….. THE COURT..
PLAINTIFF :
TC IDENTIFICATION NUMBER :
ADDRESS :
Deputy :
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
DEFENDANT :
Address :
Subject: our request for the collection of applications for payment of Labor receivables.
LITIGATION VALUE :
(In cases related to property rights)
INSTRUCTIONS :
1 -) our client is a plaintiff …. In the case of termination of the employment contract of the workers employed by the defendant company, it was decided to severally collect the labor receivables from the defendant company as our client as the parent employer … .(Annex-1)
2 -) employee initiated … Executive Directorate … E./…. K. with a numbered file .(Annex-2) our client was forced to pay, and the compensation fee imposed was paid to the employee by the client’s municipality.
3 -) paid ….. TL.along with the interest for delay that will be processed from the date of payment, the business is obliged to open this case for the collection of recourse from the defendant company.
Legal reasons: 4857 P. K. m. 2, 6098 S. K. m. 167
LEGAL EVIDENCE: 1. … Mah. … / … E. … / … K. numbered court order
2. … Executive Directorate. … / … E. … / … K. numbered file
3. Expert examination.
Conclusion and claim: for the reasons mentioned above, the client…. Together with the legal interest to be operated from the date of the TL labor receivables paid by the municipality to the employee, we demand by proxy that the defendant decide to collect the recourse from the company, charge the court costs and Attorney’s fee to the other party. …/…/…
ECLAIR :
1. … Mah. … / … E. … / … K. numbered court order
2. … Executive Directorate. … / … E. … / … K. numbered file
3. An example of an approved power of attorney.
Acting Plaintiff
Attorney.
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