LABOR COURT
DEFENDANT
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 looking 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. 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 remedied with the job application form, interview and job acceptance statements, rejection of the request due to lack of documents and new employment dates.
5- Thus, plaintiff client has suffered a total loss of ….. over minimum wage for the …. Month period when he was idle due to the lack of a work certificate. TL) has suffered damages.
It has become mandatory to file this lawsuit for the compensation of this damage.
Legal Grounds:
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, it is decided to accept the lawsuit, …. And to pay TL (……) TL compensation from the defendant with interest and to collect the litigation costs. And attorney’s fees from the defendant.
I would like to present my regards,
Plaintiff Lawyer
Lawyer ……………..
(SIGNATURE)
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