On December 21, 2020 a
Party Discovery
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 06/15/2022 10:03 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 464 RECEIVED NYSCEF: 06/15/2022
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
2011 Descendants Trust and derivatively as Index No.: 657193/2020
a holder of equitable interests in a
shareholder or a member of the Company
Defendants,
Motion Sequence No. 18
Plaintiff,
-against-
BREMEN HOUSE INC., GERMAN NEWS
COMPANY, INC., BERRIN TEKINER, GONCA
TEKINER, and BILLUR AKIPEK, in her capacity
as a Trustee of The Yasemin Tekiner 2011
Descendants Trust,
Defendants.
ZEYNEP TEKINER,
in her individual capacity, as a beneficiary
and a Trustee of The Zeynep Tekiner 2011
Descendants Trust and derivatively as a
holder of equitable interests in a
shareholder or a member of the Company
Defendants,
Intervenor-Plaintiff,
-against-
BREMEN HOUSE INC., GERMAN NEWS
COMPANY, INC., BERRIN TEKINER, GONCA
TEKINER, and BILLUR AKIPEK, in her capacity
as a Trustee of The Zeynep Tekiner 2011
Descendants Trust,
Defendants.
1 of 2
FILED: NEW YORK COUNTY CLERK 06/15/2022 10:03 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 464 RECEIVED NYSCEF: 06/15/2022
AFFIRMATION OF MICHELE KAHN IN SUPPORT OF YASMINE TEKINER’S
MOTION FOR (I) PRODUCTION OF DOCUMENTS SUBJECT TO THE
FIDUCIARY EXCEPTION TO THE ATTORNEY-CLIENT PRIVILEGE
AND WRONGFULLY WITHHELD BY DEFENDANTS AND
(II) DISCOVERY REGARDING THE MENTAL HEALTH AND
SUBSTANCE ABUSE ISSUES AS SPECIFIED IN YASEMIN’S MOTION
MICHELE KAHN, an attorney duly admitted to practice before the Court of the State of
New York, affirms under penalties of perjury:
1. I am a partner of Kahn & Goldberg, LLP, attorneys for Plaintiff-Intervenor Zeynep
Tekiner.
2. I submit this affirmation to advise the Court that Zeynep Tekiner supports the motion of
Plaintiff Yasmine Tekiner for (I) Production of Documents Subject to the Fiduciary Exception to
the Attorney-Client Privilege and Wrongfully Withheld By Defendants and (II) Discovery
Regarding the Mental Health and Substance Abuse Issues as Specified in Yasemin’s Motion.
3. For the reasons set forth in Yasemin’s moving papers, the motion should be granted.
Dated: New York, New York
June 15, 2022
________________________________
Michele Kahn
Tekiner/MK Aff-Supp Y-M-Prod Exec Priv Docs and Mental Hlth Docs
2 of 2
Document Filed Date
June 15, 2022
Case Filing Date
December 21, 2020
Category
Commercial Division
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FILED: NEW YORK COUNTY CLERK 06/15/2022 10:03 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 464 RECEIVED NYSCEF: 06/15/2022 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 2011 Descendants Trust and derivatively as Index No.: 657193/2020 a holder of equitable interests in a shareholder or a member of the Company Defendants, Motion Sequence No. 18 Plaintiff, -against- BREMEN HOUSE INC., GERMAN NEWS COMPANY, INC., BERRIN TEKINER, GONCA TEKINER, and BILLUR AKIPEK, in her capacity as a Trustee of The Yasemin Tekiner 2011 Descendants Trust, Defendants. ZEYNEP TEKINER, in her individual capacity, as a beneficiary and a Trustee of The Zeynep Tekiner 2011 Descendants Trust and derivatively as a holder of equitable interests in a shareholder or a member of the Company Defendants, Intervenor-Plaintiff, -against- BREMEN HOUSE INC., GERMAN NEWS COMPANY, INC., BERRIN TEKINER, GONCA TEKINER, and BILLUR AKIPEK, in her capacity as a Trustee of The Zeynep Tekiner 2011 Descendants Trust, Defendants. 1 of 2 FILED: NEW YORK COUNTY CLERK 06/15/2022 10:03 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 464 RECEIVED NYSCEF: 06/15/2022 AFFIRMATION OF MICHELE KAHN IN SUPPORT OF YASMINE TEKINER’S MOTION FOR (I) PRODUCTION OF DOCUMENTS SUBJECT TO THE FIDUCIARY EXCEPTION TO THE ATTORNEY-CLIENT PRIVILEGE AND WRONGFULLY WITHHELD BY DEFENDANTS AND (II) DISCOVERY REGARDING THE MENTAL HEALTH AND SUBSTANCE ABUSE ISSUES AS SPECIFIED IN YASEMIN’S MOTION MICHELE KAHN, an attorney duly admitted to practice before the Court of the State of New York, affirms under penalties of perjury: 1. I am a partner of Kahn & Goldberg, LLP, attorneys for Plaintiff-Intervenor Zeynep Tekiner. 2. I submit this affirmation to advise the Court that Zeynep Tekiner supports the motion of Plaintiff Yasmine Tekiner for (I) Production of Documents Subject to the Fiduciary Exception to the Attorney-Client Privilege and Wrongfully Withheld By Defendants and (II) Discovery Regarding the Mental Health and Substance Abuse Issues as Specified in Yasemin’s Motion. 3. For the reasons set forth in Yasemin’s moving papers, the motion should be granted. Dated: New York, New York June 15, 2022 ________________________________ Michele Kahn Tekiner/MK Aff-Supp Y-M-Prod Exec Priv Docs and Mental Hlth Docs 2 of 2