Notice And Severance Pay Claim
LABOR COURT JUDGE
Plaintiff : ……….. (Turkish ID No. …..……)
Address:………………………………………..
Defendant :
Address:………………………………………..
Case: The plaintiff, who was dismissed from work without just cause and without compensation, requests that the defendant employer be ordered to pay the seniority and notice compensation calculated as of the dates on which they were due, together with the highest deposit interest rates applicable, while reserving the right to claim additional amounts.
Fee basis: …… TL.
Explanations:
1- Dismissal without compensation:
The plaintiff, an insured worker with S.S.K. registration no. ……….., worked at the defendant company between ………… and ………… as “…………………” and was dismissed without compensation.
2- Length of service:
The plaintiff worked continuously at the same workplace and for the same employer during the period mentioned above, but the social security service record shows that he worked at different workplaces due to entries and exits. We believe that this may be due to ……
3- Plaintiff’s monthly net salary:
The plaintiff’s last salary was ………… TL gross per month, including two annual bonuses, meal allowance, and transportation allowance. Severance pay and notice pay should be calculated accordingly.
Legal grounds: Labor Law No. 4857, Law No. 5521, Civil Procedure Code No. 6100, etc.
Legal evidence: Workplace and insurance records, witnesses, expert reports, etc., any type of evidence.
Conclusion and Request: Based on the reasons explained above and those that the court will consider on its own initiative;
Due to unfair dismissal, in accordance with Article 107 of Law No. 6100, based on the evidence to be collected, while reserving our rights to any additional claims, we respectfully request that the defendant employer be ordered to pay the severance pay, notice pay, and annual leave wages, along with the highest deposit interest rates applicable from the due dates, litigation costs, and attorney’s fees.
Plaintiff
1) The plaintiff’s craftsmanship certificate
2) Employment notification form
3) SGK records
4) Latest pay slip
Documents to be requested from relevant authorities:
1) The employee’s personnel file from the workplace
2) Insured account statement from SGK