Appeal on violation of labor protection rules
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Judicial Board of Appeal on criminal cases of the Almaty City Court
Advocate No. 6 AGCA Sarzhanov G.T.Almaty Bukharzhyrau
64, office 15. + 7 (708) 578 57 58.
THE APPEAL
on the verdict of the Bostandyk district court No. 2 of Almaty dated 07.07.2018
By the verdict of the district court no.2 Bostandyk district of Almaty dated 07.07.2018 __________. 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. When imposing the punishment, the court did not take into account such aggravating circumstances as the actions taken by it aimed at compensating for the harm caused by the crime, in particular, the statements of the injured party to compensate my clients for material damage in the form of payment for the funeral costs of the deceased workshop foreman T. Kuzeev, as well as compensation for moral damage. When prescribing the punishment, please take these circumstances into account: - sincere repentance __________., the degree of guilt of my client in the incident, the degree of guilt of the victim himself, who was drunk at work, the presence of young children and unemployed friends, who as a result will be left without means of livelihood, the positive characteristics of the convicted person from his place of work, as well as from his place of residence. Thus, by the district court No. 2 of the Bostandyk district.Almaty at the sentencing of __________. The criminal law was incorrectly applied. When imposing punishment, the court unreasonably failed to apply the provisions of Article 53 of the Criminal Code of the Republic of Kazakhstan, which led to the imposition of unfair, excessively harsh punishment by the court.
Based on the above, in accordance with Articles 414-425,423, 431, Part 1, paragraph 2 of the Criminal Procedure Code of the Republic of Kazakhstan,
ask: Verdict of the district court No. 2bostandyk district of Almaty dated 07.07.2015 in respect of __________ Article 156, Part 2 of the Criminal Code of the Republic of Kazakhstan should be amended to impose a minimum fine and a minimum term of deprivation of the right to hold certain positions.
Application: 1. A copy of the appeal
Sincerely, Lawyer: ________________/Sarzhanov G.T. "___"___________ 2019
Attention!
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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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