PETITION FOR AN OVERWORK FEE LAWSUIT

-EXAMPLE PETITION-

 

ANKARA ( ) SENTRY EMPLOYMENT TRIBUNAL

 

PLAINTIFF:

ADDRESS:

ATTORNEY:

ADDRESS:

PHONE:

DEFENDANT :

address :……

CASE VALUE:….

SUBJECT OF REQUEST: For now, provided that our requests are increased after the expert report and our rights regarding the surplus are reserved ….. TL is a request that the overtime payee be charged together with the highest bank deposit interest from the date of the lawsuit.

OUR EXPLANATIONS

Client A…. B…. As can be seen from the SGK employment entry statement presented in the appendix, he started his job with the plaintiff on October 12, 2015 and received the last net fee ….. It is TL.

The plaintiff client works with the defendant dec dec. 6 days a week between 08:00 and 19:00, and there is a 1-hour lunch break between 12:00 and 13:00 every day. This issue will be revealed by witness statements. In such a work order, the plaintiff client works 60 hours a week, and work more than 45 hours a week is considered overtime, and for each hour of work worked, multiplied by 1.5, the overtime pay that the employee will receive is calculated.

The plaintiff client was unfairly dismissed by the defendant on 01.08.2021, and the defendant party also did not pay overtime to the plaintiff client.

For the time being, provided that we reserve the right to demand and sue for more with our other labor rights and scoundrels for all the reasons described above and which will be taken into account by your Dear Court …. It has been necessary to open this case to ensure that a decision is made on the collection of the judgment that we will receive overtime pay.

LEGAL REASONS: Labor Code, Code of Civil Procedure, other relevant legislation

EVIDENCE : the final report of mediation, the plaintiff’s personal record file in documents from the Bank of salary payments with respect to a subpoena, witness accounts, the plaintiff with the declaration of the input and output of the service status of the document from the SGK subpoena, other documents that are offered in the appendix, mail correspondence between the company with the client, the defendant, warning letters, petitions, expert reports, discovery, swear, every poet evidence (evidence show me the evidence against the respondent, and we reserve the right to show)

CONCLUSION AND REQUEST : For all the reasons described above and which will be considered by your Esteemed Court you’re:

-For the time being, our receivables that will be fully revealed by the expert report upon the Acceptance of our case will be reserved ….. The decision to collect the TL overwork fee from the defendant together with the highest bank deposit interest that will be processed from the date of default / lawsuit should be made,

-All kinds of trial fees and expenses, as well as fees-i for the assignment of power of attorney to the other party

We request that the decision be made by proxy.25.08.2021

 

Plaintiff’s Attorney

 

 

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