Petition to the investigator in the criminal case / petition to the defense in the case
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Police Department of Zhambyl region of the Ministry of internal affairs of the Republic of Kazakhstan
State institution" Police Department of Shu district"
Senior investigator of the investigative department to police Captain G. K. Kikimbayev
081128, Zhambyl region, Shu district, Shu city, K. Satpayev STR., 66.
+7 72643 2-21-02, 8 747 74323 73.
From the defender: lawyer's office" Law and law " IIN 201240021767.
Republic of Kazakhstan, 050002, Almaty, Medeu district,
Abylai Khana Ave., house 79/71, office 304.
e-mail: info@zakonpravo.kz website: www.zakonpravo.kz Tel.:
+7 708 578 57 58 / 8 727 978 57 55.
Suspect: Sh. A .a. yin........ Address: Zhambyl region ... the city,..... 2/1 Street.
Application form
on termination of the criminal case
In your proceedings there is a criminal case No. 223166031000176 with respect to a suspected citizen of the Republic of Kazakhstan, born on September 8, 1990 in Zhambyl region, by nationality Kazakh, citizen of the Republic of Kazakhstan, under Paragraph 2 of Part 4 of Article 190 of the Criminal Code of the Republic of Kazakhstan and paragraph 1.4 of Part 3 of Article 190 of the Criminal Code of the Republic of Kazakhstan, who repeatedly committed fraud, that is, the acquisition of rights to foreign property in a particularly large amount by deception and abuse of trust. The victim in this case is zh.n.a. -according to him, the suspect said that in "M-Lombard" LLP there is an investment in gold, and if he invests in it, he receives 20% of his money every month, after 1 year all the money invested will be returned, and this case will be done through a citizen named Aigul, and the suspect said that by his criminal actions, the victim caused property damage in the amount of 16,617,000 Tenge, the total value of which exceeds the largest amount. However, the suspect received 6,079,000 tenge from the victim between 2020 and 2022. The transfer of these funds from the registered in the name of the mother of the suspect, but in the case of the suspect "Nurlukul K." to the named "Caspian gold" condyr, the victim from the "Caspian gold" condyryr was provided to the investigator in kind. It should be noted here that the suspect responded to the victim with evidence that from 2020 to 2022, with a percentage of the above-mentioned amount, he paid 21,255,500 tenge.
Petition to the investigator in the criminal case / petition to the defense in the case
The fact that the victim transferred 16,617,000 tenge to the suspect in cash or to the Caspian gold facility, or otherwise, has not been presented to the investigator to this day and has not found evidence by the investigation. At the same time, the victim's words about the investment in gold in "M-Lombard" LLP did not find a place in kind, his words were verbal and inaccurate. As specified in the norm of Article 19 of the Criminal Procedure Code of the Republic of Kazakhstan "presumption of innocence", everyone is considered innocent until his guilt in committing a criminal offense is proven in accordance with the procedure provided for by this code and established by a court verdict that has entered into legal force. No one with son is obliged to prove his innocence. Unresolved doubts about the guilt of the suspect, accused, defendant are interpreted in their favor. Doubts arising in the application of criminal and criminal procedure laws must also be resolved in favor of the suspect, accused, defendant. In accordance with Article 35 of the Criminal Code of the Republic of Kazakhstan, proceedings in a case are terminated on the grounds provided for in Paragraphs 1) and 2) of the first part of this article, both when the absence of an event of a criminal offense or the composition of a criminal offense is proved, and if all opportunities are used to collect additional evidence, their presence is not proved. At the same time, the relationship of the suspect with the victim can be classified as civil legal relations. Based on the above and in accordance with Articles 19, 35, 105 of the Criminal Code of the Republic of Kazakhstan,
Please:
In connection with the absence of the incident of a criminal offense or the composition of a criminal offense on the application of the victim zh.N.A. ;
Respond to the application within the time stipulated by law in accordance with Article 105 of the Criminal Procedure Code of the Republic of Kazakhstan.
Defender: ___________/ Sarzhanov Galymzhan Turlybekovich "___"_______2022 year
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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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