APPLICATION FOR SEVERANCE PAY CLAIM DUE TO MARRIAGE

TO THE ON-DUTY LABOR COURT

PLAINTIFF:
Name and Surname
Address

ATTORNEY:
Lawyer's Name and Surname,
Address

DEFENDANT:
Name and Surname
Address

SUBJECT:
Claim for severance pay and reimbursement of unjustified notice pay deductions due to termination of employment contract because of marriage.

EXPLANATIONS:

1. The plaintiff worked diligently at the defendant's workplace for many years. However, the plaintiff wishes to terminate her employment contract due to marriage, exercising her legal right.
2. According to the relevant provisions of the Labor Law, a female employee is entitled to severance pay if she terminates her employment contract within one year of her marriage. The plaintiff notified the defendant of the termination of her employment contract through a notary public, in accordance with this regulation.
3. The defendant, claiming that the plaintiff abused their legal right, did not pay the severance pay and instead deducted it from the plaintiff's salary under the name of notice pay. However, there is no obligation to pay notice pay in cases of termination due to marriage.
4. Furthermore, the defendant employer's claim that the plaintiff started working at a different workplace does not negate the plaintiff's right to severance pay. Supreme Court rulings also support this point; an employee who terminates their employment contract due to marriage and then starts working at another job is not considered to have acted in bad faith.
5. The plaintiff's termination notice is entirely in accordance with the law and constitutes a fair termination of the employment contract. However, the defendant employer's unfair deductions and failure to pay severance pay have necessitated the filing of this lawsuit.

LEGAL GROUNDS:
Relevant articles of the Labor Law, Supreme Court decisions, and other legislation.

EVIDENCE:

1. Notary notice
2. payslip
3. Employment contract
4. Witness statements
5. Other legal evidence

WITNESSES:

1. Name and Surname, Address
2. Name and Surname, Address

CONCLUSION AND REQUEST:

For the reasons stated and explained above;

1. The plaintiff's severance pay, along with legal interest, shall be collected from the defendant
2. The return of the unjustly deducted severance pay,
3. On behalf of my client, I respectfully request and demand that the court order the defendant to pay the court costs and attorney's fees.

Date: …/…/…
Plaintiff's
Attorney Name and Surname
Signature