Motion to the Investigator to Send a Request to the Telecommunications Operator to Establish the Location of a Subscriber Number

Motion to the Investigator to Send a Request to the Telecommunications Operator to Establish the Location of a Subscriber Number
To the Senior Investigator of the Police Department under the
Medeu District Police Department of the Police Department of Almaty
Police Major D.K. Kabitova
From the defense counsel of the witness having the right to defense
Boy Mi Tursungalievna – Attorney Sabit Davletovich Nigmetov
IIN 820125350700
Almaty, 79 Abylai Khan Avenue, Office 304
Tel. 87009785755
MOTION
to send a request to the telecommunications operator to establish the location of a subscriber number
A criminal case based on the statement of Aoy S.T. against Boy M.T. on the fact of fraudulent actions is being investigated by the Police Department under the Medeu District Police Department of the Police Department of Almaty.
In her statement and during the confrontation with Boy M.T., Aа S.T. claims that on October 16, 2025, at approximately after 20:00, she gave Boy M.T. cash in the amount of 4,100,000 tenge as a loan on Karkaraly Street in Duman microdistrict of Medeu District of Almaty.
Ba M.T. categorically denies Aoy S.T.’s testimony in this part.
According to the information of the public procurement portal of the Republic of Kazakhstan, Aа STenesbekovna is registered at the following address: Kyzylkairat village, Talgar District, Almaty Region, subscriber number +7 771 412 28 90.
Pursuant to Article 24 of the Criminal Procedure Code of the Republic of Kazakhstan, the investigator is obliged to take all measures provided for 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 submit 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 submitted. In cases where immediate decision-making on the motion is impossible, it shall be resolved no later than three days from the date of its submission.
Based on the foregoing, I request:
To send a request to the mobile telecommunications operators servicing subscriber numbers +7 747 053 21 25, +7 708 697 22 35 (numbers of Boy M.T.) to provide information for the period from 17:00 on October 16, 2025 to 03:00 on October 17, 2025, namely:
information on the base stations (Cell ID, LAC, coordinates) through which the subscriber number was serviced;
the time of registration in the network and connections;
connection details (without disclosure of the content of conversations);
information on the IMEI of the device used (if available).
To send a request to the mobile telecommunications operator servicing subscriber number +7 771 412 28 90 (number of Aoy S.T.) to provide information for the period from 17:00 on October 16, 2025 to 03:00 on October 17, 2025, namely:
information on the base stations (Cell ID, LAC, coordinates) through which the subscriber number was serviced;
the time of registration in the network and connections;
connection details (without disclosure of the content of conversations);
information on the IMEI of the device used (if available).
If necessary, to apply to the investigating judge for authorization to obtain information constituting telecommunications secrecy.
Obtaining information on the location of the subscriber number will allow:
to establish the actual location of Boy M.T. and Aoy S.T. on October 16, 2025;
to verify the reliability of the testimony of the victim Aoy S.T.;
to confirm or refute the fact of the meeting between Aoy S.T. and Boy M.T. in Duman microdistrict of Medeu District of Almaty on October 16, 2025 after 20:00;
to exclude the unjustified involvement of Boy M.T. in criminal prosecution.
The above information is of substantial importance for the proper legal assessment of the actions and establishment of the truth in the case.
Based on the foregoing, I request that the motion be granted.
Attachment: screenshot of the “Public Procurement of the Republic of Kazakhstan” portal.
Defense Counsel S. Nigmetov
28.02.2026
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