Petition to Object to Termination Notice

TO THE ISTANBUL (...) LABOR COURT

PLAINTIFF: Name and Surname - (Turkish Republic Identity Number: …)

ADDRESS:

ATTORNEY: Lawyer's Name, Surname, Address, Mobile Phone Number

DEFENDANT: Name and Surname

ADDRESS:

SUBJECT: Objection to termination notice

EXPLANATIONS:

1- My client worked at the defendant's workplace from …. to ….. On the last day he worked, the employer made an unfair statement about him and tried to warn my client not to come back after that day.

2- The termination notice did not state any reason, and since this notice is contrary to the law, procedure, and principles of good faith, it should be deemed invalid; therefore, we are pursuing this claim and lawsuit.

EVIDENCE: 1- Employment contract, 2- Notice of termination, 3- Witness statement and any other type of 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 and related legislation.

CONCLUSION AND REQUEST: For the reasons briefly explained above, I respectfully request and demand, as the plaintiff's attorney, that the court accept the case, declare the unlawful termination invalid, order the continuation of the employment contract, order the defendant to re-employ the plaintiff within one month of application, and if the defendant fails to re-employ the plaintiff within this period, order the defendant to pay compensation equivalent to ... months' wages, and order the defendant to bear the court costs and attorney's fees. …/…/…

Plaintiff's Attorney