On December 21, 2020 a
Letter,Correspondence
was filed
involving a dispute between
Yasemin Tekiner,
Yasemin Tekiner
In Her Individual Capacity, As A Beneficiary And A Trustee Of The Yasemin Tekiner 2011 Descendants Trust And Derivatively As A Holder Of Equitable Interests In A Shareholder Or A Member Of The Company Defendants,
and
254-258 W. 35Th St. Llc,
Berrin Tekiner,
Billur Akipek
In Her Capacity As A Trustee Of The Yasemin Tekiner 2011 Descendants Trust,
Bremen House Inc.,
Bremen House Texas, Inc.,
German News Company, Inc.,
German News Texas, Inc.,
Gonca Tekiner,
Zeynep Tekiner,
for Commercial Division
in the District Court of New York County.
Preview
February 18, 2021
Norton Rose Fulbright US LLP
1301 Avenue of the Americas
New York, New York 10019-6022
Hon. Joel M. Cohen, J.S.C. United States
Supreme Court of the State of New York
Commercial Division Sean Topping
60 Centre Street Associate
Direct line +1 212 318 3361
Courtroom 208
sean.topping@nortonrosefulbright.com
New York, NY 10007
Tel +1 212 318 3000
Fax +1 212 318 3400
nortonrosefulbright.com
Re: Tekiner v. Bremen House, et al. (Index No. 657193/2020) – Proposed Stipulation and
Order for the Production and Exchange of Confidential Information
Dear Justice Cohen:
We represent Defendants Bremen House, Inc., Bremen House Texas, Inc., German News
Company, Inc., German News Texas, Inc., 254-258 W 35th St LLC, Berrin Tekiner, Gonca
Tekiner, and Billur Akipek (“Defendants”) in the above-referenced matter. On behalf of
Defendants and Plaintiff, Yasemin Tekiner, we write to submit a Proposed Stipulation and Order
for the Production and Exchange of Confidential Information, which has been executed by both
parties. Pursuant to Section IV.A. of Your Honor’s Practices and Procedures, we note that the
parties have not made any substantive changes to the Commercial Division Model Confidentiality
Order, but have omitted paragraph 11 as it does not apply to cases filed in New York County, and
have added the Commercial Division Privilege Clawback Provision set forth in Appendix E to the
Commercial Division Rules.
Thank you for your attention to this matter.
Respectfully submitted,
Sean Topping
SMT
Cc: Counsel of Record (via NYSCEF)
Norton Rose Fulbright US LLP is a limited liability partnership registered under the laws of Texas.
Norton Rose Fulbright US LLP, Norton Rose Fulbright LLP, Norton Rose Fulbright Australia, Norton Rose Fulbright Canada LLP and Norton Rose
Fulbright South Africa Inc are separate legal entities and all of them are members of Norton Rose Fulbright Verein, a Swiss verein. Norton Rose Fulbright
Verein helps coordinate the activities of the members but does not itself provide legal services to clients. Details of each entity, with certain regulatory
information, are available at nortonrosefulbright.com.
Document Filed Date
February 18, 2021
Case Filing Date
December 21, 2020
Category
Commercial Division
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February 18, 2021 Norton Rose Fulbright US LLP 1301 Avenue of the Americas New York, New York 10019-6022 Hon. Joel M. Cohen, J.S.C. United States Supreme Court of the State of New York Commercial Division Sean Topping 60 Centre Street Associate Direct line +1 212 318 3361 Courtroom 208 sean.topping@nortonrosefulbright.com New York, NY 10007 Tel +1 212 318 3000 Fax +1 212 318 3400 nortonrosefulbright.com Re: Tekiner v. Bremen House, et al. (Index No. 657193/2020) – Proposed Stipulation and Order for the Production and Exchange of Confidential Information Dear Justice Cohen: We represent Defendants Bremen House, Inc., Bremen House Texas, Inc., German News Company, Inc., German News Texas, Inc., 254-258 W 35th St LLC, Berrin Tekiner, Gonca Tekiner, and Billur Akipek (“Defendants”) in the above-referenced matter. On behalf of Defendants and Plaintiff, Yasemin Tekiner, we write to submit a Proposed Stipulation and Order for the Production and Exchange of Confidential Information, which has been executed by both parties. Pursuant to Section IV.A. of Your Honor’s Practices and Procedures, we note that the parties have not made any substantive changes to the Commercial Division Model Confidentiality Order, but have omitted paragraph 11 as it does not apply to cases filed in New York County, and have added the Commercial Division Privilege Clawback Provision set forth in Appendix E to the Commercial Division Rules. Thank you for your attention to this matter. Respectfully submitted, Sean Topping SMT Cc: Counsel of Record (via NYSCEF) Norton Rose Fulbright US LLP is a limited liability partnership registered under the laws of Texas. Norton Rose Fulbright US LLP, Norton Rose Fulbright LLP, Norton Rose Fulbright Australia, Norton Rose Fulbright Canada LLP and Norton Rose Fulbright South Africa Inc are separate legal entities and all of them are members of Norton Rose Fulbright Verein, a Swiss verein. Norton Rose Fulbright Verein helps coordinate the activities of the members but does not itself provide legal services to clients. Details of each entity, with certain regulatory information, are available at nortonrosefulbright.com.