LABOR COURT
TO THE HONORABLE JUDICATURE
PROSECUTOR :
ATTORNEYS:
DEFENDANT :
SUBJECT: Provided that we reserve the right to request and sue for excess due to an accident at work…………-TL financial compensation, …………..- TL. non-pecuniary compensation, which is the total …………-TL is your compensation ../../…. the request is to decide on the collection together with the interest that will be processed from the date of the request.
EXPLANATIONS: Our client is the plaintiff, the defendant …….. A.When working at the workplace belonging to Sh,../../…. he was injured in a work accident in his history and lost his earning power in the profession by 9.3% and remained disabled.
The Law of Employment in the formation of this accident m.73 v.d. the defendant employer is 100% defective due to the fact that he has violated the mandatory provisions of the Employee Health and Safety Regulation and that the necessary measures to be taken at the workplace have not been taken.
Due to the disability of the accidental worker, there was a need to claim moral compensation based on the loss rate of earning power in the profession and the material for the loss of effort ; The elements and suffering that he has suffered and will continue to suffer throughout his life.
OUR REQUEST FOR AN INJUNCTION : In order for our rights and receivables to be guaranteed throughout the case and to ensure the execution of the defendant employer at the end of the case ………….. it was necessary to demand that an injunction be issued on the factory land and building located in te.
REASONS : Relevant laws, statutes and regulations
EVIDENCE : A Workplace identity file from the workplace, documents related to the month-by-month wage status and income for years, T.I.P, ) P.S.From K (…………. occupational accident insurance provided assistance with the paperwork and the registration number of workers on temporary incapacity allowance investigation files, and documents ), injury rate and injury rate on the documents, discovery, examination, witness statements, and other legal evidence.
RESULT OF THE REQUEST : For the reasons mentioned above, first of all, to accept our request for an injunction, other claims and litigation rights are reserved, ………..- TL. the date of the compensation is the date of the work accident ../../…. we sincerely hope and demand that it is decided to collect from the defendant together with the legal interest from the date of the trial, to transfer the trial expenses to the defendant, and to determine the counterparty proxy fee on our behalf in accordance with paragraph 164/last amended by Law 4667 of the Law No. 1136 on Attorney’s Law No. 1136. ../../….
PLAINTIFF ATTORNEY
