LABOUR COURT
DEFENDANT :
DEFENDANT :
CLAIM : Compensation for abuse of the right of termination. (……. TL)
FACTS : 1- While the plaintiff client has been working at the defendant’s ………. workplace since …./…./……, the defendant employer did not let the plaintiff come to the workplace without any notification, stating that he terminated his employment contract on …./…./……
2- The reason for the defendant’s termination of the defendant’s employment contract is that he could not see the sexual intimacy he demanded from the defendant. This issue has become known by almost everyone in the workplace. Thus, the defendant wanted to take revenge on the defendant by terminating the employment contract in bad faith and because he could not achieve his personal ambitions.
3- The plaintiff’s working period is more than … years. His monthly wage is … TL together with the material benefits provided. Although it is a legal obligation. The defendant does not pay the fee for the notice period. In addition. Since the employment contract was terminated. By abusing the right of termination, we demand an additional compensation of … times the notice compensation. Thus, the total unpaid amount of … TL had to be collected through legal means.
For these reasons. It has become compulsory to file this lawsuit.
Legal Reasons :
Evidence : Labour contract, wage slips. Witness statements and all kinds of evidence.
Conclusion and Request : According to the reasons and evidence presented above. The lawsuit is accepted and the total amount of ……. TL compensation from the defendant together. With interest, and to charge the defendant. With the costs of the proceedings and attorney’s fees.
I would like to submit. Sincerely yours,
Plaintiff’s Counsel
Lawyer……………..
(SIGNATURE)
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