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At Part 3 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 ___ day of , 2022.
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 #11
shareholder or a member of the Company
Defendants,
ORDER TO SHOW CAUSE TO SEAL
CERTAIN DOCUMENTS IN
Plaintiff,
CONNECTION WITH PLAINTIFF’S
MOTION FOR LEAVE TO RENEW
-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.
Defendants, Bremen House, Inc., German News Company, Inc., Berrin Tekiner, Gonca
(Tekiner) Chelsea, and Billur Akipek (“Defendants”), by their attorneys, Norton Rose Fulbright
US LLP, having moved this Court for an Order to Show Cause why a further Order should not
be issued permitting certain exhibits attached to the Affirmation of Judith A. Archer, dated
March 24, 2022 (the “Archer Affirmation”), and the Affidavit of Berrin Tekiner, dated March
24, 2022 (the “Tekiner Affidavit”) submitted in opposition to Plaintiff’s Motion for Leave to
Renew be filed under seal or in redacted form, and granting such other and different relief as
the Court may deem just and proper.
UPON the annexed emergency affirmation of Judith A. Archer, sworn to on March 24,
2022, the accompanying memorandum of law, and upon all papers filed and proceedings had
herein,
LET Plaintiff show cause before the Honorable Joel M. Cohen of this Supreme Court
of the State of New York, at the Courthouse Part 3 at 60 Centre Street, New York, NY 10007
on the day of , 2022 at 9:30 a.m., or as soon thereafter as counsel
can be heard,
WHY an order should not be made and entered:
1. Permitting certain exhibits attached to the Archer Affirmation and Tekiner
Affidavit submitted in opposition to Plaintiff’s Motion for Leave to Renew to be filed under
seal or in redacted form only; and
2. Granting such other and further relief as this Court deems just and proper.
IT IS HEREBY ORDERED that any responsive papers to this motion made by Order
to Show Cause shall be served by electronic mail on counsel for Plaintiff and filed with the
Clerk on or before , 2022; and it is further
ORDERED that service by electronic mail of this Order to Show Cause, together with the
papers upon which it is based, shall be made upon counsel for the Defendants on or before
, 2022, and such service shall be deemed sufficient; and it is further
ORDERED that pending the hearing on this Order to Show Cause, NYSCEF Nos. 226,
228, 229, 230, 236, and 238, will remain temporarily under seal, accessible only to the parties,
their counsel, and court personnel.
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Dated: , 2022
ENTER:
J.S.C.
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