… 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 :

LITIGATION VALUE :

(In cases related to property rights)

Subject: agreed in the contract due to unfair termination before the term of the service contract……. TL consists of our request to collect the criminal condition.

INSTRUCTIONS :

1 -)…/…/… – …/…/…. between the dates the defendant worked with the employer (Annex 1) , the service contract was unfairly terminated on the date of…/…/…, the accrued notice and severance payments were paid by depositing into the bank account. (Appendix 2)

2 -) in case of unfair termination before the date of the contract …/…/… in a mutually signed contract between the parties on the date of establishment of the Labor relationship with the defendant employee ….- TL were expected to be paid in the amount of a penalty (Appendix 3) our client, arising due to the amount deposited in the bank account of termination of the contract is not sufficient to meet, therefore, within the framework of the provision of this contract due to the termination of the contract …the contract early-TL noterligi for the payment of penalties …. he applied with a warning registered in his salary (Annex 4), but no payment was made during the period recognized in the warning.

3 -) in accordance with the provision of the contract between the parties for the reasons described, our client has an obligation to request from your court that TL be collected from the defendant as a criminal condition……..

Legal reasons: 6098 P. K. m. 179, 180, 182

LEGAL EVIDENCE :

1 -) Workplace Records, Service breakdown

2-) …/…./….. a notice of termination dated

3-) …./ … / … example of a dated employment contract

4 -) … Notary Public…. a notice registered for a salary

Conclusion and request: an employment contract in a contract between the parties for the reasons explained above…/…/…. in the case of wrongful termination before the date ……… The prediction TL penalty that will be paid, due to our client from the defendant as a condition punitive ……… TL collection, litigation costs and attorneys ‘ fees on behalf of our client, we respectfully request that you decided to yukletilm the opposite side of it. …/ …/ …

Acting Plaintiff

Lawyer

ECLAIR :

1 -) Workplace Records, Service breakdown

2-) …/…./….. a notice of termination dated

3-) …./ … / … example of a dated employment contract

4 -) … Notary Public…. a notice registered for a salary

5 -) one sample of approved power of Attorney