Request For Determination Of The Right To Disability Pension (Law No. 506)
…… TO THE LABOR COURT JUDGE
THE PLAINTIFF
PROVISIONAL :
ADDRESS :
DEFENDANT
ADDRESS :
SUBJECT : This is our petition for the determination of the right to disability retirement.
A P P L A C T I O N S
1-) Our client started working at the … Iron and Steel Factory at … address … on …/…/… date. Our client has been insured since his employment and has been insured for 10 (ten) years; his insurance registration number is ….
2-) On …/…/…/… date, our client had a work accident; as a result of iron blocks and construction rubble in the factory falling on our client, he became paralyzed from the waist down.
3-) Due to this accident, our client has completely lost his ability to work and has fallen into a very difficult situation economically. For this reason, it is necessary to determine his disability and to connect him to a pension. For this reason, it has become necessary to apply to your court.
LEGAL GROUNDS : 506 S. Code Articles 53, 54, 55.
LEGAL EVIDENCE : 1-) Workplace Records
2-) Insurance File, Insurance Records
3-) Work Accident Report
4-) Doctor Reports
5-) Expert examination
6-) Any other legal evidence in favor
CONCLUSION AND REQUEST
For the reasons we have explained above, we respectfully request on behalf of our client to determine the disability of our client as a result of the accident, to grant a pension to our client after the determination is made, and to charge the trial expenses and attorney fees to the other party. …/…/…
Counsel for the Plaintiff