Petition For Compensation Due To Work Accident
………. LABOR COURT
TO THE HONORABLE JUDGE
THE PLAINTIFF :…….
ATTORNEYS :…….
DEFENDANT :…….
SUBJECT :
…………-TL pecuniary compensation, …………..-TL. moral compensation, which is a total of …………-TL compensation, without prejudice to our right to claim and sue for the excess due to the work accident …/…/…. It is a request to decide to collect the compensation together with the interest to be processed from the date.
EXPLANATIONS :
Our client, the plaintiff, defendant …….. A.Ş., the defendant …. A.Ş., was disabled in a work accident on …/../…. and became disabled by losing 9.3% of his earning capacity in the occupation.
In the occurrence of this accident, the defendant employer is 100% at fault for violating the mandatory provisions of Article 73 etc. of the Labor Law and the Occupational Health and Safety Regulation and for not taking the necessary precautions in the workplace.
Due to the disability of the injured worker, it is necessary to claim financial compensation for the loss of earning capacity and loss of effort; and non-pecuniary compensation based on the pain and suffering he has suffered and will continue to suffer throughout his life.
OUR REQUEST FOR PRECAUTIONARY INJUNCTION:
In order to secure our rights and receivables throughout the lawsuit and to ensure the execution of our rights and receivables at the end of the lawsuit, it has become necessary to request a precautionary injunction on the defendant employer’s factory land and building located at …………..
CAUSES : Relevant laws, statutes and regulations
EVIDENCE :
From the workplace 🙁 Workplace personnel file, documents related to wage status and income month by month for years, T.İ.S, ) S.S.K (…………. insurance registration number of the worker’s work accident investigation file and documents and documents related to the benefits provided and temporary incapacity allowance), disability rate and disability rate documents, discovery, expert examination, witness statements and other legal evidence.
CONCLUSION OF THE REQUEST :
For the reasons stated above, first of all, we respectfully request and demand that our request for interim injunction be accepted, without prejudice to our other claims and litigation rights, ………..-TL. compensation be collected from the defendant together with legal interest from the date of the work accident …/…/…., the costs of the proceedings be charged to the defendant, and the counterparty attorney fee be decided on our behalf as the Attorney in accordance with the 164/last paragraph of the Attorneyship Law No. 1136 amended by Law No. 4667. ../../….
ATTORNEY FOR THE PLAINTIFF
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