Service Determination Lawsuit Petition
LABOR COURT
PLAINTIFF : Name and Surname, Turkish ID No:
Address
DEFENDANTS : 1. Ministry of Labor and Social Security, Social Security Institution, General Directorate of Social Insurance
2. Institution where the plaintiff worked
SUBJECT OF THE CLAIM: The request is for a decision to be made regarding the determination of the period from …/…/… to …/…/… during which I worked as an insured employee at the defendant …, and the determination of the start date of insurance as …/…/…, and for me to be entitled to social insurance benefits.
EXPLANATIONS: 1- (…), I started working as an employee at (…) on (…) and was registered with the Social Insurance Institution under the employee number (…) with an employment notification form submitted on behalf of me. My employment start date is (…) and I am still insured; however, since the defendant employer has not paid the premiums, I have not been able to qualify for retirement since (…).
2- The defendant worked at the workplace under an employment contract, is legally entitled to retirement, and due to privatization, will lose his job in six months, necessitating retirement benefits. Therefore, it is necessary to determine the date of employment based on the start date of insurance coverage, making it imperative to file this service determination lawsuit.
LEGAL EVIDENCE: Workplace File, Insurance File, Witness Statements from Yuvacık, and other evidence.
LEGAL GROUNDS: Law No. 5510, Articles 2 and 86, and related legislation.
CONCLUSION AND REQUEST: For the reasons stated above, I respectfully request, on behalf of our client, that our valid claim be accepted, that the start date of the insured service be determined as (…), that the insurance premiums not paid during this period be paid by the defendant, that these services be combined with other services, and that the litigation costs and attorney’s fees be imposed on the opposing party.
Plaintiff