On December 21, 2020 a
Motion-Secondary
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
FILED: NEW YORK COUNTY CLERK 03/08/2022 11:00 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 200 RECEIVED NYSCEF: 03/08/2022
SUPREME COURT OF THE STATE OF NEW YORK
COMMERCIAL DIVISION: NEW YORK COUNTY
-------------------------------------------------------------- x
YASEMIN TEKINER, in her individual capacity, :
as a beneficiary and a Trustee of The Yasemin : Index No.: 657193/2020
Tekiner 2011 Descendants Trust and derivatively as :
a holder of equitable interests in a shareholder or a : Motion Seq. No.:
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. :
-------------------------------------------------------------- x
EMERGENCY AFFIRMATION OF STEPHEN P. YOUNGER IN
SUPPORT OF PLAINTIFF’S MOTION TO SEAL CERTAIN DOCUMENTS
IN CONNECTION WITH PLAINTIFF’S MOTION FOR LEAVE TO RENEW
STEPHEN P. YOUNGER, being duly sworn, pursuant to C.P.L.R. § 2106, hereby
affirms the following to be true and correct under penalty of perjury:
1. I am an attorney duly admitted to practice before the courts of the State of New
York and am a member of the firm Foley Hoag LLP, located at 1301 Avenue of the Americas,
New York, NY 10019, counsel to Plaintiff Yasemin Tekiner (“Plaintiff”) in this action.
2. I make this affirmation in support of the application of Plaintiff to file under seal
all or portions of Exhibits A, B, and I to the Affirmation of Stephen P. Younger, dated March 7,
2022 (the “Younger Affirmation”). These exhibits contain information that Defendants have
designated as confidential pursuant to the Stipulation and Order for the Production and
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FILED: NEW YORK COUNTY CLERK 03/08/2022 11:00 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 200 RECEIVED NYSCEF: 03/08/2022
Exchange of Confidential Information [NYSCEF No. 91] (the “Confidentiality Stipulation”) in
this case, based on Defendants’ contention that these documents contain sensitive business
information and/or personal potentially identifying information. While Plaintiff does not
necessarily agree with these confidentiality designations, we are filing these documents under
seal given the provisions of the Confidentiality Stipulation in this case.
3. Accordingly, Plaintiff respectfully requests that the Court issue an order
permitting Plaintiff to file these documents under seal and to file only the redacted versions of
certain of these documents in order to protect their confidentiality as provided for in the
Confidentiality Stipulation.
4. No prior application for the relief sought herein has been made to this or any other
Court.
Dated: New York, New York
March 8, 2022
/s/ Stephen P. Younger
Stephen P. Younger
FOLEY HOAG LLP
1301 Avenue of the Americas, 25th Floor
New York, NY 10019
(212) 812-0365
spyounger@foleyhoag.com
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Document Filed Date
March 08, 2022
Case Filing Date
December 21, 2020
Category
Commercial Division
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Preview
FILED: NEW YORK COUNTY CLERK 03/08/2022 11:00 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 200 RECEIVED NYSCEF: 03/08/2022 SUPREME COURT OF THE STATE OF NEW YORK COMMERCIAL DIVISION: NEW YORK COUNTY -------------------------------------------------------------- x YASEMIN TEKINER, in her individual capacity, : as a beneficiary and a Trustee of The Yasemin : Index No.: 657193/2020 Tekiner 2011 Descendants Trust and derivatively as : a holder of equitable interests in a shareholder or a : Motion Seq. No.: 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. : -------------------------------------------------------------- x EMERGENCY AFFIRMATION OF STEPHEN P. YOUNGER IN SUPPORT OF PLAINTIFF’S MOTION TO SEAL CERTAIN DOCUMENTS IN CONNECTION WITH PLAINTIFF’S MOTION FOR LEAVE TO RENEW STEPHEN P. YOUNGER, being duly sworn, pursuant to C.P.L.R. § 2106, hereby affirms the following to be true and correct under penalty of perjury: 1. I am an attorney duly admitted to practice before the courts of the State of New York and am a member of the firm Foley Hoag LLP, located at 1301 Avenue of the Americas, New York, NY 10019, counsel to Plaintiff Yasemin Tekiner (“Plaintiff”) in this action. 2. I make this affirmation in support of the application of Plaintiff to file under seal all or portions of Exhibits A, B, and I to the Affirmation of Stephen P. Younger, dated March 7, 2022 (the “Younger Affirmation”). These exhibits contain information that Defendants have designated as confidential pursuant to the Stipulation and Order for the Production and 1 1 of 2 FILED: NEW YORK COUNTY CLERK 03/08/2022 11:00 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 200 RECEIVED NYSCEF: 03/08/2022 Exchange of Confidential Information [NYSCEF No. 91] (the “Confidentiality Stipulation”) in this case, based on Defendants’ contention that these documents contain sensitive business information and/or personal potentially identifying information. While Plaintiff does not necessarily agree with these confidentiality designations, we are filing these documents under seal given the provisions of the Confidentiality Stipulation in this case. 3. Accordingly, Plaintiff respectfully requests that the Court issue an order permitting Plaintiff to file these documents under seal and to file only the redacted versions of certain of these documents in order to protect their confidentiality as provided for in the Confidentiality Stipulation. 4. No prior application for the relief sought herein has been made to this or any other Court. Dated: New York, New York March 8, 2022 /s/ Stephen P. Younger Stephen P. Younger FOLEY HOAG LLP 1301 Avenue of the Americas, 25th Floor New York, NY 10019 (212) 812-0365 spyounger@foleyhoag.com 2 2 of 2