Motion-Secondary: 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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                                FILED:         NEW     YORK       COUNTY        CLERK        09/08/2021             10:41        PM                 INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   153                                                                                RECEIVED      NYSCEF:     09/08/2021




                  SUPREME COURT OF THE STATE OF NEW YORK
                  COUNTY OF NEW YORK

                   YASEMIN TEKINER,

                            in her individual capacity, as a beneficiary
                            and a Trustee of The Yasemin Tekiner
                                                                                   Index No.: 657193/2020
                            2011 Descendants Trust and derivatively as
                            a holder of equitable interests in a
                                                                                   Motion Sequence #6
                            shareholder or a member of the Company
                            Defendants,
                                                                                   AFFIRMATION OF VICTORIA V.
                                                                                   CORDER IN OPPOSITION OF
                                                                Plaintiff,
                                                                                   PLAINTIFF’S MOTION TO AMEND
                                                                                   THE FIRST AMENDED COMPLAINT
                                            -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
                   CHELSEA, and BILLUR AKIPEK, in her
                   capacity as a Trustee of The Yasemin Tekiner
                   2011 Descendants Trust,

                                                                Defendants.


                           VICTORIA V. CORDER, an attorney duly admitted to practice law in the Courts of the

                  State of New York, affirms the following under penalty of perjury as follows:

                           1.       I am   an  attorney    associated   with   Norton    Rose   Fulbright   US    LLP,   counsel   for

                  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”). As such, I am fully familiar with the facts set forth herein. I submit this

                  affirmation,    pursuant   to  CPLR     2106,   in opposition     to Plaintiff’s   Motion    to Amend      the  First

                  Amended Complaint.

                           2.       Discovery in this case has been underway since Plaintiff served her initial discovery

                  requests on February 1, 2021.        Defendants made their initial document production on February 22,

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   FILED:         NEW     YORK       COUNTY        CLERK        09/08/2021             10:41        PM             INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   153                                                                            RECEIVED      NYSCEF:    09/08/2021




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   FILED:         NEW     YORK       COUNTY        CLERK        09/08/2021             10:41        PM                 INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   153                                                                                RECEIVED      NYSCEF:     09/08/2021




                                                                CERTIFICATION

                           Counsel for Defendants hereby certifies that this document complies with the word count

                  limit of Commercial Division Rule 17.           This affirmation was prepared using Microsoft Word, and

                  the total number of words in this affirmation, exclusive of the caption, table of contents, table of

                  authorities, and signature block is less than 7,000 words.



                  Dated: September 8, 2021                                                   By:   /s/ Victoria V. Corder
                           New York, New York                                                      Victoria V. Corder




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