MOTION FOR RECOVERY OF REPRESENTATIVE’S LEGAL FEES AND EXPENSES
To the Taldykorgan City Court of the Zhetisu Region
Presiding JudgeS.S. Yaroshenko
From: Attorney Sarzhanov Galymzhan Turlybekovich
Law Firm “Zakon i Pravo”BIN 201240021767
Office 304, 79/71 Abylai Khan Avenue,Almaly
District, Almaty, 050002,Republic of Kazakhstan
Tel.: +7 708 578 5758
MOTION FOR RECOVERY OF REPRESENTATIVE’S LEGAL FEES AND EXPENSES
Civil case No. 3310-26-00-2/985 is currently pending before the Taldykorgan City Court of the Zhetisu Region upon the claim of Ba M.A. and Ta A.B. against the Police Department of the Zhetisu Region and the Ministry of Internal Affairs of the Republic of Kazakhstan for reinstatement at work.
Pursuant to Paragraph 1 of Article 113 of the Civil Procedure Code of the Republic of Kazakhstan (the “CPC”), upon the motion of the party in whose favor the judgment was rendered, the court shall award from the other party the expenses actually incurred by that party for payment of the services of a representative (several representatives) who participated in the proceedings and was not in an employment relationship with that party. In property claims, the total amount of such expenses may not exceed ten percent of the satisfied portion of the claim. For non-property claims, expenses shall be recovered within reasonable limits, but may not exceed three hundred monthly calculation indices.
On 4 December 2025, the Plaintiffs, B M.A. and T A.B., entered into Legal Services Agreement No. 0412/25 with the Law Firm “Zakon i Pravo”, pursuant to which B M.A. and T A.B. each paid KZT 750,000 for the services of the Law Firm “Zakon i Pravo”.
The above amount of KZT 750,000 is subject to recovery from the Defendants.
Based on the foregoing, I respectfully request the Court to:
- recover, jointly and severally, from the State Institution “Police Department of the Zhetisu Region of the Ministry of Internal Affairs of the Republic of Kazakhstan” and the State Institution “Ministry of Internal Affairs of the Republic of Kazakhstan” in favor of Ba Ma Abilkassimovich the expenses incurred for payment of representative’s legal services in the amount of KZT 750,000;
- recover, jointly and severally, from the State Institution “Police Department of the Zhetisu Region of the Ministry of Internal Affairs of the Republic of Kazakhstan” and the State Institution “Ministry of Internal Affairs of the Republic of Kazakhstan” in favor of Ta Aa Bakbergenuly the expenses incurred for payment of representative’s legal services in the amount of KZT 750,000.
Attachments:
- Legal Services Agreement No. 0412/25 dated 4 December 2025;
- Receipt confirming payment for legal services by B M.A.;
- Receipt confirming payment for legal services by T A.B.
Attorney Sarzhanov G.T.
22 April 2026
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