……………. TO THE HONOURABLE JUDGE OF THE CIVIL COURT OF PEACE
ENFORCEABILITY
WANTED
REQUESTER :
Address :
PROXY :
Address :
OTHER PARTY :
Address :
Subject of Request
Mediation certificate : ………………. Mediation Bureau, ….. Mediation
No., …… Bureau No., Mediation Agreement Document
SUBJECT : Mediation Agreement which we have submitted the information
document to be given an annotation of enforceability.
EXPLANATIONS :
1- ………. Mediation Office, …… Mediation No. ….. Mediator with Bureau no. ……….. ………….., which we have presented in the annex …/…. /…. Dated Mediation Agreement Document (Mediation Agreement Final Minutes) has been issued.
2- Pursuant to this Mediation Agreement document;
The other party (Party-2) in accordance with our labour receivables written in the agreement document;
(……. TL written in the agreement document. our labour receivables or)
Severance pay : ? Notice pay : ?
Wage : ? Overtime : ?
Annual leave fee: ? LVI: ?
As our receivables, total: …………. (…..) TL. payment in three equal instalments:
…/ …/ …. On the date …………….. TL. – …/ …/ …. On the date …………….. TL.
…/ …/ …. Date in …………….. TL.
It has been written as an agreement clause that it will pay in the form of an agreement clause and it has been agreed that an Enforceability Annotation can be obtained upon the application of one of the Parties.
3- For the reasons we have presented, we have had the obligation to request an annotation of enforceability to the aforementioned Mediation agreement document in accordance with paragraph 3 of Article 18 of the Mediation Law No. 6325 on Civil Disputes.
LEGAL GROUNDS : Law No. 6325 on Mediation in Civil Disputes,
Law No. 7036 on Labour Courts, CPL and related legislation
EVIDENCE : The attached Mediation Agreement and other evidence
CONCLUSION AND REQUEST : For the reasons we have given and explained and the Honourable Court
For the reasons to be taken into consideration ex officio, we respectfully request and demand that the mediation agreement document (minutes of the last session) dated … /…/…/ ….., which we have submitted in the annex, be granted a certificate of enforceability.
ANNEXES
1- Power of attorney,
2- Mediation agreement document dated …/ … / ….. (Mediation final minutes)
Requester ………………………..
Representative, Av. …. ……………….
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