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Home / Forms / MOTION TO ATTACH DOCUMENTS TO THE CRIMINAL CASE FILE AND REQUEST FOR A FORENSIC RELIGIOUS STUDIES EXAMINATION

MOTION TO ATTACH DOCUMENTS TO THE CRIMINAL CASE FILE AND REQUEST FOR A FORENSIC RELIGIOUS STUDIES EXAMINATION

MOTION TO ATTACH DOCUMENTS TO THE CRIMINAL CASE FILE AND REQUEST FOR A FORENSIC RELIGIOUS STUDIES EXAMINATION

 

 

To: Investigator of the Investigative Division of the Police

 Department of the Maktaaral DistrictDepartment

 of Police of the Turkestan RegionA.A. Makhamadov

From: Attorney Galyмzhan Turlybekovich Sarzhanov

IIN 850722301036

Law Firm “Zakon i Pravo”

BIN 201240021767

79 Abylai Khan Avenue, Office 304, Almaty, Republic of Kazakhstan

info@zakonpravo.kz / www.zakonpravo.kz

+7 708 578 57 58; +7 727 971 78 58

Acting in the interests of the suspectEa Sha Chamshedovich

MOTION

Pursuant to the requirements of Article 272-1 of the Criminal Procedure Code of the Republic of Kazakhstan, I hereby notify you that on April 23, 2026, the Law Firm “Zakon i Pravo” commissioned a forensic religious studies examination in criminal case No. 255143031000127 concerning Ea Sh.Ch., in connection with the alleged elements of the criminal offense provided for by Part 1 of Article 174 of the Criminal Code of the Republic of Kazakhstan.

According to Expert Report No. 35 dated April 29, 2026, the texts contained in the materials examined (Screenshot_20250313_115239_WhatsApp, Screenshot_20250313_133530_WhatsApp, Screenshot_20250313_133534_WhatsApp, VID-20250201-WA0068, VID-20250217-WA0070) promote ideas of the Salafi trend within Islam (within the framework of Sunni theology), while no idea of hostility of one particular religious group toward another religious group is promoted.

Pursuant to Article 111 of the Criminal Procedure Code of the Republic of Kazakhstan:

1. Evidence in a criminal case shall mean lawfully obtained factual data on the basis of which the inquiry body, inquirer, investigator, prosecutor, or court, in the manner prescribed by this Code, establishes the presence or absence of an act provided for by the Criminal Code of the Republic of Kazakhstan, whether such act was committed or not committed by the suspect, accused, or defendant, his or her guilt or innocence, as well as other circumstances relevant to the proper resolution of the case.

2. Factual data relevant to the proper resolution of a criminal case shall be established by the testimony of the suspect, accused, victim, witness, witness having the right to defense, expert, and specialist; by an expert's or specialist's opinion; physical evidence; records of procedural actions; and other documents.

Based on the foregoing, I REQUEST THAT YOU:

  • attach to the materials of criminal case No. 255143031000127 concerning Ea Sh.Ch. Expert Report No. 35 dated April 29, 2026, consisting of 12 pages;
  • attach to the materials of criminal case No. 255143031000127 concerning Ea Sh.Ch. the request for a forensic religious studies examination, consisting of 4 pages.

Attachments: Expert Report No. 35 dated April 29, 2026 — 12 pages; request for a forensic religious studies examination — 4 pages.

Attorney G.T. Sarzhanov

                                                                 **April 29, 2026**

 

 

 

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