Request,Application: 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
                            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                     STIPULATION SETTING
                            Defendants,                                                REVISED
                                                                                       DISCOVERY DEADLINES
                                                       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.


                           WHEREAS, on August 24, 2021 Defendants interposed counterclaims for the first time

                  in this action,

                           IT IS HEREBY STIPULATED AND AGREED by the undersigned attorneys for the

                  parties that:

                           1.       The deadline to serve discovery demands shall be September 30,
                                    2021;

                           2.       The deadline to complete depositions shall be December 15, 2021;

                           3.       The deadline to complete fact discovery shall be December 15,
                                    2021;

                           4.       The deadline for CPLR 3101(d) expert disclosure shall be
                                    December 23, 2021;
                           5.       The end date for all discovery shall be January 31, 2022;

                           6.       The deadline to file the note of issue shall be February 1, 2022;

                           7.       The deadline for filing dispositive motions shall be March 2, 2022;
                                    and

                           8.       This stipulation may be executed in counterparts and with
                                    electronic or facsimile signatures.



                  Dated:    August 27, 2021


                    NORTON ROSE FULBRIGHT US LLP                              MANDEL BHANDARI LLP



                   By:   _/s/ Victoria Corder______________                    By:   _/s/ Evan Mandel_________________
                          Victoria Corder                                              Evan Mandel
                          1301 Avenue of the Americas                                  80 Pine Street, 33rd Floor
                          New York, NY 10019-6022                                      New York, NY 10005
                          (212) 318 3342                                               (212) 269-5600

                    Attorneys for Defendant                                    Attorneys for Plaintiff



                                                                                 SO ORDERED




                                                                                 ___________________________________
                                                                                 Hon. Joel M. Cohen




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