Preview
FILED: NEW YORK COUNTY CLERK 06/24/2022 12:10 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 570 RECEIVED NYSCEF: 06/24/2022
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 a holder of Index No. 657193/2020
equitable interests in a shareholder or
a member of the Company Commercial Division Part 3
Defendants,
Hon. Joel M. Cohen
Plaintiff,
Motion Sequence #24
-against-
AFFIRMATION OF SERVICE
BREMEN HOUSE INC., GERMAN NEWS
COMPANY, INC., BERRIN TEKINER, DEFENDANTS’ OPPOSITION TO
GONCA TEKINER, and BILLUR AKIPEK, PLAINTIFF’S MOTION TO REMOVE
in her capacity as a Trustee of The Yasemin BILLUR AKIPEK AS TRUST
Tekiner 2011 Descendants Trust, COMMITTEE MEMBER AND TO
APPOINT AN INDEPENDENT TRUST
Defendants. COMMITTEE MEMBER
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.
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FILED: NEW YORK COUNTY CLERK 06/24/2022 12:10 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 570 RECEIVED NYSCEF: 06/24/2022
I, Judith Archer, 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 Norton Rose Fulbright US LLP, counsel for Defendants Bremen House,
Inc. (“Bremen House”), German News Company, Inc. (“German News”) (both, the “Companies”),
Berrin Tekiner, Gonca (Tekiner) Chelsea, and Billur Akipek (collectively, the “Defendants”) in
the above-captioned action.
2. On June 23, 2022, I caused to be served Defendants’ Memorandum Of Law In
Opposition To Plaintiff’s Motion To Remove Billur Akipek As Trust Committee Member And To
Appoint An Independent Trust Committee Member; Affirmation of Judith Archer; Affidavit of
Billur Akipek; Affidavit of Berrin Tekiner; and Affidavit of Eve Rachel Markewich (together,
NYSCEF Nos. 554 – 569) as follows:
VIA E-MAIL
Parker Ibrahim & Berg LLP
Scott Parker, 5 Penn Plaza, Suite 2371, New York, New York 10001
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
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
Kahn & Goldberg, LLP Michele Khan, Esq.
555 Fifth Avenue, 14th Floor
New York, NY 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
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FILED: NEW YORK COUNTY CLERK 06/24/2022 12:10 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 570 RECEIVED NYSCEF: 06/24/2022
3. There were technical issues with the filing, as such Defendants served the
aforementioned counsel via email on June 23, 2022. Defendants subsequently e-filed the
opposition papers the morning of June 24, 2022.
4. 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 NORTON ROSE FULBRIGHT US LLP
June 24, 2022 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
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Preview
FILED: NEW YORK COUNTY CLERK 06/24/2022 12:10 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 570 RECEIVED NYSCEF: 06/24/2022 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 a holder of Index No. 657193/2020 equitable interests in a shareholder or a member of the Company Commercial Division Part 3 Defendants, Hon. Joel M. Cohen Plaintiff, Motion Sequence #24 -against- AFFIRMATION OF SERVICE BREMEN HOUSE INC., GERMAN NEWS COMPANY, INC., BERRIN TEKINER, DEFENDANTS’ OPPOSITION TO GONCA TEKINER, and BILLUR AKIPEK, PLAINTIFF’S MOTION TO REMOVE in her capacity as a Trustee of The Yasemin BILLUR AKIPEK AS TRUST Tekiner 2011 Descendants Trust, COMMITTEE MEMBER AND TO APPOINT AN INDEPENDENT TRUST Defendants. COMMITTEE MEMBER 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- 1 of 3 FILED: NEW YORK COUNTY CLERK 06/24/2022 12:10 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 570 RECEIVED NYSCEF: 06/24/2022 I, Judith Archer, 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 Norton Rose Fulbright US LLP, counsel for Defendants Bremen House, Inc. (“Bremen House”), German News Company, Inc. (“German News”) (both, the “Companies”), Berrin Tekiner, Gonca (Tekiner) Chelsea, and Billur Akipek (collectively, the “Defendants”) in the above-captioned action. 2. On June 23, 2022, I caused to be served Defendants’ Memorandum Of Law In Opposition To Plaintiff’s Motion To Remove Billur Akipek As Trust Committee Member And To Appoint An Independent Trust Committee Member; Affirmation of Judith Archer; Affidavit of Billur Akipek; Affidavit of Berrin Tekiner; and Affidavit of Eve Rachel Markewich (together, NYSCEF Nos. 554 – 569) as follows: VIA E-MAIL Parker Ibrahim & Berg LLP Scott Parker, 5 Penn Plaza, Suite 2371, New York, New York 10001 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 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 Kahn & Goldberg, LLP Michele Khan, Esq. 555 Fifth Avenue, 14th Floor New York, NY 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 -2- 2 of 3 FILED: NEW YORK COUNTY CLERK 06/24/2022 12:10 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 570 RECEIVED NYSCEF: 06/24/2022 3. There were technical issues with the filing, as such Defendants served the aforementioned counsel via email on June 23, 2022. Defendants subsequently e-filed the opposition papers the morning of June 24, 2022. 4. 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 NORTON ROSE FULBRIGHT US LLP June 24, 2022 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 -3- 3 of 3