15 Sep WORK PETITION FOR SEVERANCE AND NOTICE PAY
TO THE HONORABLE JUDICATURE
…….
PLAINTIFF :…….
ATTORNEYS:…….
RESPONDENT :…….
SUBJECT: Provided that We Reserve the Right to Request and Sue for Excess ……. Severance Pay ……. With the highest Reeskont Interest From the date of and…….. Compensation ……. Our Request For Collection Together With The Legal Interest From The Date of Hk.
EXPLANATIONS :1-Our Client ….. since the year the defendant has been working as a secretary in the Production Department at the workplace since 04.03.1998 in accordance with the decision of the Disciplinary Board dated 04.03.1998 and 1998/2 X. The term Bulk of an employment contract 8/C-17/2 gains obtained under Clause 4 and the overtime overtime law 1475 taking on the material, and thus harmed the company, without compensation, on the grounds that our client have been terminated as a service contract and this situation …….League ……. date and ……. it has been reported with the notification number of the journal.
2-The appeal made by our client against the termination of the service contract was rejected by the Decision of the Disciplinary Board dated 17.03.1998 and numbered 1998/3.
3-date for the company in decision 1998/2 04.03.1998 the defendant and numbered “No. 1004 27.02.1998 date and the headquarters of the authority, with the approval of the examinations in 1997 and 1998, the production department production manager and production puantor prepared in two copies, in the form of weekly overtime is approved by the directorate staff and sent to the Directorate of Social Affairs after some copies of puantor ….. …….. it was reported by the company that additional names and overtime hours were found to be unfairly earned, our client also received overtime without coming to work for 19 days,” and the employment contract was terminated without compensation.
4-Our client does not know about the termination of the service contract in any way. These overtime periods are scored without our client’s knowledge….. ……. it was written by. Our client was working overtime when requested at the workplace. The Scorecard ….. ……. he prepared the legal basis for his action by making many employees appear to have worked overtime to keep up with his unfair profit-making actions and caused the victimization of our client.
5-After the appearance of this incident, as a result of the research conducted by our client, it turned out that he was working overtime, but he did not seem to be working overtime on his days. How many hours of overtime are counted on the overtime schedule…. …… is written by. It is not possible to control this by our client. Our client is a person who has been known for his honesty and commitment to work in the defendant workplace for 12 years. It is impossible for him to earn unjustly by resorting to this path. Since she is the only female employee working as a secretary at work, she does not even have a friend with whom she can compare or calculate her salary. Therefore, it is impossible for him to notice the incomplete or overpayment in his salary.
6-Besides, our client has never worked overtime between the dates in question.dec. Overtime points difference ….. ……. because it is written by a haphazard and primitive technique, overtime does not seem to be worked on days that are working overtime, overtime seems to be done on days that are not working. It is impossible to hold our client responsible for this situation. The application of Article 17/2 of the Labor Code against my client is not legal, there are cases where he does not comply with the rules of morality and goodwill ….. …… is the action of. It is impossible to hold our client responsible for someone else’s action.
LEGAL REASONS : Labor law, HUMK and Related Legislation
THE EVIDENCE :
RESULT OF THE REQUEST : Provided that we reserve the right to request and sue for excess for reasons that may be submitted and reseen…….. Severance Pay ……. with the highest reeskont interest from the date of…….. Compensation ……. We demand that it be decided to collect it together with the legal interest from the date of its date, to transfer the trial expenses to the defendant, and to determine the counterparty proxy fee on our behalf in accordance with paragraph 164/last amended by Law No. 4667 of the Law No. 1136 on Advocacy Law No. 1136.
PLAINTIFF ATTORNEY
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