LABOUR COURT
DEFENDANT :
DEFENDANTS :
CLAIM : Receivable due to temporary labour relationship. (……. TL)
FACTS : 1- The plaintiff client has been working in the workplace named …………., which belongs to ………….., one of the defendants, for more than …. years.
2- However, on the date of …./…./……., the duty of fulfilling the performance of work was temporarily transferred to the other defendant with the consent of the client and thus a temporary employment relationship was established. After the establishment of the temporary employment relationship, the client’s …. monthly salary …… TL receivable has accumulated. As this receivable has not been paid until today, they state that they are not responsible for this debt and that they will not pay it, stating that the employer with whom a temporary labour relationship was established is responsible for the main employer and the employer with whom a temporary labour relationship was established is responsible for the main employer.
3- Since both defendants refrained from paying the accumulated salaries, although it was both previously agreed and a legal obligation, the plaintiff client had to legally claim his right.
For these reasons, it has become compulsory to file this lawsuit.
Legal Grounds :
Evidence : Employment contract, temporary labour relationship contract. Witness statements and all kinds of evidence.
Conclusion and Request : According to the reasons and evidence presented above. I request that the lawsuit be accepted and the total accumulated salary of …… (…..) TL, together. With legal interest from the default date for each month. Be jointly and severally collected from both defendants, and that the trial expenses and attorney fees be imposed on the defendants.
I would like to submit this request. Sincerely yours,
Plaintiff’s Counsel
Lawyer……………..
(SIGNATURE)
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