Motion in a Criminal Case

To the Senior Investigator of the Police Department under the Medeu

 District Police Department of the Police Department of Almaty

Police Major Kabitova D.K.

from the defense counsel of the witness having the right to defense

Boy Mi Tursungalievna – Advocate Nigmetov Sabit Davletovich

IIN 820125350700

Almaty, 79 Abylai Khan Ave., Office 304

Tel. 87009785755

MOTION

A criminal case based on the statement of Aoy S.T. against Boy M.T. regarding fraudulent actions is under investigation at the Police Department under the Medeu District Police Department of the Police Department of Almaty.

During the interrogation and confrontation with Aoy S.T., the witness having the right to defense, Ba M.T., testified that she received monetary funds from Aoy S.T. as a loan at interest. She also stated that she did not receive cash in the amount of 4,100,000 tenge from Aoy S.T. Ba M.T. also explained that she repaid the debt to Aoy S.T. by transfers through the “Kaspi.kz” mobile application.

The above is confirmed by the bank account statement of JSC “Kaspi Bank” for the period from 19.12.2023 to 22.12.2023, as well as by “Kaspi Gold” receipts of JSC “Kaspi Bank” dated 27.12.2024 in the amount of 650,000 tenge, dated 27.11.2025 in the amount of 200,000 tenge, dated 06.08.2025 in the amount of 300,000 tenge, dated 09.07.2025 in the amount of 300,000 tenge, dated 29.06.2025 in the amount of 300,000 tenge, dated 25.05.2025 in the amount of 500,000 tenge, dated 21.02.2025 in the amount of 200,000 tenge, dated 26.12.2025 in the amount of 300,000 tenge, dated 27.01.2026 in the amount of 300,000 tenge.

In addition, there are messages between Boy M.T. and Aoy A.T. in the “WhatsApp” mobile application, according to which it is confirmed that Aa A.T. provided monetary funds to Boy M.T. as a loan at 15%.

Pursuant to Article 24 of the Criminal Procedure Code of the Republic of Kazakhstan, the investigator is obliged to take all measures provided 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 it is impossible to make an immediate decision on the motion, it shall be resolved no later than three days from the date of its filing.

Based on the foregoing, I hereby

REQUEST:

• to attach to the case materials as physical evidence the statement of the bank account of Boy M.T. with JSC “Kaspi Bank” for the period from 19.12.2023 to 22.12.2023;
• to attach to the case materials as physical evidence the “Kaspi Gold” receipts of JSC “Kaspi Bank” dated 27.12.2024 in the amount of 650,000 tenge, dated 27.11.2025 in the amount of 200,000 tenge, dated 06.08.2025 in the amount of 300,000 tenge, dated 09.07.2025 in the amount of 300,000 tenge, dated 29.06.2025 in the amount of 300,000 tenge, dated 25.05.2025 in the amount of 500,000 tenge, dated 21.02.2025 in the amount of 200,000 tenge, dated 26.12.2025 in the amount of 300,000 tenge, dated 27.01.2026 in the amount of 300,000 tenge;
• to attach to the case materials as physical evidence screenshots of the correspondence between Boy M.T. and Aoy S.T. in the “WhatsApp” mobile application;
• to conduct an additional interrogation of the victim Aoy S. Tenesbekovna regarding the circumstances set out in the motion.

Attachments: statement of the bank account of Boy M.T. with JSC “Kaspi Bank” for the period from 19.12.2023 to 22.12.2023, “Kaspi Gold” receipts of JSC “Kaspi Bank” dated 27.12.2024 in the amount of 650,000 tenge, dated 27.11.2025 in the amount of 200,000 tenge, dated 06.08.2025 in the amount of 300,000 tenge, dated 09.07.2025 in the amount of 300,000 tenge, dated 29.06.2025 in the amount of 300,000 tenge, dated 25.05.2025 in the amount of 500,000 tenge, dated 21.02.2025 in the amount of 200,000 tenge, dated 26.12.2025 in the amount of 300,000 tenge, dated 27.01.2026 in the amount of 300,000 tenge, screenshots of the correspondence between Boy M.T. and Aoy S.T. in the “WhatsApp” mobile application on 6 sheets.

Defense Counsel S. Nigmetov

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