Petition to the court for the recovery of evidence from the bank

Semeysky City Court of the East Kazakhstan region,

to the judge _________________ 071400, Semey, Kabanbai Batyr St., __

8 _______________, _________ ____________@sud.kz

from the Defendant: .............. IIN: ......................

Proxy representative: Galymzhan Turlybekovich Sarzhanov

IIN: 850722301036. Almaty, Medeu district,050002, Zhibek Zholy ave., 50, office 202,

Business center Quarter. info@zakonpravo.kz / www.zakonpravo.kz + 7 (708) 578 57 58.

REQUEST for evidence

Q, is there a civil case in your case № .................. dated 10/25/20...... of the year according to the claim of JSC "_______________" to an individual entrepreneur ..................................... on the recovery of the amount of debt and foreclosure on mortgaged property. Earlier, we sent to the Bank an Application for the issuance of documents dated 04/12/2018, where they asked for debt calculations, personal account statements and other documents according to the list of the specified application. However, the bank, under all possible pretexts, refuses to issue the requested documents to us, and therefore they are forced to request the documents through the court.

46. Civil Procedure Code of the Republic of Kazakhstan Rights and obligations of persons participating in the case Persons participating in the case have the right to get acquainted with the case materials, make extracts from them and make copies; file challenges; present evidence and participate in their study; ask questions to other persons participating in the case, witnesses, experts and specialists; submit petitions, including for measures to secure the claim, to provide evidence, to request additional evidence, and to apply conciliation procedures; provide oral and written explanations to the court; to present their arguments on all issues arising during the trial; to object to petitions and arguments of other persons involved in the case; to participate in court debates; to get acquainted with the minutes of the court session and submit written comments on it; to appeal decisions, rulings and court orders; to enjoy other procedural rights granted by the legislation of the Republic of Kazakhstan on civil legal proceedings.

Petition to the court for the recovery of evidence from the bank

Based on the above, guided by Article 46 of the Civil Procedure Code of the Republic of Kazakhstan, a petition to the court for the recovery of evidence from the bank

I ask the court:

For the purpose of a comprehensive, complete and objective consideration of the said civil case, it is necessary to request from the bank all the documents listed below, after which the court will be provided with evidence that may affect the content of the decision.

A copy of the Guarantee Agreement;

A copy of the Insurance Contract;

All copies of Bank Loan Agreements with repayment schedule;

All additional agreements to the bank loan agreement with repayment schedules;

All pledge agreements and additions to the agreement;

Personal loan account statement;

Extract from an overdue personal account;

Extract from an open current account;

Detailed debt calculation;

All available copies of documents on payment of account opening fees, insurance, loan application fees, etc.;

All correspondence between the Borrower and the bank;

The rules on internal policy, namely, a document outlining the conditions for granting loans to individuals and legal entities;

Sincerely, Representative by proxy: ________________/Sarzhanov G.T. "___"___________20........ G.

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