Sample Request for evidence
Attention! The Law and Law Law Company draws your attention to the fact that this document is basic and does not always meet the requirements of a specific situation. Our lawyers are ready to assist you in drafting any legal document that suits your situation. For more information, please contact lawyer Kenesbek Islam by phone; +7 (708) 971-78-58; +7 (727) 971-78-58.
To Almaly District Court No. 2 of Almaty
to the judge .............
Republic of Kazakhstan, Almaty, 050005,
267 Tole bi St.,
8 727 333 11 53.
From the defendant: LLP "..........."
BIN ...........
Office 402, Seifulin ave., Almaty.
8 727 ………………….
Representative by proxy:
Sarzhanov Galymzhan Turlybekovich
IIN: 850722301036.
Almaty, Medeu district,050002,
50 Zhibek Zholy Ave., office 202, Business center Block.
info@zakonpravo.kz / www.zakonpravo.kz
+ 7 (708) 578 57 58.
THE PETITION
on the demand for evidence
Q, is there a civil case in your case № .............. dated 07/05/20.... of the year according to the claim of gr. .........., to THE LLP "............" on the recovery of travel expenses in the amount of 564,092 tenge. During the trial, the Plaintiff, in his claim, motivates that, in accordance with the employment contract dated 10.10.20..., he worked in an LLP ".................", as a tax consultant to perform certain work - provision of services under an agreement with JSC "..... - .............." with a piecework salary of 405,000 tenge, and was sent by LLP "....." to Astana to conduct a tax audit in JSC ".............. - processing and marketing."
Sample Request for evidence
The time spent on a business trip was 42 days. In the LLP "..........." The daily allowance is set at 6 MCI per day. In 20.... the MCI was 2,121 tenge. The total daily allowance for the business trip period is 2,121 tenge x 6 x 42 = 534,492 tenge. Also, travel from Astana to Almaty and from Almaty to Astana on branded Talgo trains amounted to about 14,800 tenge in one direction in 20..., so the Plaintiff paid 14,800 x 2 = 29,600 tenge for the trip. The exact amount for the trip is indicated in the tickets, which the Plaintiff submitted together with an advance report to the accounting department of Abia Goldmark Audit LLP. In total, he asks the court to recover from the LLP "........." in favor of his travel expenses in the amount of 564,092.00 tenge and representative services 56,400 tenge. We disagree with the claim, and the Court is also respected! We have doubts about the Plaintiff's movement from Astana to Almaty and from Almaty to Astana on Talgo branded trains.
however, the plaintiff indicated that the amount for the trip was indicated in the tickets, which he handed over together with the advance report to the accounting department of the LLP "...............". In this regard, we have reliable information that the Plaintiff gr. .........., I did not travel on the Astana – Almaty, Almaty – Astana route, on the Talgo branded trains for 20... year. Also, the plaintiff's arguments regarding Tickets are questionable, since all tickets purchased at the stations are registered on the database of Kazakhstan Temir Zholy JSC, from where you can get ticket purchase statements, travel itinerary, ticket refunds and other information. However, the Plaintiff, without substantiating his arguments, indicated in the Lawsuit that he had handed over the tickets to the Accounting Department. Also, the Plaintiff has never been to the office of the LLP. "............." and they are sure that the plaintiff cannot describe the location of the office.
46 of the 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 participating 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.
Sample Request for evidence
Based on the above, guided by Article 46 of the Civil Procedure Code of the Republic of Kazakhstan,
I ask the court:
For the purpose of comprehensive, complete and objective consideration of the said civil
cases to claim an extract on movement on railway tracks gr. ................. with JSC KTZ (Kazakhstan Temir Zholy) and/or with authorized state (Law enforcement) agencies that have access to this information;
To summon the Plaintiff gr. ................... to the trial for additional questioning on the circumstances of the civil case, where his answers to questions may affect the content of the court's decision.
With respect,
Representative by proxy:
________________/Sarzhanov G.T.
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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