-SAMPLE PETITION-
ANKARA ( ) SENTRY EMPLOYMENT TRIBUNAL
PROSECUTOR :
ADDRESS
ATTORNEY :
ADDRESS
DEFENDANTS : 1.General Directorate of Social Insurance of the Presidency of the Social Security Institution (Ankara)
2.C………… B…………
address
SUBJECT OF CLAIM : The Plaintiff is your client ../../…. – ../../…. It is a Request to Decide the Determination of the Services That He Works as an Insured Between the Dates.
OUR EXPLANATIONS
Client A….. B….. the defendant, whom he entered with the status of a worker, is in the workplace …/…/…. On the date he started his job and was fired …/…/…. Until its date, it has been working with AKDI for an indefinite period of service without interruption. On this date, the employment contract has been terminated without any reason and without notice.
Although the client continued to work for the defendant’s employer without interruption during the specified period, it was found that the defendant’s work for the employer was not notified to the relevant insurance directorate in a timely manner and the SSI premiums were underinvested. Despite this unfair situation, since his rights arising from the law have not been paid to him, the plaintiff has had the obligation to substitute this case to determine that the client has been working all the time.
As will be revealed by the reasons we will explain below and the evidence we will present in october annex to this petition, as well as witness statements, the client has been fully entitled to his rights recognized by law. That is to say;
1-As will be revealed in the Insurance documents to be subpoenaed (OCTOBER-1), the client, …/… /…. he was dismissed for no reason in his history. It has been working continuously until this date, and most of its work has not been reported to the insurance directorate.
2- As can be understood from the october payrolls (ANNEX-2), the client has insurance from the minimum wage, like other employees working in the same position at the employer during the period in which he works; ….. TL is charged monthly by hand. (Witness accounts are important in this regard.)
3- Although the plaintiff client has made a request to the defendant’s employer to deposit insurance premiums, the defendant has not given any response to this. On top of that, the client, …/…/…. 12345 Evmiye Number of the Ankara Notary’s Office in the history of …/…/….with the dated Notice of Warning (OCTOBER-3), the defendant has warned the employer, the notice has reached the addressee, but the notice has not resulted in any result.
4- For all the reasons described above and which will be taken into account by your Dear Court, our other labor rights and scoundrels and the right to claim and sue for more, provided that the plaintiff client is insured within these undeclared periods, the obligation to open this case has arisen to determine that the plaintiff client is insured.
LEGAL REASONS: Labor Code, Code of Civil Procedure, other relevant legislation
EVIDENCE DEC Witness Statements, Plaintiff’s personal registration file, Subpoena of documents related to salary payments from banks, Plaintiff’s entry and exit statements and service status documents subpoena from SSI, OTHER DOCUMENTS OCTOBER IN THE ANNEX, Mail correspondence between the client and the defendant company, petitions, legal documents related to mutual complaints (bilahare will be submitted, subpoena is also requested.), All kinds of other evidence,
We reserve the right to show evidence against the evidence that the defendant will show.
CONCLUSION AND CLAIM : For all the reasons described above and which will be considered by your court you’re:
-Your Plaintiff Client is in the defendant’s employment service …/…/…. –…/…/…. Determination of the Fact That He Works As an Insured Without Interruption Between the Dates Dec,
-We request by proxy that all kinds of trial expenses and power of attorney fees be decided to be left on the defendant party. 01.09.2021
Deputy Plaintiff
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