Sample Petition For Payment Of Wage And Overtime Work Fee
… LABOR COURT
THE PLAINTIFF :…….
ATTORNEYS :…….
DEFENDANT :…….
SUBJECT :It is our request for the payment of wage receivable and overtime wages.
EXPLANATIONS :
1-) Our client started to work in the defendant’s enterprise with an employment contract concluded on …/…/…/…date and his employment contract was unilaterally terminated by the employer without just cause. Our client worked at the workplace for a total of … years and … days without interruption until …/…/…/…the date his employment contract was terminated.
2-) After the termination of our client’s employment contract, he was not paid his notice and severance pay, … monthly salary and … hours of overtime pay. This is evidenced by witness statements and the last … month records of the bank account from which the salary was paid.
3-) For these reasons, it has become necessary to apply to your court for the payment of wage receivable, severance and notice pay, … monthly salary and … hours of overtime wages.
LEGAL GROUNDS : 4857 S. K. Art. 32, 41, Regulation on Overtime Work and Overtime Working Regarding Labor Law Art. 5, 9
LEGAL EVIDENCES : 1-) Employment contract dated …/…/…/…
2-) The names and addresses of the witnesses and the subjects they will testify about
witness list.
3-)… Bank account numbered …
CONCLUSION AND REQUEST : For the reasons explained above, on behalf of my client, I request that the unpaid … monthly wage receivable and … hours of overtime wages be paid to our client by applying the highest interest rate applied to deposits, and that the costs of the proceedings and attorney’s fees be charged to the other party…./…/ …
Counsel for the Plaintiff
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