，称其被强迫提供虚假陈述。

这对控方提供的证据可靠性产生了怀疑。

总之，我请求法院根据新证据和程序错误，撤销一审判决，对我的委托人予以无罪释放。