LABOR COURT
THE PLAINTIFF :
ATTORNEY :
DEFENDANT :
CASE : Compensation for abuse of the right of termination. (……. TL)
FACTS : 1- While the plaintiff client was working at the defendant’s ………. workplace since …./…./……, the defendant employer did not let the plaintiff back to the workplace without any notification, stating that he terminated his employment contract on …./…./……
2- The reason why the defendant terminated the employment contract is that the plaintiff could not receive the sexual intimacy she requested from the defendant. This issue has become known by almost everyone in the workplace by word of mouth. Thus, the defendant wanted to take revenge on the defendant by terminating the employment contract in bad faith and because he could not achieve his personal ambitions.
3- The plaintiff’s working period is more than … years. His monthly wage is … TL together with the material benefits provided. Although it is a legal obligation, the defendant does not pay the fee for the notice period. In addition, since the employment contract was terminated by abusing the right of termination, we demand an additional compensation of … times the notice compensation. Thus, the total unpaid amount of … TL has to be collected through legal means.
For these reasons, it has become compulsory to file this lawsuit.
Legal Reasons :
Evidence : Employment contract, payrolls, witness statements and all kinds of evidence.
Conclusion and Request : According to the reasons and evidence presented above, the lawsuit is accepted and the total amount of ……. TL from the defendant with interest, and that the defendant be charged with the costs of the proceedings and attorney’s fees.
I would like to submit. Sincerely yours,
Counsel for the Plaintiff
Atty……………..
(SIGNATURE)
APPENDIX:
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