Petition For Injunction For Unlawful Strike
… LABOR COURT JUDGE
THE PLAINTIFF :…….
ATTORNEYS :…….
DEFENDANT :…….
SUBJECT: This is a petition for the determination of the illegality of the strike announced by the unauthorized union and started on … date. There is also a request for an injunction to stop the strike.
1- The respondent union has gone on strike at my client’s workplace … and this strike decision was announced on … and started to be implemented as of ….
This strike is an illegal strike. This is because
a) Many conditions required for a strike are not present and the legal deadlines are not complied with in the process of taking and implementing this strike decision.
b) The union is not authorized for such a strike.
c) The main purpose of this strike is political because it is a strike to support other strikes that have started in places named ….
2- Due to all these circumstances, the strike in question is an illegal strike and if it is not prevented, the economic and commercial life of my client will be damaged in a meaningless way and even terminated. For this reason, it has become necessary to request an interim injunction to stop the strike. We request that the strike be stopped before the judgment is finalized in order to prevent my client from suffering unjustified damages.
LEGAL GROUNDS Collective Bargaining, Strike and Lockout Law, Labor Law and other relevant legislation.
EVIDENCE: Authorization certificate, strike notice, witnesses and any other legal evidence
CONCLUSION OF THE REQUEST For the reasons explained above;
We request that the strike currently in force at the workplace be suspended by way of voluntary injunction until the judgment on this matter is finalized, that this strike currently in force be determined as an illegal strike, and that the costs of the trial and attorney fees be collected from the defendant.
Sincerely …/…/…
PLAINTIFF’S ATTORNEY
………………………..
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