Petition for additions to the case file as material evidence

 

To the senior investigator of the OP at the UE of the Medeu district of the DP of Almaty

to Police Major Kabitova D.K.

 

from the defense attorney of a witness who has the right to defend himself

Boya Tursungalievna – lawyer Nigmetov Sabit Davletovich

IIN 820125350700

79 Abylai Khan Ave., office 304, Almaty

Phone: 87009785755

 

 

 

the petition.

 

A criminal case is pending under the OP at the UP of the Medeu district of the DP of Almaty on the application of Koi A.T. against Boy M.T. on the fact of fraudulent actions.

During the interrogation, a witness entitled to defend Ba M.T. testified that she received funds from Koi A.T. in the amount of 12,000,000 tenge in debt, with interest in July 2024.

This is confirmed by an extract from the bank account of JSC Kaspi Bank Boy M.T. for the period from 05/23/2024 to 05/24/2024.

And also, the correspondence between the M.T. Boy and the A.T. Boy in the Vacap mobile application, according to which it is confirmed that the A.T. Girl lent money to the M.T. Boy at interest. Namely, on April 14, 2023, at 11:07 a.m., Ka A.T. writes "You will write a receipt for 2 million," to the question: "How much will you give?", Ka A.T. answers "1" on the same day at 11:08. This confirms that Ka A.T. lends money only at interest.

Also, according to the testimony of Boy M.T., she returned money to Koi A.T. in the amount of about 7,000,000 tenge, which is confirmed by receipts from Kaspi Gold of Kaspi Bank JSC dated 09/18/2024 in the amount of 40,000 tenge, dated 04/11/2025 in the amount of 500,000 tenge, dated 05/30/2025 in the amount of 500,000 tenge, 07/09/2025 in the amount of 500,000 tenge, dated 07/18/2025 in the amount of 40,000 tenge, 07/25/2025 in the amount of 200,000 tenge, dated 08/22/2025 in the amount of 300,000 tenge, dated 11/18/2025 in the amount of 20,000 tenge, dated 12/10/2025 in the amount of 20,000 tenge, dated 12/26/2025 in the amount of 500,000 tenge, from 31.12.2025 in the amount of 100,000 tenge.

Also, with the consent of Koi A.T. Ba M.T., on 18.09.2024, Kaspi Bank JSC replenished the accounts of Kaspi Gold to a woman named Aizhan K. in the amount of 940,000 tenge, a man named Yerlan S. in the amount of 900,000 tenge and Koi A.T. herself in the amount of 420,000 tenge. tenge, which is confirmed by photographs of receipts of "Kaspi gold" JSC "Kaspi Bank" dated 18.09.2024..

Also, at the request of Koi A.T., Ba M.T. wrote receipts for receiving money in the amount of 2,000,000 tenge 2 times on 07/05/2024 and 08/22/2024, while there was no actual transfer of money.

According 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 investigation of the circumstances necessary and sufficient for the proper resolution of the case.

According to Article 70 of the CPC of the Republic of Kazakhstan, the defender has the right to file petitions.

According to Article 99 of the CPC of the Republic of Kazakhstan, the petition is subject to consideration and resolution immediately after its application. In cases where an immediate decision on the application is not possible, it must be resolved no later than three days from the date of the application.

Based on the above, I ask:

- to attach to the case file as material evidence the statement of Kaspi Bank JSC on the bank account of Boy M.T. for the period from 05/23/2024 to 05/24/2024.;

- attach screenshots of correspondence between Boy M.T. and Koi A.T. to the case file as physical evidence in the Vacap mobile application, where Ka A.T. requires a receipt for 2,000,000 tenge for the transfer of money in the amount of 1,000 000 tenge;

- attach to the case file as material evidence the receipts of Kaspi Gold JSC Kaspi Bank dated 09/18/2024 in the amount of 40,000 tenge, dated 04/11/2025 in the amount of 500,000 tenge, dated 05/30/2025 in the amount of 500,000 tenge, 07/9/2025 in the amount of 500,000 tenge, dated 07/18/2025 in the amount of 40 000 tenge, 07/25/2025 in the amount of 200,000 tenge, dated 08/02/2025 in the amount of 300,000 tenge, dated 11/18/2025 in the amount of 20,000 tenge, dated 12/10/2025 in the amount of 20,000 tenge, dated 12/26/2025 in the amount of 500,000 tenge, dated 12/31/2025 in the amount of 100,000 tenge;

- attach screenshots of correspondence between Boy M.T. and Koi A.T. to the case file as physical evidence in the Vacap mobile application, where Ka A.T. agrees to transfer money to pay off a debt to a woman named "Aizhan K." to a man named "Yerlan";

- photos of receipts of "Kaspi Gold" JSC "Kaspi Bank" dated 09/18/2024 to a woman named "Aizhan K." in the amount of 940,000 tenge, to a man named "Yerlan S." in the amount of 900,000 tenge and Koi A.T. in the amount of 420,000 tenge;

- copies of receipts dated 07/05/2024 and 08/22/2024.;

- to conduct an additional interrogation of the victim Koi Aisula Tleuzhanovna on the circumstances set out in the petition;

- identify a woman named "Aizhan K." and a man named "Yerlan S." and interrogate them on the circumstances of the case.

 

 

Defender S. Nigmetov

                                                                  02/27/2026

 

 

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