Preview
At Part 3 of the Supreme Court of the State of
New York, County of New York, held at the
Courthouse at 60 Centre Street, New York,
New York, on the __ day of , 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, :
ORDER TO SHOW CAUSE TO
:
SEAL CERTAIN DOCUMENTS
- against – :
IN CONNECTION WITH
:
PROPOSED INTERVENOR-
BREMEN HOUSE INC., BREMEN HOUSE :
PLAINTIFF’S OPPOSITION
TEXAS, INC., GERMAN NEWS COMPANY, :
TO DEFENDANTS’ MOTION
INC., GERMAN NEWS TEXAS, INC., 254 - 258 :
FOR TEMPORARY
W. 35TH ST. LLC, BERRIN TEKINER, GONCA :
RESTAINING ORDER
TEKINER, and BILLUR AKIPEK, in her capacity :
as a Trustee of The Yasemin Tekiner 2011 :
Descendants Trust, :
Defendants. :
x
Proposed Intervenor-Plaintiff Zeynep Tekiner (“Zeynep”), by her attorneys, Kahn &
Goldberg LLP, having moved this Court for an Order to Show Cause why a further Order should
not be issued permitting the March 31, 2022 letter of Michele Kahn and the March 31, 2022 Affidavit of
Zeynep Tekine, both in opposition to Defendants’ motion for a temporary restraining order in connection
with Defendants’ assertion of attorney client privilege, and the exhibits thereto, 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 Michele Kahn, sworn to on March 31,
2022, the accompanying memorandum of law, and upon all papers filed and proceedings had
herein,
LET Defendants 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 the March 31, 2022 letter of Michele Kahn and the March 31, 2022 Affidavit
of Zeynep Tekine, both in opposition to Defendants’ motion for a temporary restraining order in
connection with Defendants’ assertion of attorney client privilege, and the exhibits thereto, to be filed
under seal; 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. 253,
254, 255, 256, 257, and 258, will remain temporarily under seal, accessible only to the parties,
their counsel, and court personnel.
Dated: , 2022
ENTER:
J.S.C.
Tekiner/Proposed OSC to Seal
Preview
At Part 3 of the Supreme Court of the State of New York, County of New York, held at the Courthouse at 60 Centre Street, New York, New York, on the __ day of , 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, : ORDER TO SHOW CAUSE TO : SEAL CERTAIN DOCUMENTS - against – : IN CONNECTION WITH : PROPOSED INTERVENOR- BREMEN HOUSE INC., BREMEN HOUSE : PLAINTIFF’S OPPOSITION TEXAS, INC., GERMAN NEWS COMPANY, : TO DEFENDANTS’ MOTION INC., GERMAN NEWS TEXAS, INC., 254 - 258 : FOR TEMPORARY W. 35TH ST. LLC, BERRIN TEKINER, GONCA : RESTAINING ORDER TEKINER, and BILLUR AKIPEK, in her capacity : as a Trustee of The Yasemin Tekiner 2011 : Descendants Trust, : Defendants. : x Proposed Intervenor-Plaintiff Zeynep Tekiner (“Zeynep”), by her attorneys, Kahn & Goldberg LLP, having moved this Court for an Order to Show Cause why a further Order should not be issued permitting the March 31, 2022 letter of Michele Kahn and the March 31, 2022 Affidavit of Zeynep Tekine, both in opposition to Defendants’ motion for a temporary restraining order in connection with Defendants’ assertion of attorney client privilege, and the exhibits thereto, 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 Michele Kahn, sworn to on March 31, 2022, the accompanying memorandum of law, and upon all papers filed and proceedings had herein, LET Defendants 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 the March 31, 2022 letter of Michele Kahn and the March 31, 2022 Affidavit of Zeynep Tekine, both in opposition to Defendants’ motion for a temporary restraining order in connection with Defendants’ assertion of attorney client privilege, and the exhibits thereto, to be filed under seal; 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. 253, 254, 255, 256, 257, and 258, will remain temporarily under seal, accessible only to the parties, their counsel, and court personnel. Dated: , 2022 ENTER: J.S.C. Tekiner/Proposed OSC to Seal