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At an IAS Part __ of the Supreme Court of the State of
New York, County of New York, at the Courthouse,
60 Centre Street, New York, New York, on
__________, 2022
PRESENT: HON. ____________________
_____________________________________________X
YASEMIN TEKINER,
Index No. 657193/20
in her individual capacity, as a beneficiary,
and a Trustee of the Yasmine Tekiner 2011
Descendants Trust and derivatively as a PROPOSED INTERVENOR-
holder of equitable interests in a shareholder PLAINTIFF ZEYNEP TEKINER’S
or a member of the Company Defendants, ORDER TO SHOW CAUSE MOTION
TO INTERVENE AND FOR
Plaintiff,
PRELIMINARY INJUNCTION WITH
-against- TEMPORARY RESTRAINING ORDER
BREMEN HOUSE INC., BREMEN HOUSE TEXAS, INC., REQUESTED THAT RETURN DATE
GERMAN NEWS COMPANY, INC., GERMAN NEWS BE SET FOR APRIL 13, 2022
TEXAS, INC., 254-258 W. 35TH ST., LLC,
BERRIN TEKINER, GONCA TEKINER and BILLUR ORAL ARGUMENT REQUESTED
AKIPEK, in her capacity as a Trustee of the
Yasemin Tekiner 2011 Descendants Trust, Motion Sequence #010
Defendants.
_____________________________________________
UPON THE ANNEXED AFFIDAVIT of Zeynep Tekiner (“Proposed Intervenor”)
affirmed pursuant to CPLR 2106 (6) March 22, 2022, the annexed affirmation of Michele Kahn
dated March 22, 2022, the emergency affirmation of Michele Kahn dated March 22, 2022, and
all of the exhibits annexed thereto, which include the proposed intervenor’s proposed Verified
Complaint in Intervention, and upon the Memorandum of Law submitted herewith, and upon all
prior pleadings and proceedings herein,
LET the 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
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Tekiner and Billur Akipek, appear and show cause before this Court, at Part ___, at the
Courthouse, 60 Centre Street, Room ___, New York, New York, or virtually or otherwise as the
Court may direct, on _______________, 2022, at 9:30 a.m. or as soon thereafter as counsel may
be heard, why an Order should not be issued:
(a) pursuant to, inter alia, CPLR 1012 and 1013:
(i) granting Zeynep Tekiner permission to intervene as of right; or in the alternative, to
intervene with permission;
(ii) directing that the amended summons be served upon Defendants in the manner to be
directed by the Court;
(iii) directing that the Verified Complaint in Intervention Intervenor and Plaintiff
complaint in the form attached to the Zeynep Tekiner affidavit as Exhibit A be served
upon Defendants in the manner to be directed by the Court;
and
(b) pursuant to inter alia, CPLR 6301, 6311, 6312, and 6313, enjoining Defendants and their
agents from:
(i) terminating Zeynep from her position as a director, officer, employee, or Trustee
of any or all of the Company(ies) or the Zeynep Trust;
(ii) reducing her salary, bonus, or other payment heretofor made to her or for her
benefit;
(iii) removing her from her home in Bronxville, NY or impairing her rights to use
and occupy her home;
(iv) reducing or stopping payments of all expenses previously paid on Zeynep’s
Bronxville home; and
(v) taking any other retaliatory action against Zeynep;
and
(c) granting Zeynep such other relief as the Court deems just and proper.
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SUFFICIENT CAUSE APPEARING THEREFOR, pending the hearing and
determination of this motion, it is hereby:
ORDERED, that Defendants and their agents are enjoined from: terminating Zeynep from
her position as a director, officer or employee of any or all of the Company(ies) and the Zeynep
Trust; reducing Zeynep’s salary, bonus, or other payments heretofore made to her or for her
benefit; removing Zeynep from her home in Bronxville, NY or impairing her rights to use and
occupy her home; reducing or stopping payments of all expenses previously paid on Zeynep’s
Bronxville home; and taking any other retaliatory action against Zeynep; and
LET service of a conformed copy of this Order and of the papers upon which it is
granted by ECF and email upon Defendants’ attorney, sent on or before ___________, 2022 be
deemed good and sufficient service hereof.
E N T E R:
J.S.C.
Tekiner/OSC Intervene and Injunctive Relief FINAL FOR FILING
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Preview
At an IAS Part __ of the Supreme Court of the State of New York, County of New York, at the Courthouse, 60 Centre Street, New York, New York, on __________, 2022 PRESENT: HON. ____________________ _____________________________________________X YASEMIN TEKINER, Index No. 657193/20 in her individual capacity, as a beneficiary, and a Trustee of the Yasmine Tekiner 2011 Descendants Trust and derivatively as a PROPOSED INTERVENOR- holder of equitable interests in a shareholder PLAINTIFF ZEYNEP TEKINER’S or a member of the Company Defendants, ORDER TO SHOW CAUSE MOTION TO INTERVENE AND FOR Plaintiff, PRELIMINARY INJUNCTION WITH -against- TEMPORARY RESTRAINING ORDER BREMEN HOUSE INC., BREMEN HOUSE TEXAS, INC., REQUESTED THAT RETURN DATE GERMAN NEWS COMPANY, INC., GERMAN NEWS BE SET FOR APRIL 13, 2022 TEXAS, INC., 254-258 W. 35TH ST., LLC, BERRIN TEKINER, GONCA TEKINER and BILLUR ORAL ARGUMENT REQUESTED AKIPEK, in her capacity as a Trustee of the Yasemin Tekiner 2011 Descendants Trust, Motion Sequence #010 Defendants. _____________________________________________ UPON THE ANNEXED AFFIDAVIT of Zeynep Tekiner (“Proposed Intervenor”) affirmed pursuant to CPLR 2106 (6) March 22, 2022, the annexed affirmation of Michele Kahn dated March 22, 2022, the emergency affirmation of Michele Kahn dated March 22, 2022, and all of the exhibits annexed thereto, which include the proposed intervenor’s proposed Verified Complaint in Intervention, and upon the Memorandum of Law submitted herewith, and upon all prior pleadings and proceedings herein, LET the 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 1 Tekiner and Billur Akipek, appear and show cause before this Court, at Part ___, at the Courthouse, 60 Centre Street, Room ___, New York, New York, or virtually or otherwise as the Court may direct, on _______________, 2022, at 9:30 a.m. or as soon thereafter as counsel may be heard, why an Order should not be issued: (a) pursuant to, inter alia, CPLR 1012 and 1013: (i) granting Zeynep Tekiner permission to intervene as of right; or in the alternative, to intervene with permission; (ii) directing that the amended summons be served upon Defendants in the manner to be directed by the Court; (iii) directing that the Verified Complaint in Intervention Intervenor and Plaintiff complaint in the form attached to the Zeynep Tekiner affidavit as Exhibit A be served upon Defendants in the manner to be directed by the Court; and (b) pursuant to inter alia, CPLR 6301, 6311, 6312, and 6313, enjoining Defendants and their agents from: (i) terminating Zeynep from her position as a director, officer, employee, or Trustee of any or all of the Company(ies) or the Zeynep Trust; (ii) reducing her salary, bonus, or other payment heretofor made to her or for her benefit; (iii) removing her from her home in Bronxville, NY or impairing her rights to use and occupy her home; (iv) reducing or stopping payments of all expenses previously paid on Zeynep’s Bronxville home; and (v) taking any other retaliatory action against Zeynep; and (c) granting Zeynep such other relief as the Court deems just and proper. 2 SUFFICIENT CAUSE APPEARING THEREFOR, pending the hearing and determination of this motion, it is hereby: ORDERED, that Defendants and their agents are enjoined from: terminating Zeynep from her position as a director, officer or employee of any or all of the Company(ies) and the Zeynep Trust; reducing Zeynep’s salary, bonus, or other payments heretofore made to her or for her benefit; removing Zeynep from her home in Bronxville, NY or impairing her rights to use and occupy her home; reducing or stopping payments of all expenses previously paid on Zeynep’s Bronxville home; and taking any other retaliatory action against Zeynep; and LET service of a conformed copy of this Order and of the papers upon which it is granted by ECF and email upon Defendants’ attorney, sent on or before ___________, 2022 be deemed good and sufficient service hereof. E N T E R: J.S.C. Tekiner/OSC Intervene and Injunctive Relief FINAL FOR FILING 3