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  • 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 v. Bremen House Inc., German News Company, Inc., Berrin Tekiner, Gonca Tekiner, Billur Akipek in her capacity as a Trustee of the Yasemin Tekiner 2011 Descendants Trust, Zeynep Tekiner (Intervenor Plaintiff)Commercial Division document preview
  • 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 v. Bremen House Inc., German News Company, Inc., Berrin Tekiner, Gonca Tekiner, Billur Akipek in her capacity as a Trustee of the Yasemin Tekiner 2011 Descendants Trust, Zeynep Tekiner (Intervenor Plaintiff)Commercial Division document preview
  • 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 v. Bremen House Inc., German News Company, Inc., Berrin Tekiner, Gonca Tekiner, Billur Akipek in her capacity as a Trustee of the Yasemin Tekiner 2011 Descendants Trust, Zeynep Tekiner (Intervenor Plaintiff)Commercial Division document preview
  • 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 v. Bremen House Inc., German News Company, Inc., Berrin Tekiner, Gonca Tekiner, Billur Akipek in her capacity as a Trustee of the Yasemin Tekiner 2011 Descendants Trust, Zeynep Tekiner (Intervenor Plaintiff)Commercial Division document preview
						
                                

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FILED: NEW YORK COUNTY CLERK 06/15/2022 11:57 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 476 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 Motion Sequence #22 Defendants, NOTICE OF DEFENDANTS’ CROSS- Plaintiff, MOTION FOR PROTECTIVE ORDER REGARDING THE PERSONAL -against- MEDICAL HISTORY OF DEFENDANTS BERRIN TEKINER BREMEN HOUSE INC., GERMAN NEWS AND GONCA CHELSEA COMPANY, INC., BERRIN TEKINER, GONCA TEKINER, and BILLUR AKIPEK, in her capacity ORAL ARGUMENT REQUESTED 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 11:57 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 476 RECEIVED NYSCEF: 06/15/2022 PLEASE TAKE NOTICE that, upon the accompanying memorandum of law, affirmation of Judith A. Archer, Esq., dated June 15, 2022, affidavit of Gonca Tekiner Chelsea, sworn to June 15, 2022, affidavit of Billur Akipek, sworn to June 15, 2022, and affidavit of Berrin Tekiner, sworn to June 15, 2022, along with the exhibits annexed thereto, Defendants Bremen House, Inc., German News Company, Inc., Berrin Tekiner, Gonca Tekiner, and Billur Akipek will move this Court in the Motion Submission Part Courtroom (Room 130) located at 60 Centre Street, New York, New York, on June 22, 2022 at 9:30 a.m., or as soon thereafter as counsel can be heard, for an order protecting from disclosure Defendants Berrin Tekiner and Gonca Chelsea’s personal medical history including documents or testimony there about; and providing such other and different relief as the Court may deem just and proper. PLEASE TAKE FURTHER NOTICE THAT, reply papers, if any, are required to be served on June 21, 2022. Dated: June 15, 2022 NORTON ROSE FULBRIGHT US LLP By: /s/ Judith A. Archer Judith A. Archer Victoria V. Corder Sean M. Topping 1301 Avenue of the Americas New York, New York 10019-6022 Tel.: (212) 318-3000 Fax: (212) 318-3400 judith.archer@nortonrosefulbright.com victoria.corder@nortonrosefulbright.com sean.topping@nortonrosefulbright.com Attorneys for Defendants 2 of 2