TO THE … LABOR COURT ;
prosecutor :
TC IDENTIFICATION NUMBER :
address :
attorney :
(Legal representatives of the parties, if any)
address :
(Legal representatives of the parties, if any)
DEFENDANT :
ADDRESS :
subject :
CASE VALUE :
(In cases related to property rights) … – TL. he will receive wages (unpaid wages for the last … month of work)
… – TL. severance pay
…- TL. notice compensation
…- TL. holiday holiday pay
…- TL. overwork fees
Total: …- TL.
INSTRUCTIONS :
1-) Our client has started working in the department of the defendant’s workplace with the employment contract (ANNEX-1) concluded on the date of /…//. A total of … years … months … days have been served without interruption until the date of termination of the employment contract.
2-) Our client’s employment contract is unfair, baseless and unilateral by the employer../…/… has been terminated on date. Our client, ../../… which he has filed in his history and … the Employment Tribunal …/… E. …/… K. he has won the case for his return to work, which he opened with his numbered file (ANNEX-2).
3-) our client which does not start with the trial, although he won, he worked for and the moon in relation to fees, notice and severance pay, especially …-… because it is busy but made a couple days a week in the months total duration of certain non-overtime pay for overtime work with … of the year …. He was not paid for the days he worked during the holidays of Eid and … Eid. This will also be confirmed by the workplace records to be examined and the statements of our witnesses to be heard (ANNEX-3), if deemed appropriate by the court.
4-) Although the employer has been told that the receivables subject to the lawsuit will be paid on the date of /…//, there is no clear payment made to our client by the date of this lawsuit.
5-) Accordingly; with the highest interest to be applied from the date of termination of the contract in terms of severance pay, to be increased (to be increased as soon as it is possible to determine exactly) in case of an excess when calculated by expert experts; with legal interest to be processed in terms of other receivables, this Indefinite Receivable And the obligation to apply to your court for the determination of the case has arisen.
LEGAL REASONS : 1475 P. K. m. 14; 4857 P. K. m. 17, 32, 41, 44; 5521 Pp. K. m. 1, 5, 7, 8, 15, 6100 P. K. m. 107
LEGAL EVIDENCE: …/…/… employment contract dated, … Employment Court …/… E. …/… K. file number shows the names and addresses of the witnesses and the topics they will testify to witness list, Bank’s salary account belonging to our numbered client, workplace records, expert review.
CONCLUSION AND PROMPT: For the reasons described above, the maximum interest to be applied from the date of termination of employment in terms of severance pay to be increased (to be increased as soon as possible to be fully and definitively determined) in case of an excess when calculated by expert experts; the minimum total with the legal interest to be processed in terms of other receivables …..-We request by proxy on behalf of our client that it be decided that the collection of TL; trial expenses and the power of attorney fee be charged to the opposite party. …/…/…
ANNEXES: 1-) Employment contract dated October…/…/…
2-) … The Employment Tribunal …/… E. …/… K. the numbered file
3-) The witness list shows the names and addresses of the witnesses and the subjects they will testify to.
4-) An example of a certified power of attorney.
Plaintiff’s Attorney
