TO THE LABOR TRIBUNAL JUDGES

PROSECUTOR:

ATTORNEY:

DEFENDANT:

SUBJECT: This is a petition for a case to determine that the strike announced by the unauthorized trade union and which began to be implemented on its date is illegal. There is also a request for measures to stop the strike.

1- The defendant trade union went on a strike at the place called my client’s place of work, and this strike decision was announced on the date and started to be applied from the date.

This strike is a strike against the law. Because:

a) There are not many conditions required by the strike, and legal deadlines are not observed during the process of obtaining and implementing this strike decision.

b) The trade union has no authority for such a strike.

c) The main purpose of this strike is a political one, because this strike is a strike implemented to support other strikes that have started in places called …

2- For all these reasons, the strike in question is an illegal strike, and if this is not prevented, the economic and commercial life of my client will be damaged and even terminated in a way that will be meaningless. For this reason, it was necessary to request a request to stop the strike through an injunction. We are demanding that the strike be stopped before the verdict is finalized so that my client will not be unfairly harmed.

LEGAL REASONS: Collective Bargaining Agreement Provisions of the Strike and Lockout Law, Labor Law and other relevant legislation.

EVIDENCE: Certificate of authorization, declaration of strike, witness and any other legal evidence

PROMPT RESULT: For the reasons described above;

We demand that the applied strike, which is currently at work, be stopped as an old-fashioned measure until the decision on this issue is finalized, that this strike, which is currently being implemented, is determined to be an illegal strike, and that it be decided to collect the costs of the trial and the attorney’s fee from the defendant.

Best regards …/…/…

PLAINTIF’S ATTORNEY