Preview
FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 475 RECEIVED NYSCEF: 06/15/2022
SUPREME COURT OF THE STATE OF NEW YORK
COMMERCIAL DIVISION, NEW YORK COUNTY
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 Commercial Division Part 3
Defendants,
Hon. Joel M. Cohen
Plaintiff,
Motion Seq. No. 23
-against-
BREMEN HOUSE INC., BREMEN HOUSE
TEXAS, INC., GERMAN NEWS COMPANY, AFFIRMATION OF SERVICE
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.
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., 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.
1
Index No.: 657193/2020
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FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 475 RECEIVED NYSCEF: 06/15/2022
I, Scott W. Parker, Esq., hereby affirm under penalty of perjury as follows:
1. I am an attorney-at-law admitted to practice in the State of New York, and am a
Partner of the law firm of Parker Ibrahim & Berg LLP, co-counsel for Plaintiff 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 (“Plaintiff”) in the above-captioned action.
2. On June 15, 2022, I caused to be served Plaintiff’s Memorandum in of Law in
Opposition to Defendants’ Omnibus Motion to Compel Documents from Plaintiff and Lisa
Rubin and to Quash, Affirmation of Stephen P. Younger, Affidavit of Yasemin Tekiner,
Affidavit of Lisa Rubin, and this Affirmation of Service as follows:
VIA NYSCEF & E-MAIL
Norton Rose Fulbright US LLP
Judith A. Archer, Esq.
1301 Avenue of the Americas
New York, New York 10019
Attorneys for 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 Tekiner, and Billur
Akipek, in her capacity as a Trustee of The Yasemin Tekiner 2011 Descendants Trust
Foley Hoag LLP
Stephen P. Younger, Esq.
1301 Avenue of the Americas
New York, New York 10019
Co-Counsel for Plaintiff,
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
2
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FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 475 RECEIVED NYSCEF: 06/15/2022
Kahn & Goldberg, LLP
Michele Khan, Esq.
555 Fifth Avenue, 14th Floor
New York, New York 10017
Counsel for Intervenor-Plaintiff,
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
3. I hereby affirm that the foregoing statements made by me are true. I am aware
that if any of the foregoing statements made by me are willfully false I may be subject to
punishment.
Dated: New York, New York
June 15, 2022
PARKER IBRAHIM & BERG LLP
Co-Counsel for Plaintiff,
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
/s/ Scott W. Parker
Sanjay P. Ibrahim, Esq.
Scott W. Parker. Esq.
Daniel A. Schleifstein, Esq.
5 Penn Plaza, Suite 2371
New York, New York 10001
Telephone: (212) 596-7037
E-mail: sanjay.ibrahim@piblaw.com
scott.parker@piblaw.com
daniel.schleifstein@piblaw.com
Please reply to Somerset address:
270 Davidson Avenue, 5th Floor
Somerset, New Jersey 08873
Telephone: (908) 725-9700
3
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Preview
FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 475 RECEIVED NYSCEF: 06/15/2022 SUPREME COURT OF THE STATE OF NEW YORK COMMERCIAL DIVISION, NEW YORK COUNTY 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 Commercial Division Part 3 Defendants, Hon. Joel M. Cohen Plaintiff, Motion Seq. No. 23 -against- BREMEN HOUSE INC., BREMEN HOUSE TEXAS, INC., GERMAN NEWS COMPANY, AFFIRMATION OF SERVICE 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. 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., 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. 1 Index No.: 657193/2020 1 of 3 FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 475 RECEIVED NYSCEF: 06/15/2022 I, Scott W. Parker, Esq., hereby affirm under penalty of perjury as follows: 1. I am an attorney-at-law admitted to practice in the State of New York, and am a Partner of the law firm of Parker Ibrahim & Berg LLP, co-counsel for Plaintiff 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 (“Plaintiff”) in the above-captioned action. 2. On June 15, 2022, I caused to be served Plaintiff’s Memorandum in of Law in Opposition to Defendants’ Omnibus Motion to Compel Documents from Plaintiff and Lisa Rubin and to Quash, Affirmation of Stephen P. Younger, Affidavit of Yasemin Tekiner, Affidavit of Lisa Rubin, and this Affirmation of Service as follows: VIA NYSCEF & E-MAIL Norton Rose Fulbright US LLP Judith A. Archer, Esq. 1301 Avenue of the Americas New York, New York 10019 Attorneys for 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 Tekiner, and Billur Akipek, in her capacity as a Trustee of The Yasemin Tekiner 2011 Descendants Trust Foley Hoag LLP Stephen P. Younger, Esq. 1301 Avenue of the Americas New York, New York 10019 Co-Counsel for Plaintiff, 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 2 Index No.: 657193/2020 2 of 3 FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 475 RECEIVED NYSCEF: 06/15/2022 Kahn & Goldberg, LLP Michele Khan, Esq. 555 Fifth Avenue, 14th Floor New York, New York 10017 Counsel for Intervenor-Plaintiff, 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 3. I hereby affirm that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false I may be subject to punishment. Dated: New York, New York June 15, 2022 PARKER IBRAHIM & BERG LLP Co-Counsel for Plaintiff, 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 /s/ Scott W. Parker Sanjay P. Ibrahim, Esq. Scott W. Parker. Esq. Daniel A. Schleifstein, Esq. 5 Penn Plaza, Suite 2371 New York, New York 10001 Telephone: (212) 596-7037 E-mail: sanjay.ibrahim@piblaw.com scott.parker@piblaw.com daniel.schleifstein@piblaw.com Please reply to Somerset address: 270 Davidson Avenue, 5th Floor Somerset, New Jersey 08873 Telephone: (908) 725-9700 3 Index No.: 657193/2020 3 of 3