① Title: Write "Administrative Complaint".

② Basic information of the parties: mainly the basic information of the plaintiff and the defendant. If the plaintiff is a citizen, the name, gender, date of birth, nationality, native place, occupation (or work unit or position) and address shall be stated; If the plaintiff is a legal person or other organization, it shall specify its name, address, name of legal representative (or representative), position and telephone number of legal representative (or representative). The defendant column shall indicate the full name and address of the defendant's organ or organization, as well as the name and position of its legal representative or person in charge.

In the above case, when writing the administrative complaint, Liu should state his name, gender, age, nationality, occupation, work unit and residence, and also state the basic information of the other party in detail.

(2) Litigation request

The claim should be clear and specific. The plaintiff may make an appropriate request according to the nature of the defendant's administrative act and the degree of damage to his rights and interests.

For example, in this case, we can ask the court to judge the defendant to release Liu immediately and judge the defendant to bear the state compensation responsibility.

(3) Facts and reasons

This part should clearly write the factual basis and legal basis for bringing a lawsuit. The facts, reasons and results of the defendant's infringement on the plaintiff's legitimate rights and interests shall be stated clearly, and the focus of administrative disputes shall be pointed out. If the party refuses to accept the prosecution after administrative reconsideration, the process and result of the reconsideration decision made by the administrative organ for reconsideration shall also be stated. The reason is that, on the basis of stating the facts, it is analyzed according to laws and regulations to demonstrate that the litigation request is reasonable and legal.

In this case, Liu Yuming did state the fact and reason that he has been detained for more than two months and has not been released so far, which has exceeded the statutory time limit.

(4) Evidence and sources, names and addresses of witnesses.

This part requires the plaintiff to specify the name, number, source or clue of the evidence related to the proof. If there is a witness, the name and address of the witness shall be stated.

(5) the end and appendix

The tail includes: the name of the people's court; Signature of the prosecutor; Time of prosecution. The annex shall mainly list the contents and copies of the materials, and mark them separately.