TO THE JUDICIARY OF THE LABOR COURT
Plaintiff:
ATTORNEYS:
DEFENDANT:
SUBJECT : Without prejudice to our right to claim and litigation regarding surplus due to work accident, …………-TL pecuniary compensation, …………..-TL. non-pecuniary damage that the total amount of …………-TL compensation is ../../…. It is the request for a decision to be collected together with the interest that will accrue from the date of
EXPLANATIONS: While our client is the plaintiff, the defendant is working at the workplace of …….. A.Ş., ../../…. He was injured in a work accident he had in history and lost his earning power in the profession at a rate of 9.3% and became disabled.
In the formation of this accident, Article 73 of the Labor Law et al. The defendant employer is found to be at fault by 100% due to the fact that he has acted contrary to the provisions of the Occupational Health and Safety Regulation and the mandatory provisions of the Occupational Health and Safety Regulation and that the necessary precautions have not been taken in the workplace.
Financial for the loss of earning power and loss of effort due to the disability of the injured worker; It has become necessary to demand non-pecuniary compensation based on the pain and suffering that he has suffered and will continue to suffer throughout his life.
OUR REQUEST FOR INDIVIDUAL MEASURES: In order to secure our rights and receivables throughout the case and to ensure their execution at the end of the case, it has become necessary for the defendant employer to demand an Injunctive Injunction on the Factory land and building located in …………..
REASONS: Relevant laws, statutes and regulations
EVIDENCE: Workplace personnel file, monthly salary status and income documents from the workplace, assistance provided by the SSK (T.İ.S, ) with the work accident investigation file and documents of the worker with the insurance registration number and documents related to temporary incapacity allowance), disability rate and disability rate documents, discovery, expert examination, witness statements and other legal evidence.
RESULT OF THE REQUEST: For the reasons stated above, first of all, our request for interim injunction is accepted, without prejudice to our rights to other claims and lawsuits, ………..-TL. ../../…, which is the work accident date of the compensation. We respectfully submit and request that it be decided to collect the legal interest from the defendant together with the legal interest from the date of the date of the defendant, to charge the expenses of the proceedings to the defendant, and to decide on our behalf as the attorney in accordance with the 164/last paragraph of the Law on Attorneyship No. 1136 as amended by the Law No. 4667. ../../….
ATTORNEY’S ATTORNEY
