TO THE LABOR COURT JUDGE
Plaintiff:
TURKISH IDENTITY NUMBER :
ADDRESS :
ATTORNEY:
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
DEFENDANT:
ADDRESS :
SUBJECT : Regarding our client’s insurance premium debts .. Execution Office ……. It is related to the cancellation of the payment orders issued with the file no.
DESCRIPTIONS :
1-) Our client has worked as an employee in the company … between … insurance registration number …/…/… and …/…/…. (ANNEX 1)
2-) Plaintiff’s …-…. The premium debt of the insurance subject to the Law No. 1479 for this period was put into enforcement proceedings by the Social Security Institution with the file numbered ….. of the … Execution Office. (ANNEX-2)
3-) Since the statute of limitations for premiums between …- … years has elapsed, the premium debt requested from our client for this period must be cancelled.
4-) In addition to our explanations above, due to the fact that the insurance periods of our client within the scope of the Law No. 506 are sufficient alone, our client should be granted an old-age pension in accordance with the Law No. 506.
4-) Our client’s ….-…. Due to the insurance premium debts of the … Execution Office …. With the cancellation of the follow-up No. 506, it became obligatory to file this lawsuit since it was decided that the plaintiff was insured under the Law No.
LEGAL REASONS :
LEGAL EVIDENCE:
1-) Workplace and Insurance File of our client.
2-) ….. Follow-up File of the Enforcement Office No. …
3-) Expert Review
CONCLUSION AND REQUEST: For the reasons explained, the … Execution Office …. In the period coinciding with the annulment of the enforcement proceedings No. 506, we request, by proxy, that it be determined that he is insured under the Law No. 506 and that he is entitled to an old-age pension under the Law No. 506, since the SSK service alone is sufficient for retirement.
APPENDIX: 1-) Workplace and Insurance File
2-)….. Follow-up File of the Enforcement Office No.
3-) One copy of approved power of attorney
Plaintiff’s Attorney
Lawyer
