Petition Requesting Compensation Pursuant to an On-Call Employment Contract
LABOR COURT
PLAINTIFF
ATTORNEY :
DEFENDANT
CASE : Compensation according to an employment contract based on on-call work.
FACTS :
1- The plaintiff client has been working at the defendant’s ………… workplace …./…/…… since …./…/…… according to a part-time employment contract based on on-call work. .
2- The plaintiff worked at the defendant’s workplace for one month upon the call made to him. At the end of the month, the defendant employer paid the plaintiff worker …..TL for 4 weeks of work. He stated that this was calculated based on a total of ….. hours, daily…, weekly ….. hours.
3- However, the plaintiff’s daily work lasted less or more than ….. hours. It is not sufficient to work for the same fixed period of time every day as a requirement of the job. In addition, as per the law, it is not possible for the daily work to be less than … and the weekly work to be less than …. Working hours in works based on such contracts.
4- Apart from this, the hourly wage has not been agreed as … TL. However, it is not customary for the hourly wage to be less than … TL in such jobs. For these reasons, total…. hours over … hours per week and hourly wage …. The difference between TL and … hours multiplied by the … difference. TL multiplied by the hourly rate difference. TL wage difference had to be requested.
For these reasons, it has become necessary to file this lawsuit.
Legal Grounds:
Evidence : Employment contract, payment receipt, expert examination and witnesses, etc. evidence.
Conclusion and Request : According to the reasons and evidence presented above, I request the acceptance of the lawsuit and the full payment of the compensation in the amount of ….. It was decided to collect (…..) TL from defendant with interest and to collect hearing costs and attorney’s fees from defendant.
I would like to present my regards,
Plaintiff Lawyer
Lawyer ……………..
(SIGNATURE)
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