….. 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: related to our client’s insurance premium debts .. The Executive Office Of ……. Cancellation of payment orders issued with file no. based on the legal reason for the collection statute of limitations is related to the request to determine that the old age pension should be connected in accordance with law no. 506

INSTRUCTIONS :

1 -) Our client has worked as an employee in the company between the dates … /…/… numbered in the insurance registry and the dates…/…/…. (Annex-1)

2 -) plaintiff … -…. between the dates of the premium debt for this period of insurance subject to the law No. 1479 by the Social Security Institution … the Executive Office ….. It was placed in execution follow-up with a numbered file. (Annex-2)

3 -) … – … due to the fact that the statute of limitations has expired in terms of premiums between the years, it is necessary to cancel the premium debt requested from our client for this period.

4 -) in addition to our explanations above, our client must be connected to an old-age pension in accordance with law 506, since the insurance periods in accordance with law 506 are sufficient alone.

4 -) Social Security Institution by our client ….-…. The Executive Office, launched due to insurance premium debts related to their history…. With the cancellation of the follow-up, the business was obliged to open this case due to the decision on the determination that the plaintiff was insured under the Law No. 506 in the overlapping period and was entitled to the old age pension due to the fact that the SSK service was sufficient for retirement alone.

Legal reasons: 2004 p. K. m. 67

LEGAL EVIDENCE :

1 -) Workplace and insurance file belonging to our client.

2-) ….. Enforcement Agency’s … Numbered Follow-Up File

3 -) Expert Examination

Conclusion and request: for the reasons described, our client is regulated by the SSI … Executive Office …. In the period coinciding with the cancellation of enforcement proceedings, we demand by proxy on behalf of our client that it be decided that he is insured under Law No. 506 and that he is entitled to an old age pension under Law No. 506 due to the fact that SSK service is sufficient for retirement alone.

Adds: 1 -) Workplace and insurance file

2-)….. Enforcement Agency’s … Numbered Follow-Up File

3 -) one sample of approved power of attorney

Acting Plaintiff

Attorney