Application to the court for an increase in the amount of claims
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Criminal cases of Turkestan region
specialized
Inter-District Court
Plaintiff: E. K. T. defendant: K. A. N.
On increasing the size of claims
The specialized Inter-District Court for criminal cases of Turkestan region is conducting criminal proceedings No. 5198-22-00-1/36 with respect to A. N. K. In this criminal case, I previously filed a civil claim against A. N. K. for causing material and moral damage. Dear court, in my opinion, is subject to an increase in the statement of claim on the following grounds. In accordance with article 951 of the Civil Code of the Republic of Kazakhstan (special part) "moral damage is a violation of the rights and personal non – property benefits of individuals". According to the Constitution of the Republic of Kazakhstan, the Republic of Kazakhstan establishes itself as a democratic, secular, legal and social state, the most precious treasure of which is man and human life, rights and freedoms (Article 1), everyone has the right to life (Article 15), motherhood and fatherhood and childhood are under the protection of the state, caring for their children and raising them - parental rights and obligations (Article 27), Everyone has the right to freedom of work, free choice of activity and profession, everyone has the right to rest (Article 24), everyone is obliged to comply with the Constitution and laws of the Republic of Kazakhstan, respect the rights, freedoms, dignity and dignity of other people (Article 34).
Application to the court for an increase in the amount of claims
I used to be a healthy, mentally balanced person. My family situation was stable, I lived in peace with my spouse, cared for and raised our children. When I had free time, I spent time meeting my parents, relatives, friends. From childhood, I devoted myself to sports, achieved my dream in professional sports and became the owner of great achievements. Over the past 5 years, I have been engaged in wrestling training for children. Now I lost everything because of the defendant A. N. K. I, in January 2022, the defendant A. N. K. I was beaten, stabbed, and until now I have not found myself mentally, physically. First, my family situation has deteriorated. I spent 4 months in the hospital, lost my income and lost the opportunity to support my family. In addition, to relieve severe pain due to trauma operations, doctors gave me narcotic drugs with a very strong effect "morphine hydrochloride", "Promedol", "Tramadol", as a result of which my mental state changed, and our relationship with my spouse deteriorated. I even often hear that my spouse wants to divorce me. Relations with my father are not the same as before, and due to my current state of affairs, the two of us often come to terms. I used to spend family holidays with my relatives, and I lost even more. At night, I lose my sleep and fall into a state of hallucinations.
Seeing this, my mother is very worried. Currently, I am receiving treatment under the supervision of a narcologist of the Medical Center "Emirmed" in Almaty. 15.09.2022 at the Central Hospital of Maktaaralsky district, a decision will be made on my disability at the medical and social expert commission. As stated in the Constitution of the Republic of Kazakhstan, "every person has the right to life." But, in the Constitution, codes, laws, the concept of "life" is not spelled out. Even great thinkers and scientists have not developed a consensus on the concept of "life". I am not a lawyer, a thinker, but an ordinary person. For me," life " is to feel safe and sound, to have my parents safe and sound, to have the opportunity to take care of my family, to do something cute, to spend my free time with relatives and friends. From all this I was deprived by the defendant A. N. K. intentional hostility. Therefore, I believe that the defendant A. N. K. must pay the maximum value for the actions committed. In accordance with Article 169 of the Civil Procedure Code of the Republic of Kazakhstan "plaintiff ... by filing a written application before the court leaves to make a decision ... to increase the amount of claim claims ... right". On the basis of the above arguments, based on Article 169 of the Civil Procedure Code of the Republic of Kazakhstan, I ask the court:
A. N. K. In my favor to collect compensation for moral damage in the amount of 30,000,000 (thirty million) tenge.
Address as a witness: Almaty, Sh., 164, apartment 24, WhatsApp 8474.. P. E. E., address: Almaty, she. address: Almaty, St. S. S., 452, Apartment 3, WhatsApp 8775.. A. T. A., address: Almaty, S. S. STR., 452, apartment 3, WhatsApp 8701 жауап interrogation of Asylbekov;
Interrogation as a specialist-therapist of the maktaral Central District Hospital Atakent U. K. P. (WhatsApp 8700....).
I ensure that these persons appear at the court session. Appendix: A copy of the medical card on 12 sheets, doctor's recommendation Mo "Emirmed".
13.09.2022 E. K. T.
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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