Motion,Ex Parte: 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 v. Bremen House Inc., German News Company, Inc., Berrin Tekiner, Gonca Tekiner, Billur Akipek in her capacity as a Trustee of the Yasemin Tekiner 2011 Descendants Trust, Zeynep Tekiner (Intervenor Plaintiff)

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                                SUPREME COURT OF THE STATE OF NEW YORK
                  COMMERCIAL DIVISION, NEW YORK COUNTY


                   YASEMIN TEKINER,
                                                                                       Index No. 657193/2020
                            In her individual capacity, as a beneficiary               Motion Seq. #003
                            and a Trustee of The Yasemin Tekiner                       Commercial Division Part 3
                            2011 Descendants Trust and derivatively                    Hon. Joel M. Cohen
                            as a holder of equitable interests in a
                            shareholder or a member of the Company
                            Defendants,

                                                       Plaintiff,

                                  - against -

                   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, in
                   her capacity as a Trustee of The Yasemin Tekiner
                   2011 Descendants Trust,

                                                       Defendants.



                           STIPULATION SETTING BRIEFING DATES FOR MOTION TO DISMISS

                                    IT IS HEREBY STIPULATED AND AGREED by the undersigned attorneys for

                  the parties that:

                           1.       Plaintiff shall file her opposition to Defendants’ Motion to Dismiss
                                    the Verified Amended Complaint on or before March 29, 2021;

                           2.       Defendants shall file any reply in further support of the Motion to
                                    Dismiss on or before April 12, 2021;

                           3.       The return date of the Motion to Dismiss shall be April 13, 2021;
                                    and

                           4.       This stipulation may be executed in counterparts and with
                                    electronic or facsimile signatures.
                  Dated:    March 8, 2021

                    NORTON ROSE FULBRIGHT US LLP                              MANDEL BHANDARI LLP



                   By:   _/s/ Victoria Corder________________                  By:   _/s/ Evan Mandel__________________
                          Judith A. Archer                                             Evan Mandel
                          Victoria Corder                                              Donald Conklin
                          1301 Avenue of the Americas                                  80 Pine Street, 33rd Floor
                          New York, NY 10019-6022                                      New York, New York 10005
                          (212) 318 3342                                                (212) 269-5600

                    Attorneys for Defendant                                    Attorneys for Plaintiff



                                                                                 SO ORDERED




                                                                                 ___________________________________
                                                                                 Hon. Joel M. Cohen




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