MOTION TO ATTACH A COPY OF THE RECEIPT TO THE MATERIALS OF THE INVESTIGATOR’S MOTION FOR AUTHORIZATION OF DETENTION AS A PREVENTIVE MEASURE

To:Specialized Inter-District Investigative Courtof Almaty

Presiding Judge:Zh.K. Iskakbayeva

From:Defense Counsel for the Suspect, Boi Mi T –Attorney Sabit Davletovich Nigmetov

IIN 820125350700Office 304, 79 Abylai Khan Avenue, Almaty+7 700 978 57 55

MOTION

The Specialized Inter-District Investigative Court of Almaty is currently considering the investigator’s motion for authorization of detention as a preventive measure against Boi M.T. (Case Material No. 7595-26-00-2-3m/3319).

Pursuant to Part 1 of Article 138 of the Criminal Procedure Code of the Republic of Kazakhstan, when deciding whether a preventive measure is necessary and, if so, which particular preventive measure should be applied, in addition to the grounds specified in Article 136 of this Code, as well as when establishing the additional restrictions specified in Part 2 of Article 137 of this Code, the following circumstances shall be taken into account:

1. the gravity of the criminal offense committed;
2. the personality of the suspect or accused and his/her age;
3. health condition;
4. family status and the presence of dependents in the family;
5. the strength of the suspect’s or accused’s social ties;
6. the reputation of the suspect or accused;
7. occupation;
8. whether the suspect or accused has a permanent place of employment or study;
9. financial status;
10. whether the suspect or accused has a permanent place of residence and other circumstances.
11. In the absence of the grounds listed in Article 136 of this Code, the gravity of the criminal offense committed may not constitute the sole ground for choosing detention as a preventive measure.

At present, the victim, K.M. A.G., has been paid KZT 6,200,000 (six million two hundred thousand tenge) towards repayment of the debt.

Based on the foregoing,

I HEREBY REQUEST THE COURT TO:

– attach to the materials of the investigator’s motion for authorization of detention as a preventive measure against Boi Mi T. a copy of the receipt issued by K.A.G. confirming receipt of KZT 6,200,000 (six million two hundred thousand tenge);

– examine the victim, K.A. Galimovich, by questioning him during the court hearing, telephone number +7 701 ..., in order to confirm the fact that he received the money.

Attachment: Receipt issued by K.A.G.

Defense Counsel __________________ S. Nigmetov

20 March 2026 

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