LABOR COURT JUDGE
PROSECUTOR:
ATTORNEY:
ADDRESS:
DEFENDANT:
ADDRESS:
SUBJECT: Involves a claim for disability and determination of retirement rights.
INSTRUCTIONS
1–) Our client began working at the Iron and Steel Factory located at …/…/… on …/…/…. (ATTACHMENT 1) Our client has been insured since the date he started working and has been insured for 10 (ten) years (ATTACHMENT 2); insurance registration number …
2-) …/…/…/… is the date of our client’s work accident (ATTACHMENT 3); he became paralyzed from the waist down as a result of iron blocks falling on him at the factory. (ATTACHMENT 4)
3-) Our client has completely lost his ability to work due to this accident and has fallen into a very difficult economic situation. Therefore, his disability status must be determined and he must be granted a retirement pension. For this reason, we have been forced to apply to your court.
LEGAL GROUNDS: 506 PK m. 53, 54, 55.
LEGAL EVIDENCE: 1-) Workplace Records
2-) Insurance File, Insurance Records
3-) Work Accident Report
4-) Doctor’s Reports
5-) Expert assessment
CONCLUSION AND REQUEST
For the reasons explained above, we respectfully request that the property loss suffered by our client due to the accident be determined, that a pension be granted to our client after the determination, that the litigation costs and attorney’s fees be borne by the opposing party, and that a decision be made in favor of our client. …/…/…
ATTACHMENTS: 1-) Workplace Records
2-) Insurance File, Insurance Records
3-) Work Accident Report
4-) Doctor’s Reports
5-) Expert assessment
6-) A certified copy of the power of attorney
Plaintiff’s Attorney