TO THE JUDICIARY
CLAIM:…….
ATTORNEYS: …….
DEFENDANT :…….
SUBJECT : With the Reservation of Our Right to Claim and Lawsuit Regarding Surplus ……. Severance Pay……. With the Highest Rediscount Interest Since Its History and ……. Notice of Compensation ……. About Our Request for Collection with Legal Interest as of Date.
EXPLANATIONS :1- While our client has been working as a secretary in the Production Directorate at the defendant workplace since ….., on 04.03.1998, pursuant to the Disciplinary Committee’s decision dated 04.03.1998 and 1998/2, Article 8/C-4 of the X. Period Collective Labor Agreement and the Law No. 1475 Pursuant to clause 17/2, the service contract was terminated without compensation on the grounds that he had earned an unfair advantage by receiving overtime wages even though he did not work overtime, and thus inflicted damage on the Company. history and ……. It has been reported with the notice no.
2- The objection made by our client against the termination of the service contract was rejected by the Disciplinary Board’s Decision dated 17.03.1998 and numbered 1998/3.
3- The Defendant Company, in its decision dated 04.03.1998 and numbered 1998/2, states that “With the approval of the General Directorate dated 27.02.1998 and numbered 1004, after the inspections carried out in the Production Directorate in two copies in 1997 and 1998 by the Production Directorate clerk and approved by the Production Directorate, the weekly surplus Some copies of the overtime forms sent to the Personnel and Social Affairs Directorate were reported by the pointman ….. …….. that it was determined that unfair profit was provided by writing additional names and overtime, and that our client also received overtime for 19 days without coming to work, and the employment contract was terminated without compensation.
4-Our client has no knowledge of the event regarding the termination of the service contract. The overtime hours in question are beyond the knowledge of our client. ….. ……. Written by Our client stayed overtime when requested at the workplace. Rater ….. ……. has prepared the legal ground for his action by showing many personnel as if they have worked overtime in order to cover up his own acts of gaining unfair advantage and caused our client’s grievance.
5- After the occurrence of this incident, as a result of the research conducted by our client, it was revealed that he was present on days when he did not seem to have worked overtime although he worked overtime. Pointer of the number of hours worked on the overtime schedule …. Written by ……. It is not possible to control this by our client. Our client has been known for his honesty and commitment to the business for 12 years. It is not possible to gain unfair advantage by resorting to this method. Since she is the only female employee working as a secretary in the workplace, she does not even have a friend with whom she can compare or calculate her salary. Therefore, it is not possible for him to notice the missing or overpayment in his salary.
6- Moreover, our client has never worked overtime between the dates in question. Overtime timer ….. ……. Since it was written by a random and primitive technique, it seems that overtime was not worked on the days when overtime was worked, and overtime was worked on the days when it was not. Our client cannot be held responsible for this situation. It is not legal to apply Article 17/2 of the Labor Law against my client, cases that do not comply with the rules of morality and goodwill are the action of the scorer ….. ……. It is not possible to hold our client responsible for someone else’s actions.
LEGAL REASONS:
EVIDENCE:
RESULT OF THE REQUEST: Without prejudice to our right to demand and litigation regarding the surplus for reasons submitted and ex officio……. Severance Pay……. with the highest rediscount interest since the date of ……. Notice of Compensation ……. We request that it be decided to be collected together with the legal interest from the date of the legal interest, the costs of the proceedings to be loaded to the defendant, and the attorney fee of the other party to be decided on our behalf as an Attorney in accordance with the 164/last paragraph of the Law No. 1136, amended by the Law No. 4667.
ATTORNEY’S ATTORNEY
