-SAMPLE PETITION-
ANKARA ( ) SENTRY EMPLOYMENT TRIBUNAL
PROSECUTOR :
ADDRESS :……
ATTORNEY :
ADDRESS :
PHONE :
DEFENDANT :
ADDRESS :
CASE VALUE : 3.000 TL (For now)
SUBJECT OF REQUEST: Subject to increasing our demands after the expert report and reserving our rights regarding the surplus, it is a request that the highest amount of the 3.000 TL Fee will be charged together with the bank deposit interest.
OUR EXPLANATIONS
Client A…. B…. As can be seen from the SGK employment entry statement presented in the appendix, he started his job with the plaintiff on October 12, 2015, and his final net salary is TL 5,000.
The plaintiff has not paid the plaintiff client a salary for 6 months on the pretext that their job is not going well, and the plaintiff has not paid the client an employer under Article 24 of the Labor Code.within the scope of subparagraph II/e of article, the notice was withdrawn, and upon such notice, the plaintiff’s client’s employment contract was terminated by the defendant on 16.07.2021. This issue is also fixed by the SGK dismissal declaration, which was issued Code 04.
Mr. Mahkemenizce described above and re’ with the poet you consider all the reasons to sue without prejudice to our right to our low labor rights and demand more and get severance for now we remand the decision for the opening of collection has been achieved in order to give the present case, the need to.
LEGAL REASONS: Labor Code, Code of Civil Procedure, other relevant legislation
EVIDENCE : the final report of mediation, the plaintiff’s personal record file in documents from the Bank of salary payments with respect to a subpoena, witness accounts, the plaintiff with the declaration of the input and output of the service status of the document from the SGK subpoena, other documents that are offered in the appendix, mail correspondence between the company with the client, the defendant, warning letters, petitions, expert reports, discovery, swear, every poet evidence (evidence show me the evidence against the respondent, and we reserve the right to show)
CONCLUSION AND REQUEST : For all the reasons described above and which will be considered by your Esteemed Court you’re:
-With the acceptance of our case, we will receive a fee of 3,000 TL for now, in order to reserve our receivables that will be fully disclosed with the expert report, together with the highest bank deposit interest that will be processed from the date of default, it will be decided to collect from the defendant,
-All kinds of trial fees and expenses, as well as fees-i for the assignment of power of attorney to the other party
We request that the decision be made by proxy.23.08.2021
Deputy Plaintiff
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