Petition For Determination Of The Need For Old Age Pension
Request for Old Age Pension
….. TO THE LABOR COURT JUDGE
THE PLAINTIFF :
TC ID NUMBER :
ADDRESS :
PROXY :
ADDRESS :
DEFENDANT :
ADDRESS :
SUBJECT : Cancellation of the payment orders issued with the file numbered ……. of the … Execution Office regarding our client’s insurance premium debts No. of the Execution Office regarding our client’s insurance premium debts and the request for the cancellation of the payment orders issued with the file numbered 506 based on the legal reason of statute of limitations for collection and the determination that an old age pension should be connected according to the law numbered 506.
EXPLANATIONS :
1-) Our client worked as a laborer in the … Company between …/…/… dates and …/…/… dates with … insurance registration number.
2-) The premium debt of the plaintiff’s insurance subject to Law No. 1479 between the dates …-…. for this period was put into enforcement proceedings by the Social Security Institution with the file numbered ….. of the … Enforcement Office With the file numbered of the … Enforcement Office.
3-) Since the statute of limitations for the premiums between the years …- … has expired, the premium debt demanded from our client for this period must be canceled.
4-) In addition to our explanations above, since our client’s insurance periods within the scope of Law No. 506 are sufficient alone, our client should be granted an old age pension in accordance with Law No. 506.
5-) Our client’s ….-…. by the Social Security Institution …. of the … Enforcement Office initiated by the Social Security Institution due to our client’s insurance premium debts related to the dates …. No. of the Execution Office initiated by the Social Security Institution due to our client’s insurance premium debts related to the dates -, and it has become necessary to file this lawsuit due to the decision to determine that the plaintiff was insured within the scope of Law No. 506 during the overlapping period and that he was entitled to an old-age pension due to the SSK service alone being sufficient for retirement.
LEGAL GROUNDS : Article 67 of Law No. 2004
LEGAL EVIDENCES : Workplace and Insurance File of our client, xxxx Execution Office’s follow-up file numbered yyyyy, Expert Examination
CONCLUSION AND REQUEST : For the reasons explained, our client is entitled to an old-age pension under Law No. 506 due to the fact that he was insured under Law No. 506 during the overlapping period and his SSK service alone is sufficient for retirement. No. of the Execution Office issued by the SSI to our client and to determine that he was insured within the scope of Law No. 506 during the overlapping period and that he is entitled to an old age pension under Law No. 506 since SSK service alone is sufficient for retirement.
ANNEXES 1-) Workplace and Insurance File
2-)xxxxxx Execution Office’s follow-up file numbered yyyyyy
3-) One approved power of attorney sample
Counsel for the Plaintiff
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