MOTION TO THE INVESTIGATOR TO CONSOLIDATE CRIMINAL CASES INTO A SINGLE PROCEEDING
To: Investigator of the Investigation Departmentof the Police Department
of Almaty
Regionof the Ministry of Internal Affairs of the Republic of Kazakhstan
A.N. Mukishev
1 Industrialnaya Street, Konaev.
From: Legal Consultant
Kenesbek Islam Mukhameduly
IIN 970103300774
Law Firm “Zakon i Pravo”
BIN 201240021767
Office 304, 79 Abylai Khan Avenue, Almaty, Republic of Kazakhstan
+7 708 971 78 58
ACTING IN THE INTERESTS OF: AYS
IIN ...
3 Zh... Street, Almaty, Republic of Kazakhstan
MOTION
to Consolidate Criminal Cases into a Single Proceeding
The criminal case initiated on the basis of the complaint filed by Aa IS against ZB.N. concerning fraud under Article 190 of the Criminal Procedure Code of the Republic of Kazakhstan (hereinafter – the CPC), registered in the Unified Register of Pre-Trial Investigations (ERDR) under No. 261900031000268, is currently being investigated by A.N. Mukishev, Investigator of the Investigation Department of the Police Department of Almaty Region.
At the same time, it has become known that another criminal case, No. 261900031000265, is being investigated by the Police Department of Almaty Region. The said case was initiated on 1 June 2026 on the basis of a complaint filed by B Sh.U. against Za B.N. under Part 1 of Article 190 of the Criminal Code of the Republic of Kazakhstan and registered in the ERDR under No. 261900031000265.
The circumstances of the above-mentioned criminal cases are substantially interconnected. In both cases, the actions of the same person, Za B.N., are being investigated in connection with his receipt of funds from victims and subsequent failure to return such funds, as well as the issue of whether he had an initial intent to unlawfully appropriate another person's funds through deception or abuse of trust.
The evidence and circumstances established within one criminal case may be directly relevant to the proper legal assessment of Za B.N.'s actions in the other episode. Separate investigation of the said episodes prevents their examination in their entirety and does not allow for a comprehensive assessment of the nature and direction of Za B.N.'s actions.
Pursuant to Part 1 of Article 43 of the Criminal Procedure Code of the Republic of Kazakhstan, criminal cases concerning a person who has committed several criminal offenses may be consolidated into a single proceeding.
According to Part 3 of Article 43 of the CPC of the Republic of Kazakhstan, consolidation of criminal cases shall be carried out on the basis of a resolution of the authority conducting the criminal proceedings.
The consolidation of the above-mentioned criminal cases will ensure a comprehensive, complete and objective examination of the circumstances surrounding Za B.N.'s receipt of funds from different victims, verification of his method of operation, the actual conduct of the business activities claimed by him, the movement of the funds received, and, most importantly, the time at which his intent arose and its direction in relation to each episode.
Based on the foregoing and pursuant to Articles 24, 43 and 99 of the Criminal Procedure Code of the Republic of Kazakhstan,
I HEREBY REQUEST THAT YOU:
- Consolidate criminal case No. 261900031000268, initiated on the basis of the complaint filed by the victim Aa IS against Za B.N., and criminal case No. 261900031000265, initiated on the basis of the complaint filed by B Sh.U. against Za B.N., into a single proceeding in accordance with Article 43 of the Criminal Procedure Code of the Republic of Kazakhstan.
Respectfully,
Representative of the Victim:Kenesbek I.M.
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