Subcontracted Workers' Lawsuit Petition Regarding Wage Claims

TO THE DUTY LABOR COURT
OF ANKARA

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

ATTORNEY:
Lawyer's Name and Surname – Address: …

DEFENDANT:

1. Name and Surname – Address: …
2. … Ltd. – Address: …

SUBJECT OF THE LAWSUIT: We request that the defendants be ordered to jointly and severally pay a total of … TL, consisting of … TL in unpaid wages , … TL in overtime pay , … TL in severance pay, and … TL in holiday pay , along with the highest bank deposit interest applicable from the termination date of the contract, …/…/…, reserving our rights to claim further amounts.

EXPLANATIONS:

1. My client started working as a tunnel worker on …/…/… for … Construction, which is a subcontractor of … Ltd., for the … construction project . The project my client worked on is related to the excavation of the … Regulator and … Exit Tunnel , and it appears that my client's insurance registrations were made with the insurance registration number for this project. However, it was later learned that payments and premiums were not made regularly.
2. My client started working for the defendant company with a salary of … TL and worked continuously for 12 hours a day, seven days a week . My client continued working even on religious and national holidays, but no payment was made for these overtime hours.
3. My client never received their full and regular salary from the defendant company; only a portion was paid each month. The remaining balance and minimum living allowance have not yet been paid to my client. Moreover, they were dismissed on …/…/… without receiving severance pay.
4. Despite all good-faith efforts made to the defendant company, salaries, overtime pay, and other entitlements have not been paid. Therefore, to protect the client's legal rights and to recover those due.

EVIDENCE:

1. Workplace records and documents,
2. SGK (Social Security Institution) service record document
3. The client's insurance registration file,
4. Payroll records belonging to the defendant company,
5. Witness statements,
6. Expert examination and all necessary 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, Law of Obligations, Social Security Law, and related legislation.

CONCLUSION AND REQUEST:

For the reasons stated above, and without prejudice to our further claims:

1. The total amount of … TL, consisting of … TL in wages , … TL in overtime pay , … TL in severance pay , and … TL in holiday pay , shall be collected jointly and severally from the defendants , together with the highest bank deposit interest applicable from the termination date of the contract, …/…/….
2. The court costs and attorney fees shall be borne by the defendant

I respectfully request and demand a decision on behalf of my client.

…/…/…

Plaintiff's
Attorney's Name and
Surname