Sample Petition Regarding The Request For Recourse Collection Of Labor Receivables Payment
….. TO THE COURT JUDGE;
THE PLAINTIFF :
TC ID NUMBER :
ADDRESS :
LEGAL REPRESENTATIVE :
(legal representatives of the parties, if any)
ADDRESS :
(of the legal representatives of the parties, if any)
DEFENDANT :
ADDRESS :
SUBJECT : Our request for the recourse collection of the payment of labor receivables.
CLAIM VALUE :
(in cases related to property rights)
EXPLANATIONS :
1-) The solid waste collection, transportation, sweeping and urban cleaning work within the body of our client plaintiff …. Municipality was assigned to the defendant company, and in the lawsuit filed upon the termination of the employment contract of … …, one of the workers employed by the defendant company, it was decided to collect the labor receivables subject to the lawsuit jointly from our client … Municipality as the superior employer and the defendant company as the sub-employer. (ANNEX 1)
2-) With the … Enforcement Directorate … E./…. K. numbered file(ANNEX- 2) , our client was obliged to make a payment and the compensation amount awarded was paid to the worker by the client municipality.
3-) The paid ….. TL. with the delay interest to be accrued from the date of payment, it has become necessary to file this lawsuit for the recourse collection from the defendant company.
LEGAL GROUNDS : 4857 S. K. art. 2, 6098 S. K. art. 167
LEGAL EVIDENCES : 1….Mah. …/… E. …/… K. numbered court decision
2. … Execution Directorate. …/… E. …/… K. numbered file
3. Expert examination.
CONCLUSION AND REQUEST : For the reasons stated above, we hereby request, by proxy, that the amount of … TL labor receivables paid by the client …. Municipality to the worker be collected from the defendant company with legal interest to be operated as of …/…/…, and that the court costs and attorney’s fees be imposed on the other party. …/…/…
ANNEXES :
1….Mah. …/… E. …/… K. numbered court decision
2. … Execution Directorate. …/… E. …/… K. numbered file
3. One approved power of attorney sample.
Plaintiff Attorney
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