JUDGE OF THE EMPLOYMENT COURT
The Plaintiff : ……….. (Identity No. …..……)
Address:………………………………………..
Defendant :
Address:………………………………………..
Lawsuit: It consists of the request that the plaintiff, who was dismissed without compensation without a justifiable reason, be paid to the defendant employer together with the highest deposit interest rates to be operated from the dates when they should be paid by calculating seniority and notice compensation, with our rights to the surplus reserved.
Based on the spend: …….. TL.
Descriptions:
1- Dismissal without compensation:
Plaintiff ……….. S.S.K. registration no.lu insured workers and “…………………” as ………… between the dates the defendant worked in the company, he was dismissed without pay. Decriminalization
2- Length of service:
The plaintiff has worked at the same place of work and depending on the same employer continuously between the dates mentioned above, but has been shown to have worked at different places of work by logging in and out on the insured service Decoupage chart. This, ….. we speculate that it may have been caused by the fact that.
3- Plaintiff’s monthly net fee
The final fee of the plaintiff is gross per month ………… TL. in addition, two salary bonuses per year, food and road money are wage elements. Seniority and notice compensation should be calculated accordingly.
Legal Reasons : Labor Code No. 4857,.Law No. 5521, HMK No. 6100.etc.
Legal Evidence: Place of work and insurance records, witnesses, expert report, etc. all kinds of evidence.
Conclusion and Request: For the reasons explained above and which the court will consider personally;
107 of Law No. 6100 on unfair dismissal.according to the evidence collected in accordance with the article, we respectfully wish that it will be decided that they will receive severance and notice compensation and annual leave fees, as well as the highest deposit interest, trial expenses and attorney’s fees to be paid from the dates they must be paid, as well as the defendant employer, without prejudice to our rights to the excess.
Prosecutor
1) Certificate of mastery of the plaintiff
2) Declaration of entry into employment
3) SSI. records
4) Final payroll
Documents to be requested from the relevant places:
1) Personal file of the employee from the workplace
2) Insured account casting ruler from SSI
