APPLICATION FOR A CRIMINAL OFFENSE TO THE POLICE DEPARTMENT
The Police Department of the Ministry of internal affairs of the Republic of Kazakhstan
Applicant: K R A
IIN: 7777
Shymkent city,...... home resident.
Representative by power of attorney:
Legal office" law and law"
Bin 201240021767.
Lawyer Sarzhanov Galymzhan Turlybekovich
Republic of Kazakhstan, 050002, Almaty, Almaly
district, abylai Khana Avenue, house 79/71, office 304.
info@zakonpravo.kz www.zakonpravo.kz
Tel.: +7 708 971 78 58 / 8 727 971 78 58.
APPLICATION FOR A CRIMINAL OFFENSE
The Republic of Kazakhstan, having established itself as a democratic, secular, legal and social state, its highest values are man, human life, rights and freedoms (paragraph 1 of Article 1 of the Constitution).
At the same time, everyone has the right to protect their rights and freedoms by all means that do not contradict the law and receive qualified legal assistance (paragraphs 1 and 3 of Article 13 of the Constitution).
Through this application, as a representative of K R Aidaralieva, defending her interests on the basis of a power of attorney, I report the following circumstances.
Aidaralieva K. R. is the owner of boutiques No. 17, No. 20 and No. 21 in the Zhibek Zholy market, located at the address: Shymkent, Almaty highway No. 38 and carries out activities for the sale of fruit and berry products in these places.
Ash Dmen, who is trading in the boutique No. 16 in this market, has been trading together as a neighbor for about 3 years.
Since January 2026, there have been unexplained losses in the trading turnover of the Principal R. A. K., in particular, along with the short-term disappearance of goods delivered on a regular basis, the volume of real income has significantly decreased. These circumstances raised reasonable doubts about the possible systematic embezzlement of goods by outsiders.
The Principal R. A. K. received the initial information about these acts of theft from S. E. Abdykhanovna, the owner of the boutique No. 3 "B", located in the neighborhood. In particular, E. A. Sarypbekova noticed with her own eyes that on March 24, 2026, ash D. repeatedly transported goods in boxes from the boutique No. 17 owned by R. A. Kas, and immediately reported this to the principal to the R. A. KAS.
In addition, E. A. Sarypbekova suggested that in order to clarify these circumstances, the owner of the neighboring boutiques No. 1-2 H. T. R. should check the records on video surveillance cameras.
In this regard, the Principal R. A. K. turned to the owner of boutiques No. 1-2 located in the neighborhood Rozytaevna H. T., who got acquainted with the recordings of video surveillance cameras installed in her boutique. These cameras are installed in the direction of boutiques No. 16 and No. 17. Due to the fact that the records of these CCTV cameras are stored for a limited period of time, only video materials belonging to the last 10 days were provided. During the viewing of the presented videos, it was found that ash D, together with her husband Aziz (hereinafter referred to as kegu), repeatedly illegally entered the boutique No. 17 of the principal and secretly took fruit and berry products by collusion.
In particular, the videos clearly recorded their attempts to steal at least 6 (six) times.
As a result of the study of video surveillance records submitted by the market Administration, the following theft facts were revealed:
Episode 1:
On March 18, 2026, at about 22:38 in the Silk Road Market, a video surveillance record clearly shows that ash Dyn entered the territory of boutique No. 17, owned by Ra, several times took the goods in boxes and transported them to boutique No. 16, owned by him. Indicates that these actions were carried out systematically for the purpose of secret, insolvent illegal seizure of other people's property. In addition, at about 22:51, despite the fact that the video shows the approach of a security officer, Sh. D. A. A., without stopping his actions, continued to export goods. Later, after the departure of the security guard, it was recorded in the video that he left the scene. The circumstances specified in Episode 1 are clearly recorded in the video recording stored under the name "2026.03.18_22.37_bazard_camera.mp4" and fully confirm the actions of the suspected person.
Episode 2:
On March 20, 2026, at about 00:09, it was recorded from the video surveillance record that ash Dyn arrived on the territory of the market and headed for the boutique No. 17, owned by R. A. Kas. The video clearly shows her looking at the items in front of the boutique in search of the key to open the boutique door, checking all around and finding the key in a certain hidden place.
After that, open up.D. illegally entered the boutique No. 17 using the specified key and further carried out attempts to secretly take possession of someone else's property.
Open approximately from 00:10 to 00:48.D. repeatedly took the goods inside the boutique No. 17 and regularly transported them to the boutique No. 16, which belonged to him. As a result of the analysis of the video, it was found that a total of 25 (twenty-five) boxes and 2 (two) packages of fruit products were transported in stages.
The listed actions indicate that they were carried out in advance and systematically, with the aim of secretly, without payment, misappropriation of other people's property.
Proof of this: video recordings stored under the name "2026.03.20_00.07_bazard_camera.mp4" and "2026.03.20_00.45_bazard_camera.mp4".
Episode 3:
At about 23:39 on March 20, 2026, it was recorded from the video surveillance record that ash Dyn arrived on the territory of the market and continued his activities. At about 23: 41, he illegally entered the boutique No. 17, owned by RA, which is clearly reflected in the video.
Further, in the period up to 00:02 on March 21, 2026, Sh.D. A repeatedly took the goods inside boutique No. 17 and gradually transported them to boutique No. 16, which belongs to it. As a result of the analysis of the video, it was found that he took out a total of 15 (fifteen) boxes of fruit products.
At about 20:44 on March 21, 2026, video surveillance records recorded that ash DN arrived in the market area in a truck with her husband. It is reflected in the video that, upon arrival, they entered the boutique No. 16, which belonged to them. During the study of the video, it was found that during this period of time, an active inspection of the market territory was carried out by a security officer, as well as the movement of another car near the boutiques. We believe that these circumstances are circumstances that prevented them from committing a crime.
In addition, the video clearly shows that sh.d. Amen her husband had been inside their boutique No. 16 for a long time, but did not enter the boutique No. 17, owned by Ra, and carried out any attempts to remove or transport any goods. At about 22:23, the two left their boutiques and returned from the market. Proof of this: video recordings with the names "2026.03.21_20.43_bazard_camera.mp4", "2026.03.21_21.04_bazard_camera.mp4" and "2026.03.21_21.56_bazard_camera.mp4".
Episode 4:
On the evening of March 21, 2026, after the failure to carry out any theft, about two hours later, that is, at about 00:16 on March 22, 2026, it was recorded from the video surveillance record that ash Dyn came back to the market territory on foot and entered the boutique No. 16, which he owned. Then, at about 00:21, he illegally entered the boutique No. 17, owned by RA, which is clearly reflected in the video. Hungry from about 00: 24.D. No. 17 took the goods inside the boutique several times and regularly transported them to his boutique. As a result of the analysis of the video, it was found that it periodically transported a total of 20 (twenty) boxes of fruit and berry products. The last, 20th box, was transported at about 00:47, and opened at 00:48.The fact that D. left the territory of the market is recorded in the video. These actions indicate that they were systematically carried out by group collusion, for the purpose of illegal acquisition of other people's property in secret, without payment. Proof of this: video recordings stored under the name "2026.03.22_00.15_bazard_camera.mp4" and "2026.03.22_00.35_bazard_camera.mp4".
Episode 5:
At about 13:01 on March 23, 2026, taking advantage of the weekend of the market, video surveillance records recorded that ash DN arrived in the market area in a truck with her husband. It is clear from two videos that as soon as they arrived, they entered the boutique No. 17, owned by R. A. K. At about 1:03:45 p.m., her husband placed a bag of boutique merchandise in the trunk of the car. Then, at 13:04:27, a box of fruit products (bananas) was placed in the trunk, and at 13: 05: 02, another box of goods was placed in the trunk. Thus, in a short period of time, several goods were loaded into the car, and at about 13:10 they left the scene together.
The listed actions show that sh. d. Amen her husband, by conspiracy in advance, as a group of people, illegally took possession of other people's property in secret, without paying. Proof of this:" 2026.03.23_12.59_bazard_camera.mp4"," 2026.03.17_camera.mp4"," 2026.03.17_camera.mp4"," 2026.03.17_camera.mp4 " and "2026.03.17_camera.mp4". 22_ext_camera.mp4 " saved video recording.
Episode 6:
On March 24, 2026, at about 05:35, video surveillance records showed that ash Dyn arrived on the territory of the market and entered the boutique No. 16 owned by him. Then, at about 05: 37, he entered the boutique No. 17, owned by RA, which is clearly reflected in the video. Approximately from 05:37 to 05: 55, Sh.D. A.gradually took the goods inside boutique No. 17 and transported a total of 9 (nine) boxes of fruit and berry products to its boutique. At about 05:57, it is observed that he looks out the door of the boutique, watches the surroundings and tries to ensure that his actions are being carried out in secret. This suggests that his actions were deliberate and implicit in nature. Further, at about 06:06, after making sure that there was no one around, Sh.d. continued to transport the namesakes and took out additional boxes until about 06:11. In total, 12 (twelve) boxes of fruit and berry products were transported on this day, according to the analysis of the video.
The listed actions indicate that they were systematically carried out with the aim of secretly, without payment, misappropriation of other people's property. Proof of this: video recordings stored under the name "2026.03.24_05.34_bazard_camera.mp4" and "2026.03.24_05.34_camera.mp4".
Due to the fact that the video surveillance records were stored only for the last 10 days, the principal of the R. A. K. had the opportunity to study the video recordings only for the period from March 18 to March 24, 2026.
The fact that ash D and her husband secretly took possession of other people's property at least 6 times during the specified short period of time, 7 days, is confirmed by real videos. This circumstance makes it clear that their actions were not random or one-time in nature, but were carried out in a systematic, regular and premeditated manner.
In addition, according to the explanation of the Principal R. A. Kyn, since January 2026, there has been an unjustified shortage of goods and a sharp decrease in the volume of income. In this regard, there are reasonable doubts that even during the period not covered by the videos, the suspects systematically attempted theft in a similar way. These circumstances require a comprehensive, complete and objective investigation of the case, including the episodes during the period not covered by the videos.
In addition, there are suppliers who were engaged in the supply of goods of the Principal R. A. Kyn, they have contact details and information confirming the volume of delivered products, which, in turn, makes it possible to prove that the goods were delivered in real volumes and subsequently there was a shortage.
According to preliminary calculations, the total amount of material damage caused since January 2026 will be about 15,000,000 (fifteen million) tenge.
On this fact, the principal, before familiarizing himself with the above videos, applied to the Turan District Police Department of the PD of Shymkent on March 27, 2026. However, after filing the application, ash d only once confirmed that he received 2-3 boxes of goods, that is, he gave the principal money in the amount of only 200,000 (two hundred thousand) tenge and admitted his criminal activity, but did not compensate for the total material damage caused to date.
The above circumstances indicate the presence of signs of a criminal offense provided for in subparagraph 1 of Paragraph 2 of Article 188 of the Criminal Code of the Republic of Kazakhstan (by prior collusion of a group of persons), as well as subparagraphs 1,2,3 of Paragraph 3 of this article (theft committed in large quantities; repeatedly; with illegal entry into an official or industrial premises, warehouse) in the actions of a citizen named Ash D and his / her Kei Aziz theft committed with illegal entry into boutiques No. 17, 20 and 21 owned by Ra.
According to Article 167 of the Criminal Procedure Code of the Republic of Kazakhstan (hereinafter referred to as the Criminal Procedure Code of the Republic of Kazakhstan), a civil claim may be filed with a person or his representative who has caused direct property or moral damage by a criminal offense or a criminally punishable act of an insane person from the moment of
In accordance with Part 1 of Article 179 of the Criminal Code of the Republic of Kazakhstan, the beginning of a pre-trial investigation, the beginning of a pre - trial investigation is the registration of an application, a report on a criminal offense in the Unified Register of pre-trial investigations or a first-order investigative action. The prosecutor is notified of the beginning of the pre-trial investigation within one day.
In accordance with paragraph 1 of Part 1 of Article 180 of the Criminal Code of the Republic of Kazakhstan, in the absence of reasons for the beginning of a pre-trial investigation, circumstances that exclude proceedings in the case, sufficient data indicating signs of a criminal offense, in particular, the statement of an individual, will cause the beginning of a pre-trial investigation.
In accordance with paragraph 1 of Part 1 of Article 181 of the Criminal Code of the Republic of Kazakhstan, statements of an individual about a criminal offense can be oral and written or in the form of an electronic document.
In connection with the above circumstances, in accordance with articles 71, 73, 167, 179 and 181 of the Criminal Procedure Code of the Republic of Kazakhstan,
I ask you:
* Registration of a citizen named Aziz in the unified database of pre-trial investigation for committing a crime in accordance with paragraphs 2.3 of Article 188 of the Criminal Code;
* Recognition of K R Aidaralieva as a victim;
* Recognition of K R Aidaralieva as a civil plaintiff;
* Conduct a full, comprehensive and objective pre-trial investigation on these circumstances;
* appoint a lawyer Sarzhanov Galymzhan Turlybekovich and legal adviser Kenesbek Islam Mukhamedovich as representatives of the victim – civil plaintiff K R Aidaralievan in the criminal case.
Note: we are ready to send the videos shown above for additional transmission.
With respect,
Representative / lawyer by power of attorney: G. T. Sarzhanov
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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