Overtime and Annual Leave Pay Case

TO THE ON-DUTY LABOR COURT

PLAINTIFF  : Name and Surname – (Turkish Republic Identity Number: …) – Address
REPRESENTATIVE   : Attorney's Name and Surname – Address – Mobile Phone
DEFENDANT  : Name and Surname – Address
SUBJECT  : Claim for collection of overtime pay and annual leave pay.
VALUE OF CLAIM : … TL (Value for court fees)

EXPLANATIONS

1. My client has been employed continuously as a cleaning worker by the defendant , the main employer, the Municipality , through various subcontractor companies, since …/…/… date . Although the subcontractor companies changed over time, my client's actual work continued consistently within the same municipality.

2. My client's employment contract was terminated without just cause and without adhering to the notice period. However, following the termination, not only were severance and notice pay not paid, but my client was also not granted their annual paid leave and was not paid the corresponding annual leave compensation.

3. My client was made to work more than 45 hours per week during their employment period. Working hours were:

• Weekdays: Morning … – earliest … (15-20 minute lunch break),

• Saturday: Morning… – earliest… (15-20 minute lunch break)
  , and no overtime pay was given.

4. According to the Labor Law, overtime pay and unused annual leave pay must be paid to the employee upon termination of the employment contract. Since these payments were not made to my client, it became necessary to file this lawsuit.

EVIDENCE

1. The plaintiff's SSK (Social Security Institution) registration file and employer registration records, SGK (Social Security Institution) service record,

2. The plaintiff's workplace registration file,

3. Witness statements,

4. Expert examination,

5. All legal evidence.

WITNESSES

1. Name and Surname – (Turkish Republic Identity Number: …) – Address – Telephone

2. Name and Surname – (Turkish Republic Identity Number: …) – Address – Telephone

LEGAL GROUNDS

Labor Law No. 4857, Turkish Code of Obligations No. 6098, Code of Civil Procedure and related legislation.

CONCLUSION AND REQUEST

For the reasons stated and explained above;

• We reserve our rights to pursue further legal action and claims

• For now, … TL overtime pay, the highest bank deposit interest rate ,

• For now, … TL annual leave pay, together with legal interest from the date of the lawsuit/default .

• To be paid to my client,

• The court costs and attorney fees shall be borne by the defendant

I respectfully request and demand, as the client, that a decision be made.
…/…/…

Plaintiff's Attorney
: Name and Surname
Signature

                                                                                   YAĞMUR YORULMAZ, LAW FACULTY STUDENT