REQUEST FOR A CRIMINAL REQUIREMENT FOR UNJUST TERMINATION OF THE SERVICEAGREEMENT

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 :

 

CASE VALUE :

(In cases related to property rights)

 

 

SUBJECT : What is agreed in the contract due to unfair termination of the service contract before its expiration ……. The collection of the TL criminal requirement consists of our request.

 

 

INSTRUCTIONS :

 

1-) Our Client …/…/… – …/…/…. the defendant worked with the employer between the dates (APPENDIX 1) , the service contract was terminated unfairly on Dec /…/…, the accrued notice and severance payments were paid by depositing them in the bank account. (APPENDIX 2)

 

2-) In case of unfair termination of the contract before the date dec /…/… in the contract signed between the parties mutually on the date of the establishment of the business relationship with the respondent employee ….- TL were expected to be paid in the amount of a penalty (Appendix 3) our client, arising due to the amount deposited in the bank account of termination of the contract is not sufficient to meet, therefore, within the framework of the provision of this contract due to the termination of the contract …the contract early-TL noterligi for the payment of penalties …. he applied with a notice of absence registered with the Board of directors (APPENDIX 4), but no payment was made within the period recognized in the notice.

 

3-) In accordance with the provision of the contract concluded between the parties for the reasons described, our client has been obliged to request from your court that the defendant be decriminalized as a criminal condition …………. TL.

 

LEGAL REASONS : 6098 P. K. m. 179, 180, 182

 

LEGAL EVIDENCE :

1-) Workplace records, service breakdown

2-) …/…./….. dated notice of termination

3-) …./…/… an example of an employment contract dated

4-) … The Notary’s Office …. registered with the Ministry of education

 

CONCLUSION AND DECISIVENESS: For the reasons we have explained above, the employment contract between the parties is …/…/…. we respectfully request on behalf of our client that it be decided that TL will be collected from the defendant as a criminal condition, trial expenses and attorney’s fee will be charged to the other party…………………. due to the provision that TL will be paid to the criminal condition if it is terminated unfairly before the date. …/ …/ …

 

 

Plaintiff’s Attorney