Request,Application: 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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                                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 equitable interests in a
                             shareholder or a member ofthe Company                 Index No.657193/2020
                             Defendants,
                                                                                   Commercial Division Part 3
                                                                      Plaintiff,
                                                                                   Hon. Joel M. Cohen
                                             -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                      STIPULATION SETTING REVISED
                     as a Trustee ofThe Yasemin Tekiner 2011                              DISCOVERY DEADLINES
                     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 ofthe 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.
                             WHEREAS, on April 28, 2022, the Court entered the parties’ proposed scheduling Order

                   (see Doc. No. 366);

                             WHEREAS,the parties appeared before the Court for a conference on July 22, 2022;

                             WHEREAS,the parties now respectfully seek to amend the dates in that Order;

                            NOW,THEREFORE,IT IS HEREBY STIPULATED AND AGREED by the undersigned

                    attorneys for the parties that:

                             1.      The deadline to complete fact discovery shall be October 17, 2022;

                            2.       The deadline for CPLR 3101(d) expert disclosure shall be November 15, 2022;

                            3.       The end date for all discovery shall be December 27, 2022;

                            4.       The deadline to file the note of issue shall be December 28, 2022;

                            5.       The deadline for filing dispositive motions shall be January 27, 2023; and

                            This   stipulation   may   be   executed   in  counterparts    and   with   electronic   or  facsimile

                    signatures.


                    Dated:   July  7", 2022
                    PARKER IBRAHIM & BERG LLP

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                     By:
                             Scott W. Parker
                             5 Penn Plaza
                             Suite 2371
                             New York, NY 10001
                            (908) 333-6220
                     Attorneysfor Plaintiff Yasemin       Tekiner

                    KAHN & GOLDBERG LLP



                     By:
                            Michele Kahn
                            555 Fifth Avenue, M'*" Floor
                            New York, NY 10017



                                                                           2
                            (212)687-5066
                            Attorneysfor PlaintiffZeynep Tekiner

                     PRYOR CASHMAN LLP




                    By:
                          Todd^ Soloway
                            Me^an E. Hill
                    7 Times Square
                    New York, NY 10036-6569
                   (212) 326-0808
                   Attorneysfor Defendants

                                                                                SO ORDERED:




                                                                                Hon. Joel M. Cohen




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