30 Jan Labor Fee Request Petition
… 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 :
SUBJECT :
LITIGATION VALUE :
(In cases related to property rights) … – TL. wages (unpaid wages for the last … month worked)
… – TL. severance pay
… – TL. notice compensation
… – TL. Eid holiday fee
… – TL. overwork fee
Total: … – TL.
INSTRUCTIONS :
1 -) Our client, …/…/… has started working in the department … …at the workplace of the defendant … … with the employment contract (Annex-1) concluded on the date. He has performed uninterrupted services for a total of … years … months… days until the date of termination of the employment contract.
2 -) our client’s employment contract is unfair, baseless and unilateral to the employer ../ … / … defunct in history. Our client,../../ … opened in its history and … Employment Tribunal … / … E. … / … K. he won the case for restitution to the work he filed with his numbered file (Annex-2).
3-) our client which does not start with the trial, although he won, he worked for and the moon in relation to fees, notice and severance pay, especially …-… because it is busy but made a couple days a week in the months total duration of certain non-overtime pay for overtime work with … 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-3) to be heard if deemed appropriate by the court.
4 -) although the employer has been told that the receivables subject to the lawsuit will be paid on the date …/…/… there is no net payment made 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 indefinite receivables and determination case.
Legal reasons: 1475 P. K. m. 14; 4857 S. K. m. 17, 32, 41, 44; 5521 P. K. m. 1, 5, 7, 8, 15, 6100 S. K. m. 107
Legal evidence: … / … / … dated employment contract, … of the Employment Tribunal … / … E. … / … K. his numbered file shows the names and addresses of the witnesses and the subjects they will testify to, the witness list, the bank … the salary account of our numbered client, the workplace records, the 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 -) … Employment Tribunal … / … E. … / … K. numbered file
3 -) a witness list that shows the names and addresses of witnesses and the topics they will testify.
4 -) one sample of approved power of attorney.
Acting Plaintiff
Attorney
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