Motion for Additional Interrogation of the Victim Regarding the Circumstances

To Senior Investigator of the Police Department under the Police Department 

of Medeu District of the Police Department of AlmatyPolice Major K.D. Kabitova

from counsel for the suspect Boy Mi Tursungalievna– Attorney Sabit Davletovich Nigmetov

IIN 820125350700Almaty, 79 Abylai Khan Avenue, Office 304tel. 87009785755

MOTION

A criminal case concerning Boy M.T. on the fact of fraudulent actions is being investigated by the Police Department under the Police Department of Medeu District of the Police Department of Almaty.

During the interrogation, the witness having the right to defense, Ba M.T., testified that the funds were received by her from Ka A.G. in the amount of 3,000,000 tenge as a loan, with interest, in October 2023. The victim, K A.G., denied this fact during the confrontation with Boy M.T.

This is confirmed by a bank statement from the bank account of Boy M.T. with Kaspi Bank JSC for the period from 11 October 2023 to 13 December 2023.

There is also correspondence between Boy M.T. and Kym A.G. in the WhatsApp mobile application, according to which it is confirmed that K A.G. provided money to Boy M.T. as a loan at 10% interest. Namely, on 11 October 2023 at 00:22, K A.G. writes: “3000000+10%ежемесячно”. On 2 December 2024 at 23:04, K A.G. writes: “6200000 қарызсың (должна)”, and on 28 January 2025 at 15:32, K A.G. writes: “Февральда 6 800 000 тг болады қарызын!”, i.e., K A.G. thereby confirmed that he had provided the money as a loan with interest, since without any grounds he immediately increased the amount of the debt by 600,000 tenge. Further, on 12 September 2025 at 16:24, K A.G. writes in the correspondence: “7,5 расписка жазып бер”, which, by its meaning, I presume means that K A.G. is demanding from Boy M.T. money already in the amount of 7,500,000 tenge, without having any grounds for doing so.

Pursuant to Article 24 of the Criminal Procedure Code of the Republic of Kazakhstan, the investigator is obliged to take all measures provided for by law for a comprehensive, complete and objective examination of the circumstances necessary and sufficient for the proper resolution of the case.

Pursuant to Article 70 of the Criminal Procedure Code of the Republic of Kazakhstan, the defense counsel has the right to file motions.

Pursuant to Article 99 of the Criminal Procedure Code of the Republic of Kazakhstan, a motion shall be considered and resolved immediately after it is filed. In cases where immediate decision-making on the motion is impossible, it shall be resolved no later than three days from the date of its filing.

Based on the foregoing, I REQUEST:

– to attach to the case file as physical evidence the bank statement of Kaspi Bank JSC concerning the bank account of Boy M.T. for the period from 11 October 2023 to 13 October 2023;

– to attach to the case file as physical evidence screenshots of the correspondence between Boy M.T. and Kym A.G. in the WhatsApp mobile application;

– to conduct an additional interrogation of the victim, Ka Aa Galimovich, regarding the circumstances set out in this motion.

Attachments: a bank statement of Kaspi Bank JSC concerning the bank account of Boy M.T. for the period from 11 October 2023 to 13 October 2023; screenshots of the correspondence between Boy M.T. and Kym A.G. in the WhatsApp mobile application, on 6 pages.

Defense Counsel S. Nigmetov

19 March 2026 

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