TO THE LABOR COURT
prosecutor :
attorney :
DEFENDANT :
SUBJECT :It consists in the fact that he will be paid and we Want to Pay the Overtime Pay.
INSTRUCTIONS :
1-) The client has started working at the defendant’s business with the employment contract concluded on the date of /…/ and ../../../the employment contract has been terminated unilaterally by the employer for no justifiable reason. Our client has worked at the workplace continuously for a total of …years … days until the date of termination of the employment contract.
2-) After our client’s employment contract was terminated, he was not paid notice and severance pay, monthly salary and hourly overtime pay. This is fixed by witness statements and the last … monthly records of the bank account where the salary payment was made.
3-) For these reasons, he will receive remuneration, severance and notice compensation, .. it has become necessary to apply to your court for the purpose of paying the monthly salary and hourly overtime pay to us.
LEGAL REASONS : 4857 P. K. m. 32, 41, Regulation on Overwork and Overwork in Relation to the Labor Code m. 5, 9
LEGAL EVIDENCE : 1-) employment contract dated …/…/…
2-) The names and addresses of the witnesses and the subjects they will testify to
it shows the witness list.
3-)… Bank … numbered account
CONCLUSION AND REQUEST: For the reasons explained above, I request on behalf of my client that it be decided that he will receive an unpaid monthly fee and that the hourly overtime fee will be paid to our client by applying the highest interest rate applied to the deposit, and that the trial expenses and the attorney’s fee will be charged to the opposite party.…/…/ …
Plaintiff’s Attorney
