Application for admission of the defender to participate in the criminal case and familiarization with the materials of the criminal case
Ministry of Internal Affairs of the Republic of Kazakhstan,
Turkestan Region Police Department
Maktaaral District Police Department
Turkestan region, Maktaaral district,
Myrzakent village, Madikozhaeva St., building 14.
From the defender: Lawyer Galymzhan Turlybekovich Sarzhanov
Law and Law Law FirmBIN 201240021767
Republic of Kazakhstan, 050002, Almaty,
79/71 Abylai Khan ave., office 304, Almaly district
www.zakonpravo.kzinfo@zakonpravo.kz
tel.: +7 708 578 57 58 / 8 727 978 57 55
Suspect: ESH
IIN ....
Turkestan region, Maktaaral district
The petition
on the admission of the defender to participate in the criminal case and familiarization with the materials of the criminal case
You are investigating the materials of the criminal case against Ea Sh.Ch., based on the elements of a criminal offense provided for in Article 174 of the Criminal Code of the Republic of Kazakhstan.
As part of the pre-trial investigation, E.S.Ch. is suspected of committing intentional acts aimed at inciting religious discord, as well as insulting religious feelings provided for in Article 174 of the Criminal Code of the Republic of Kazakhstan.
According to paragraph 9 of article 64 of the Criminal Procedure Code of the Republic of Kazakhstan, a suspect has the right to invite a lawyer, and he can exercise this right personally, as well as through his close relatives or trusted persons.
If the suspect, his relatives or trusted persons do not invite a lawyer, the investigating authority is obliged to ensure the participation of a lawyer (in accordance with part 3 of Article 67 of the CPC RK).
According to Article 99 of the Criminal Procedure Code of the Republic of Kazakhstan, participants in criminal proceedings have the right to apply to the person conducting the pre-trial investigation, the prosecutor, the judge (court) with petitions for carrying out procedural actions or making procedural decisions aimed at establishing circumstances relevant to the criminal process, as well as to ensure the rights and legitimate interests of the person who filed the petition, or the person he represents.
The application is subject to review and resolution immediately after its application. In cases where immediate decision-making is not possible, it must be reviewed no later than three days from the date of his application.
Based on the above and guided by Articles 64 and 99 of the Criminal Procedure Code of the Republic of Kazakhstan, I request:
· To allow the defense lawyer, Galymzhan Turlybekovich Sarzhanov, to participate in the criminal case as a defender of Ea Sh.Ch.;
· To familiarize with all the procedural documents in the case against Ea Sh.Ch. and provide copies of them;
· Provide a link or a copy of the audio-video materials sent by Eim Sh.Ch. to the Atakent Bauyrlar group on the WhatsApp social network (consisting of 40 participants), namely links to the sermons "Dilmurat Abu Muhammad" and "Nazratullah Abu Mariam" published on the YouTube social network;
· Provide an answer to this petition within the time limits established by Article 99 of the CPC RK.
With respect,
Lawyer: Galymzhan Sarzhanov
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