Categories: General

Request For Payment In Lieu Of Notice And Severance Pay

EMPLOYMENT TRIBUNAL JUDGE

Plaintiff : ……….. (T.C. ID No. …..……)

Address:………………………………………..

Defendant :

Address:………………………………………..

Case: the plaintiff who is dismissed without compensation without a justifiable reason is required to be paid to the defendant employer along with the highest deposit interest to be operated from the dates when the severance and notice compensation should be calculated and paid, without prejudice to our surplus rights.

Mortar basis : …….. TL.

Instructions:

1-dismissal without compensation:

Plaintiff ……….. S.S.K. record no.lu insured worker and“…………………” as ………… between dates, the defendant worked at the company and was dismissed without compensation.

2-service period:

The plaintiff worked in the same workplace and in accordance with the same employer between the dates mentioned above, but was shown to have worked in different workplaces by entering and leaving in the insured service breakdown chart. That ….. we’re guessing it may have been caused by the fact that it happened.

3-plaintiff’s net monthly fee

Plaintiff’s final fee is gross monthly………… TL. two per year salary bonuses, food and road money are the wage elements. Severance and notice compensation should be calculated accordingly.

Legal reasons: Labor Law No. 4857,.Law No. 5521, HMK No. 6100.etc.

Legal evidence: workplace and insurance records, witnesses, expert reports, etc. all kinds of evidence.

Conclusion and request: for the reasons described above and which the court will take into consideration;

Due to unfair dismissal, Act No. 6100 was amended to act 107.in accordance with the evidence to be collected in accordance with the article, we respectfully wish that the severance and notice compensation and annual leave fee claims should be determined and decided to be paid to the defendant employer along with the highest deposit interest, trial expenses and Attorney’s fee to be operated from the dates when they should be paid.

Plaintiff

1) claimant’s certificate of mastery

2) declaration of entry into work

3) SGK. records

4) final payroll

Documents to be requested from related places:

1) employee’s personal file from the workplace

2) insured account breakdown chart from SGK

Aşıkoğlu Law Office

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