Motion-Secondary: 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)

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                                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

                      YASEMIN TEKINER,

                               in  her  individual   capacity,   as a  beneficiary
                               and a Trustee of The Yasemin Tekiner 2011
                               Descendants      Trust   and    derivatively    as  a       Index No.: 657193/2020
                               holder of equitable interests in a shareholder
                               or a member of the Company Defendants,                      Commercial Division Part 3

                                                          Plaintiff,                       Hon. Joel M. Cohen, J.S.C.

                                     - 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,
                                                                                                PLAINTIFF ZEYNEP TEKINER’S
                               in  her  individual   capacity,   as a  beneficiary              ORDER TO SHOW CAUSE TO
                               and  a  Trustee   of The   Zeynep    Tekiner   2011              SEAL CERTAIN DOCUMENTS IN
                               Descendants      Trust   and    derivatively    as  a            CONNECTION WITH YASMINE
                               holder of equitable interests in a shareholder                   TEKINER’S RULE 14 MOTION
                               or a member of the Company Defendants,                           FOR (I) PRODUCTION OF
                                                                                                DOCUMENTS SUBJECT TO THE
                                               Intervenor-Plaintiff,                            FIDUCIARY EXCEPTION TO
                                                                                                THE ATTORNEY-CLIENT
                                     - against -                                                PRIVILEGE AND WRONGFULLY
                                                                                                WITHHELD BY DEFENDANTS
                      BREMEN          HOUSE        INC.,     GERMAN           NEWS              AND (II) DISCOVERY
                      COMPANY,         INC.,    BERRIN      TEKINER,        GONCA               REGARDING THE MENTAL
                      TEKINER, and BILLUR AKIPEK, in her capacity as                            HEALTH AND
                      a Trustee   of  The   Zeynep    Tekiner   2011   Descendants              SUBSTANCE ABUSE ISSUES
                      Trust,

                                                         Defendants.
                           Plaintiff Zeynep Tekiner, by her attorneys Kahn & Goldberg LLP, having moved this Court

                  for an Order to Show Cause permitting the Reply Affidavit of Zeynep Tekiner in Support of Yasmine

                  Tekiner’s Rule 14 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; And

                  In Opposition/Reply to Defendants’ Cross-Motion For A Protective Order, and the exhibits thereto, to

                  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 June 28, 2022, the

                  accompanying memorandum of law, and upon all papers and proceeding 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 Reply Affidavit of Zeynep Tekiner in Support of Yasmine Tekiner’s

                  Rule   14  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;    And    In

                  Opposition/Reply to Defendants’ Cross-Motion For A Protective Order,                   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 be 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 Doc. Nos. 518,

                  519, and 520 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 - 4