TO THE … LABOUR COURT
PLAINTIFF:
TC IDENTIFICATION NUMBER :
ADDRESS:
ATTORNEY:
(Legal representatives of the parties, if any)
ADDRESS:
(Legal representatives of the parties, if any)
DEFENDANT :
address :
SUBJECT: Related to our client’s insurance premium debts.. The Executive Office Of ……. It is related to the request to determine that the payment orders issued with the numbered file should be canceled based on the legal reason for the collection statute and the old age pension should be connected according to the law No. 506
INSTRUCTIONS :
1-) Our client has worked as an employee at the Company between the dates of the insurance registration number and the dates of the insurance registration number. dec. (APPENDIX-1)
2-) The plaintiff …-….. the premium debt of the insured person for this period, subject to Law No. 1479, between the dates of the Social Security Institution … of the Executive Dec…… He has been placed on enforcement proceedings with his numbered file. (APPENDIX-2)
3-) …- … due to the fact that the statute of limitations has expired in terms of premiums between dec years, the premium debt requested from our client for this period must be canceled.
4-) In addition to the above explanations, due to the fact that our client’s insurance periods alone are sufficient within the scope of Law No. 506, our client must be provided with an old age pension in accordance with Law No. 506.
4-) Our client has been notified by the Social Security Institution ….-…. Initiated due to insurance premium debts related to the dates … of the enforcement agency …. Due to the cancellation of the numbered follow-up, it was decided that the plaintiff was insured under Law No. 506 within the overlapping period and that he was entitled to an old age pension due to the fact that the SSK service alone was sufficient for retirement, the work was required to open this case.
LEGAL REASONS : 2004 P. K. m. 67
LEGAL EVIDENCE :
1-) The Place of Work and Insurance File belonging to our Client.
2-) ….. Executive Office’s … Tracking File No.
3-)Expert Review
CONCLUSION AND REQUEST : For the reasons described, our client is advised that the Enforcement Agency … regulated by the SSI …. We request by proxy on behalf of our client to determine that he is insured under Law No. 506 in the period coinciding with the cancellation of enforcement proceedings No. 506 and that he is entitled to an old age pension under Law No. 506 because the SSK service alone is sufficient for retirement.
ATTACHMENTS: 1october) Place of Work and Insurance File
2-)….. Executive Office’s … Tracking File No.
3-) An example of a certified power of attorney
Plaintiff’s Attorney
