Petition to the Investigator from the UP for conducting an investigative experiment
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To the investigator of the SB UP of the Yenbekshikazakh district of the DP of the Almaty region, police captain K.A.K.
Almaty region, Esik, Tokatayev str., No. 105.
from the Defense lawyer: Galymzhan Turlybekovich Sarzhanov
Law and Law Law Firm
BIN 201240021767
79/71 Abylai Khan Ave., office 304, Almaty.
info@zakonpravo.kz / www.zakonpravo.kz
+ 7 727 578 57 58; +7 708 578 57 58.
in the interests of: K.E.N.
IIN .................
Almaty region, g....., ul. ..........№46/5.
The petition
about conducting an investigative experiment
In the proceedings of the SB UP of the Yenbekshikazakh district, a criminal case is being investigated registered in the ERDR No. 221940031000829 on the grounds of a criminal offense provided for in art.190 of the Criminal Code of the Republic of Kazakhstan in relation to K.E.N.
The case file contains the response No. 01-05/564 of the Republican State Enterprise on the right of economic introduction "Institute of Botany and Phytointroduction" of the Committee of Forestry and Wildlife dated 10/20/2022, which states that birch and pine seedlings of the standard specified in the contract should be grown in greenhouses near the village of Satai, Enbekshikazakh district of the Almaty region, in 4 the monthly period of the winter months is not possible.
However, we disagree with the arguments of the Institute of Botany and Phytointroduction and declare that we are ready to prove the opposite. In addition, during the confrontation, experts found that the Institute of Botany and Phytointroduction had no practical experience in growing birch and pine seedlings in greenhouse conditions.
It should be noted that today the conditions for conducting an investigative experiment are the closest to the period in which the reproducible events took place before the conclusion of the contract with the victims.
In order to comprehensively, fully and objectively review the criminal case, it is necessary to conduct an investigative experiment to determine the possibility of growing seedlings in winter in greenhouse conditions using fertilizers.
In accordance with Article 258 of the Criminal Procedure Code of the Republic of Kazakhstan, an investigative experiment is carried out in order to verify and clarify information relevant to the case by reproducing certain actions, circumstances, circumstances of the event under investigation and conducting experiments. During the experiment, the possibility of perceiving certain facts, performing certain actions, and the occurrence of an event can be verified, as well as the sequence of events and the mechanism of trace formation.
According to Article 99 of the Criminal Procedure Code of the Republic of Kazakhstan, participants in criminal proceedings have the right to apply to the person conducting the pre-trial investigation, the prosecutor, the judge (to the court) with petitions for procedural actions or procedural decisions to establish the circumstances relevant during the criminal process, to ensure the rights and legitimate interests of the person who filed the petition, or represented by them faces.
In accordance with Article 24 of the Criminal Procedure Code of the Republic of Kazakhstan, the investigator and the inquirer are 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.
Based on the above and in accordance with Articles 99, 258 of the Criminal Procedure Code of the Republic of Kazakhstan,
ask you:
To conduct an investigative experiment on the possibility of growing seedlings, namely birch and pine seedlings in winter under greenhouse conditions in a greenhouse owned by the suspect K.E.N.
With respect,
Lawyer: _________/ Sarzhanov G.T.
"____"____________2023 G.
Attention!
Law and Law Law Law draws your attention to the fact that this document is basic and does not always meet the requirements of a particular situation. Our lawyers are ready to assist you in legal advice, drawing up any legal document suitable for your situation.
For more information, please contact a Lawyer / Attorney by phone: +7 (708) 971-78-58; +7 (700) 978 5755, +7 (700) 978 5085.
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