EMPLOYMENT TRIBUNAL

Plaintiff: name and surname, T.C. ID No.:

Address

Defendants: 1. Ministry of labour and Social Security Presidency of Social Security Institution General Directorate of Social Insurance

2. The Institution He Worked For

Subject of the lawsuit: … / … / … from the date of … / … / … to the date of … / … / … the defendant … is the request to determine that I work as the insured and the insurance start date … / … / … and to decide whether to benefit from the insurance services.

Explanations: 1 – (…), the employer (…) also (…) started working as a worker on the date and about me (…) Social Insurance Institution by giving a declaration of entry to work ( … ) registered with the registration number. The start date is (…) and I am still insured; however, I am not eligible for retirement from the date of ( … ) because the defendant employer does not pay the premium.

2-The defendant who has worked under a contract of service in the workplace, who is entitled to retirement by law and will lose his job after 6 months due to privatization is required to pension and the starting date of the work has to be determined to be based on the start date of the insurance, the obligation to open this service

Legal evidence: Work Place file, insurance file, witness statements Yuvacık and other evidence.

Legal reasons: 5510 S. K. m. 2, 86, and related legislation.

Conclusion and claim : due to the reasons mentioned above, I respectfully request on behalf of our client that the acceptance of our right case and the determination that the service of the insured is the starting date ( … ), and that the insurance premiums not paid within these periods are paid by the defendant, that these services are combined with other services, and that the

Plaintiff