Petition to the Specialized Interdistrict Investigative Court
To the Specialized Interdistrict Investigative Court of Almaty
To the presiding judge Iskakbayeva Zh.K.
from the defender of the suspect, Boya Tursungalievna
– lawyer Galymzhan Turlybekovich Sarzhanov
Law and Law Law Firm
79/71 Abylai Khan ave., office 304, Almaly district, 050002, Almaty
info@zakonpravo.kz
www.zakonpravo.kz
Phone: +770085785758, +7 7009785755
the petition.
In the proceedings of the Specialized Interdistrict Investigative Court of Almaty, there is an investigator's petition for the authorization of a preventive measure in the form of detention of Boy M.T. (material No. 7595-26-00-2-3m/3319).
According to Part 1 of Article 138 of the CPC of the Republic of Kazakhstan, when deciding on the need to apply a preventive measure and which one, in addition to the grounds specified in Article 136 of this Code, as well as the establishment of additional restrictions specified in part two of Article 137 of this Code, should be taken into account:
1) the gravity of the crime committed;
2) the identity of the suspect, the accused, his age;
3) Health status;
4) marital status, presence of dependents in the family;
5) the strength of the suspect's and the accused's social ties;
6) the reputation of the suspect, the accused;
7) occupation;
8) whether the suspect or the accused has a permanent place of work or study;
9) property status;
10) the presence of a permanent place of residence and other circumstances.
2. In the absence of the grounds listed in Article 136 of this Code, the gravity of the crime committed may not be the only reason for choosing a preventive measure in the form of detention.
During the interrogation and confrontation, the investigator was informed by M.T. that she had borrowed money from the victims at interest. In support of the words of Boy M.T., screenshots of the correspondence of the Vacap mobile application and extracts from Kaspi Bank were provided, which were attached to the materials of the criminal case by the investigator's decision.
All these circumstances were subject to verification, and only after verification did the investigator have to decide whether to recognize M.T.'s case as a suspect and the measure of restraint against her.
Based on the above, I ask:
- to attach to the materials of the investigator's petition for the authorization of a preventive measure in the form of detention of Boyko Tursungalievna a copy of the investigator's decision to grant the petition for the attachment of the Caspi Bank statement, copies of receipts, screenshots of correspondence between Boy M.T. and A. S.T.;
Appendices: a copy of the resolution on the satisfaction of the petition.
Defender Sarzhanov G.T.
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