30 May Employee Claims Lawsuit
… TO AN EMPLOYMENT TRIBUNAL JUDGE;
PLAINTIFF :
TC IDENTIFICATION NUMBER :
ADDRESS :
Deputy :
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
DEFENDANT :
Address :
Deputy :
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
Subject: in accordance with Law No. 1475, it is related to the request for collection of our receivables arising from the employment contract terminated due to marriage.
LITIGATION VALUE :
(In cases related to property rights) … – TL. wages (unpaid wages for the last … month worked)
… – TL. severance pay
… – TL. Eid holiday fee
… – TL. overwork fee
Total: … – TL.
INSTRUCTIONS :
1 -) Our client … … has started working in the workplace of the defendant … … with an employment contract (Annex-1) concluded on the date of…/…/. He has performed uninterrupted services for a total of … years … months… days until the date of termination of the employment contract.
2 -) Our client, …/…/… married his wife … … in the history of … (Annex-2). Our client’s wife, it operates its own … shop in the province ( Annex-3). For this reason, after marriage, our client moved to the city … where his wife lived and worked (Annex-4).
3 -) the fact that our client wants to live with his wife after marriage is in accordance with the usual flow of life and is also one of the requirements of common life. For this reason, the fact that the employer, who is aware of the date of the wedding and that our client’s employment contract will expire due to the marriage, does not pay our client’s receivables indicates that it is malicious. Indeed, by the employer our client …… Of noterligi …… Journal No. with the pink slip ….. he was informed that he would be leaving work the day before.(Annex-5)
4 -) our client’s salary for the month in which he worked, severance pay, especially overtime pay for overtime work performed several days a week due to the fact that work is busy during the months, but the total duration of which is not certain … of the year…. He was not paid for the days he worked on Eid and … Eid holidays. This will also be confirmed by the workplace records to be examined and the statements of our witnesses (annex-6) to be heard if deemed appropriate by the court. Although the employer has been told that the receivables subject to the lawsuit will be paid on the date, there is no net payment to our client until the date of this lawsuit.
5 -) accordingly; in case of excess when calculated by expert experts to be increased (to be increased as soon as possible) in terms of severance pay with the highest interest to be applied from the date of termination of the contract…/…/…; for collection with legal interest to be processed in terms of other receivables, the business is obliged to apply to your court for this partial case.
Legal reasons: 1475 P. K. m. 14; 4857 S. K. m. 32, 41, 44; 7036 P. K. m. 5, 6, 7, 9; 6100 S. K. m. 109.
Legal evidence: … / … / … dated employment contract, marriage certificate belonging to our client, records of the shop belonging to our client’s wife, residence certificate, …… notary’s Office …. The Daily notice shows the names and addresses of witnesses and the issues they will testify to, witness list, workplace records, expert review.
Conclusion and claim: for the reasons explained above, to be increased in case of excess when calculated by expert experts (to be increased as soon as possible) in terms of severance pay with the highest interest to be applied from the date of termination of the contract…/…/…; the minimum total with legal interest to be processed in terms of other receivables …..-In TL, we demand by proxy on behalf of our client that the decision be made to charge the trial costs and power of attorney fee to the other party. …/…/…
Adds: 1 -) … / … / … dated employment contract.
2 -) marriage certificate belonging to our client.
3 -) records of the store belonging to our client’s wife.
4 -) certificate of residence.
5 -)…… Notary Public…. The pink slip’s Journal No.
6 -) a witness list that shows the names and addresses of witnesses and the topics they will testify.
7 -) one sample of approved power of attorney.
Acting Plaintiff
Lawyer
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