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An appeal for violation of labor protection rules

An appeal for violation of labor protection rules

Attention! The Law and Law Law Company draws your attention to the fact that this document is basic and does not always meet the requirements of a specific situation. Our lawyers are ready to assist you in drafting any legal document that suits your situation. For more information, please contact lawyer Kenesbek Islam by phone.; +7 (708) 971-78-58; +7 (727) 971-78-58.

Judicial Board on criminal cases of the Almaty City Court  

Lawyer ............. legal address:city of Almaty ............ Tel.8 705 ..............  

acting in the interests of the convicted person ............... 02.09.19... G.R., convicted under 

Part 2 of Article 156 of the Criminal Code of the Republic of Kazakhstan  

THE APPEAL

on the verdict of the district court no.2 Bostandyksky district of Almaty city dated 07/25/20... year

By sentence

District court no .2 Bostandyk district of Almaty dated 07/25/20.. year ...............He was found guilty of committing a crime under Article 156, Part 2 of the Criminal Code of the Republic of Kazakhstan, and was fined 200 monthly calculation indices, with the deprivation of the right to hold certain positions for a period of 3 years. The above-mentioned agreement regarding the imposition of punishment is unfair due to its excessive severity. The court did not take into account such mitigating punishments as the actions taken by him aimed at making amends for the harm caused by the crime, in particular, the statements of the injured party about the compensation of material damage to my client in the form of payment for medical expenses, as well as compensation for moral damage.

 

When assigning a punishment, please take into account these circumstances: - sincere repentance .............., the degree of guilt of my client in what happened, the degree of guilt of the victim himself, who was in a drunken state at work, the presence of young children and an unemployed spouse, who as a result will be left without means of livelihood, the positive characteristics of my client from his place of work, and also from the place of residence. Temsam, District Court No. 2 of the Bostandyk district of Almaty when making a verdict in respect of .............. an incorrect application of the criminal law was allowed. 53 of the Criminal Code of the Republic of Kazakhstan, which led to the imposition of unfair, excessively harsh punishment by the court. By virtue of Part 4 of art. 55 of the Criminal Code of the Republic of Kazakhstan "In the presence of exceptional circumstances related to the goals and motives of the act, the role of the perpetrator, his behavior during or after the commission of a criminal offense, and other circumstances that significantly reduce the degree of public danger of the act, as well as with the active assistance of a participant in a group criminal offense to disclose the acts committed by the group, punishment may be imposed below the lowest limit provided for by the relevant article of the Special Part of this Code, or the court may impose a more lenient type of punishment, as provided for in this article, or not to apply the additional type of punishment provided for as mandatory." On the basis of the above, in accordance with Articles 414-425, 423, 431, part 1, paragraph 2 of the CPC

ask:

Verdict of the district court No. 2 of the Bostandyk district of Almaty dated July 25, 2018 in respect of .................. According to Article 156, Part 2 of the Criminal Code of the Republic of Kazakhstan, to amend and impose punishment in the form of a minimum fine and a minimum term of deprivation of the right to hold certain positions.

Lawyer                                                                           ………………

I am familiar with the defender's complaint and support it. ..............

"___" August 20...

 

Attention!   

       Law and Law Law Law draws your attention to the fact that this document is basic and does not always meet the requirements of a particular situation. Our lawyers are ready to assist you in legal advice, drawing up any legal document suitable for your situation.  

 For more information,  please contact a Lawyer / Attorney by phone: +7 (708) 971-78-58; +7 (700) 978 5755, +7 (700) 978 5085. 

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