TO THE LABOR COURT
Plaintiff:
TURKISH IDENTITY NUMBER :
ADDRESS :
ATTORNEY:
(Legal representatives of the parties, if any)
ADDRESS :
(Legal representatives of the parties, if any)
DEFENDANT:
ADDRESS :
CASE VALUE:
(On property rights cases)
SUBJECT : Due to the wrongful termination of the service contract before the expiry of the contract, ……. The collection of TL penal clause consists of our request.
DESCRIPTIONS :
1-) Our client …/…/… – …/…/…. Worked for the defendant employer between (Appendix 2)
2-) In the contract mutually signed between the parties on …/…/… on the date of establishment of the business relationship with the defendant worker, it is stipulated that in case of wrongful termination of the contract before …/…/…, a penal clause amounting to ….- TL will be paid (Appendix 3). Due to the fact that the amount deposited is not sufficient to meet the rights arising from the termination of the contract, within the framework of this contract, for the payment of the penalty of …-TL due to the termination of the contract before the term of the contract, the …. He applied with the warning letter (Annex 4) registered in his daily journal, but no payment was made within the period given in the warning.
3-) For the reasons explained, in accordance with the contract stipulated between the parties, our client has become obligated to demand the collection of ……… TL from the defendant as a penal clause from your court.
LEGAL REASONS: 6098 S. K. m. 179, 180, 182
LEGAL EVIDENCE:
1-) Workplace records, service breakdown
2-) Notice of termination dated …/…./…..
3-) Sample of employment contract dated …./…/…
4-) … of the Notary of …. written notice
CONCLUSION AND REQUEST: In the contract drawn up between the parties for the reasons explained above, the employment contract is …/…/…. We respectfully request on behalf of our client to decide on the collection of .. …/ …/ …
Plaintiff’s Attorney
Hunting.
