… TO THE JUDICIARY OF THE LABOR COURT
PLAINTIFF:
ATTORNEY:
DEFENDANT:
SUBJECT: It is a petition for the case of determination that the strike announced by the unauthorized union and started to be implemented on … is illegal. There is also a request for injunction to stop the strike.
1- The defendant union went on strike at my client’s workplace called …, and this strike decision was announced on … and started to be implemented as of ….
This strike is against the law. For:
a) There are not many conditions required by the strike, and legal deadlines are not complied with in the process of taking and implementing this strike decision.
b) The union does not have the authority to strike such a strike.
c) The main purpose of this strike is a political one because it is a strike that is carried out with the aim of supporting other strikes that started in places called ….
2- Due to all these circumstances, the strike in question consists of an illegal strike, and if this is not prevented, my client’s economic and commercial life will be meaningless, and it will even come to an end. For this reason, it has become necessary to request a request to stop the strike through interim injunction. We demand that the strike be stopped before the verdict is finalized, so that my client does not suffer unfairly.
LEGAL REASONS: The provisions of the Collective Bargaining Agreement, Strike and Lockout Law, Labor Law and other relevant legislation.
EVIDENCE: Power of attorney, strike notice, witness, and any other legal evidence
RESULT OF THE REQUEST: For the reasons explained above;
We request that the current strike at the workplace be stopped by means of discretionary measures until the verdict on this matter is finalized, that this strike that is currently being implemented is an illegal strike, and that the trial expenses and attorney’s fees be collected from the defendant.
Regards …/…/…
ATTORNEY'S ATTORNEY