LABOR COURT
PLAINTIFF: Full Name, Turkish ID Number:
Address
DEFENDANTS: 1. Ministry of Labor and Social Security Social Security Institution General Directorate Social Insurance General Directorate
Employer
SUBJECT OF THE CASE: I have been working as an insured employee since … /… /… and the start date of my insurance is determined as /… /…, and the request is for a decision to be made regarding the use of insurance services.
EXPLANATIONS: 1- (…), the employer (…) started working as an employee on (…) and registered me with the Social Insurance Institution with the registration number (…) by submitting an employment notification regarding me. My start date is (…) and I am still insured; however, as of (…) I am not eligible for retirement because the defendant employer is not paying premiums.
2- The defendant, who worked at the workplace under a service contract, is legally entitled to retirement and will lose his job six months later due to privatization, must be paid a retirement pension, and the start date of employment must be determined according to the start date of his insurance; therefore, this service determination lawsuit must be filed.
LEGAL EVIDENCE: Workplace file, insurance file, witness statements, and other evidence.
LEGAL GROUNDS: 5510 PK m. 2, 86, and related legislation.
CONCLUSIONS AND IMPORTANT INFORMATION: For the reasons stated above, it has been ruled that the just cause and the insured service start date should be accepted (…) that these services should be combined with other services during the period of insurance premiums paid and not to be deposited by the defendant, and that the court costs and attorney’s fees should be borne by the opposing party. I respectfully request this on behalf of our client.
Prosecutor