LABOR COURT
THE PLAINTIFF :
ATTORNEY :
DEFENDANT :
CASE : Compensation for failure to issue a work certificate. ….. TL)
FACTS : 1- The plaintiff client worked at the defendant’s …………… workplace for a long time and terminated his employment contract by mutual agreement on …./…./…….
2- During the termination of the employment contract, the plaintiff asked the defendant for the work certificate specified in the law and the defendant ignored the request by stating that he would provide it as soon as possible.
3- The plaintiff then started to look for another job and found a job at ……………….., but since he did not have a work certificate, he could not prove his knowledge and experience in his job, and until he brought the document, someone else was hired instead. After that, it took …. months for the plaintiff to look for a job again and in this process, the plaintiff suffered damages due to the lack of a work certificate.
4- These issues are fixed with the job application form, interview and job acceptance statements, rejection of his request due to lack of documents and new employment dates.
5- Thus, the plaintiff client suffered a total of …. over the minimum wage for the ….-month period during which he was idle due to the lack of a work document. TL) has suffered damage.
It has become mandatory to file this lawsuit for the compensation of this damage.
Legal Reasons :
Evidence : Late work certificate, job application and rejection statements, new employment certificate, witness statements and all kinds of evidence.
Conclusion and Request : According to the reasons and evidence presented above, by accepting the lawsuit, …. TL (……) TL compensation from the defendant together with interest, and to charge the defendant with the costs of the proceedings and attorney’s fees.
I would like to submit. Sincerely yours,
Counsel for the Plaintiff
Atty……………..
(SIGNATURE)
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