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A statement about a criminal offense committed for knowingly false denunciation

A statement about a criminal offense committed for knowingly false denunciation 

 

In the UP of the Turksib district of the DP of the city of Almaty,

 the Ministry of Internal Affairs of the Republic of Kazakhstan

Almaty, Richard Sorge St., 14.

 

from the Applicant: AI Saidulaevich

IIN ....

3 Zh... street, Almaty.

+7 701 ....

 

statement

about the committed criminal offense

 

I have been warned about criminal liability for knowingly false denunciation under article 419 of the Criminal Code of the Republic of Kazakhstan.

 

I, as IS, am submitting this application for criminal prosecution of ZBN, born on 04/19/1985, IIN...., upon the commission of fraud.

On December 30, 2024, my former colleague Z.B.N. approached me with a request to lend him money, citing his extremely difficult life situation. In support of his request, he said that he had become a participant in a traffic accident, as a result of which human health was harmed, and he urgently needed funds to compensate for material and moral damage to the victim. Using these circumstances and exerting psychological pressure on me, he convinced me to transfer funds in the amount of 5,000,000 tenge to him by February 15, 2025.

In order to mislead me and create the appearance of securing the obligation, Z. B.N. personally drew up a receipt dated December 30, 2024, in which he indicated that in case of non-repayment of the debt, he would transfer to me as collateral two machines for the production of expanded metal mesh, allegedly belonging to him by right of ownership.

On the same day, I made money transfers: 1,300,000 tenge at 11:17 a.m. to Mr. B.'s account (at the request of B.N., who is his mother), 2,000,000 tenge at 11:19 a.m. to his personal account, and 1,700,000 tenge at 11 a.m.:40 hours. All of these transfers are confirmed by the relevant bank receipts (the transfer receipts are attached to the application).

Subsequently, on January 28, 2025, Z.B.N. again asked me to provide funds, again referring to the current situation related to the accident. Initially, I refused, but he assured me that this time he would provide more reliable security, namely the apartment in which he lives. In support of his words, he provided the original purchase and sale agreement for an apartment located at the address: Almaty region, Enbekshikazakh district, village 2, T street, apartment 4. At the same time, the owner is indicated in the agreement by Imanvarovna, born on 03/10/1961.

To my direct question about the ownership of the apartment, Z.B.N. said that the apartment actually belongs to him, but it is registered to his relative. I repeatedly warned him about the inadmissibility of deception, which is confirmed by the audio recording (name of the audio recording: "WhatsApp_Audio_2026-04-01_at 13.54.06_(1).OGG"), however, believing him, I transferred funds in the amount of 3,000,000 tenge on January 28, 2025 against a receipt with a repayment period until March 1, 2025.

After these deadlines, Z.B.N. did not fulfill his obligations, did not return the funds, despite repeated demands, telephone conversations and face-to-face meetings. At the same time, he systematically evaded repayment of the debt, citing various reasons.

Later, when I tried to sell the collateral, I became aware that the two machines indicated in the receipt did not belong to Zu BN, but belonged to a third person named Dastan (contact number: +7 708 ....), what is confirmed by the audio recording (name of the audio recording: "The machines belong to the factory.OGG", which is loaded into a flash drive). Similarly, it turned out that the apartment provided as collateral for the second receipt also does not belong to him, but is actually the property of a third party to whom he also has a debt.

In addition, I would like to inform you that I carry out business activities related to the sale of building materials, including plaster mesh. Z. B.N. has repeatedly purchased the specified product from me with the condition of subsequent payment, that is, in debt. As a result of systematically receiving the goods without making payment, he owed me 2,000,000 (two million) tenge, which has not been repaid to date.

I also recorded videos (the name of the videos: "WhatsApp_Video_2026-04-01_at_14.01.51.mp4" and "WhatsApp_Video_2026-04-01_at_13.58.47.mp4"), on which Z.B.N. acknowledges the debt and requests a postponement: recording dated November 18, 2025 (with the promise of repayment by November 21, 2025) and recording dated December 3, 2025 (with the promise of a refund by December 10, 2025), which they also have not fulfilled.

These actions On behalf of B.N. indicate that he had an initial mercenary intent aimed at the illegal and gratuitous circulation of my funds in his favor. He deceived me by providing deliberately false information about his property (machines and apartments), as well as by abusing the trust that arose from personal and business relationships, as a result of which I voluntarily transferred funds to him. In accordance with the clarifications of the Regulatory Resolution of the Supreme Court of the Republic of Kazakhstan dated June 29, 2017 No. 6 "On judicial practice in fraud cases", such actions constitute fraud, since property is transferred to victims voluntarily under the influence of deception or abuse of trust if the perpetrator has a selfish purpose.

Additionally, I would like to inform you that on February 23, 2026, I already contacted the police with a statement on this fact, and was interrogated by an investigator from the Turksib district Police Department in Almaty, Zhumabai B.B., but so far there have been no results of the pre-trial investigation. At the same time, I am aware that on February 24, 2026, Z.B.N. wrote an explanatory note addressed to the head of the UP of the Turksib district, in which he acknowledged the debt owed to me in the amount of 10,000,000 tenge and pledged to repay it within two months, but this obligation was also not fulfilled.

According to paragraph 1 of the Regulatory Resolution of the Supreme Court of the Republic of Kazakhstan dated June 29, 2017 No. 6 (as amended on 12/22/2022), a mandatory sign of fraud is the presence of a mercenary purpose by the perpetrator, as well as the fact of the transfer of property under the influence of deception or abuse of trust.

In view of the above, I believe that B.N.'s actions show signs of a criminal offense provided for in subparagraph 1) part 3 of Article 190 of the Criminal Code of the Republic of Kazakhstan, namely fraud committed on a large scale. The total amount of funds that he seized through deception and abuse of trust is 10,000,000 (ten million) tenge, which is confirmed by receipts, bank transfers and other evidence. This amount is significant and represents a large amount of damage caused to me as a victim.

According to Article 167 of the Criminal Procedure Code of the Republic of Kazakhstan (hereinafter referred to as the CPC), a civil claim may be filed from the moment the pre-trial investigation begins until the end of the judicial investigation by a person who has directly suffered property or moral damage by a criminal offense or a criminally punishable act of an insane person, or by his representative.

In accordance with Article 179 of the CPC, the beginning of a pre-trial investigation is the registration of an application, a report of a criminal offense in the Unified Register of Pre-Trial Investigations, or the first urgent investigative action.  

Paragraph 1, Part 1, of Article 180 provides that sufficient data indicating signs of a criminal offense serve as grounds for initiating a pre-trial investigation in the absence of circumstances precluding the proceedings, namely: a statement by an individual or a message from an official of a state body or a person performing managerial functions in an organization about a criminal offense. or an unknown disappearance of a person.

Based on the above and in accordance with articles 71, 73, 167, 179 and 181 of the Criminal Procedure Code of the Republic of Kazakhstan,

 

I ask you to:

 

· Register a criminal case in the Unified Register of Pre-Trial Investigations against B.N. on the grounds of a criminal offense provided for in subparagraph 1) 190 of the Criminal Code of the Republic of Kazakhstan (fraud).

·        To recognize me, A.S., as a victim in this criminal case.

·        To recognize me, A. S., as a civil plaintiff.

·        To conduct a comprehensive, complete and objective pre-trial investigation with the adoption of all measures provided for by law.

 

 

Yours sincerely, A.I.S.

 

 

 

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