Labour Wage Claim Petition
…………( ) LABOUR COURT ON DUTY
THE PLAINTIFF : A….. B….. (T.C.:………..)
ADDRESS
AGENT :Lawyer …………..
ADDRESS
DEFENDANT : C….. D…. (T.C.:………..)
ADDRESS
CASE VALUE :3.000 TL (For now)
SUBJECT OF THE DEMAND :
It is the request for the collection of 3.000 TL Fee receivable together with the highest bank deposit interest for the time being, provided that our demands are increased after the expert report and our rights regarding the surplus are reserved.
OUR EXPLANATIONS
Client A…. B…. As can be seen from the attached SSI employment declaration. He started to work for the plaintiff on 12.02.2015 and his last net salary is 5.000 TL.
The plaintiff party has not paid salary to the plaintiff client for 6 months under the pretext that the business has not been going well, and the plaintiff client has drawn a notice to the employer within the scope of Article 24, paragraph II/e of the Labour Law, and upon the said notice, the employment contract of the plaintiff client was terminated by the defendant on 16.07.2021. This matter is also fixed with the SSI exit notification dated 04 Code.
For all the reasons explained above and to be taken into consideration ex officio by your Honourable Court, it has become necessary to file this lawsuit in order to make a decision for the collection of our severance pay receivable for the time being, without prejudice to our other labour rights and claims and our right to demand and sue more.
LEGAL GROUNDS :
Labour Law, Code of Civil Procedure, other relevant legislation
EVIDENCE :
Final Minutes of Mediation, Plaintiff’s personal registry file, Subpoena of documents related to salary payments from banks, Witness statements, Subpoena of the plaintiff’s employment and exit notifications and service status documents from SSI, OTHER DOCUMENTS SUBMITTED IN ADDENDUM, E-mail correspondence between the client and the defendant company, notices, petitions, expert report, discovery, oath, all kinds of other evidence (We reserve our right to show evidence against the evidence to be shown by the defendant)
CONCLUSION AND REQUEST :
For all the reasons explained above and to be taken into consideration ex officio by your Honourable Court:
-With the acceptance of our lawsuit, without prejudice to our receivables that will be fully revealed by the expert report, to decide to collect the fee receivable of 3.000 TL from the defendant together with the highest bank deposit interest to be processed from the default date,
-To charge all kinds of judgement fees, expenses, attorney’s fees to the other party
We request a decision by proxy.23.08.2021
Plaintiff’s Counsel
Lawyer
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