LABOR COURT
PLAINTIFF:
ATTORNEY:
DEFENDANT:
SUBJECT: This is a case to determine that the strike announced by an unauthorized union and implemented on … is unlawful. There is also a request for a preliminary injunction to stop the strike.
1- The defendant union has initiated a strike at my client’s workplace named … The strike decision was notified on … and has been implemented since …
This strike is unlawful because:
a) Most of the conditions required for a strike are not met,. And the legal deadlines were not observed in the process of adopting and implementing this strike decision.
b) The union does not have the authority to hold such a strike.
c) The main purpose of this strike is political;. It is a strike held to support other strikes that began in places called …
2- Due to all these conditions, the strike in question is unlawful, and if it is not prevented, my client’s economic and commercial life will become meaningless and may even come to an end. Therefore, it has become necessary to request the suspension of the strike through precautionary measures. To prevent my client from being unjustly harmed, we request that the strike be suspended before the decision becomes final.
LEGAL GROUNDS: Collective Bargaining Agreement, Strike and Lockout Law,. Labor Law, and provisions of other relevant legislation.
EVIDENCE: Power of attorney, strike notice, witnesses, and other legal evidence.
RESULT OF THE REQUEST: For the reasons explained above;
We request that the ongoing strike at the workplace be suspended by precautionary measures until a final decision is made on this matter, that the current strike be deemed unlawful,. And that the defendant be ordered to pay the court costs and attorney’s fees.
Sincerely,
ATTORNEY’S ATTORNEY