Preview
FILED: NEW YORK COUNTY CLERK 10/31/2022 01:02 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 848 RECEIVED NYSCEF: 10/31/2022
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. 36
-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.
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FILED: NEW YORK COUNTY CLERK 10/31/2022 01:02 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 848 RECEIVED NYSCEF: 10/31/2022
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 October 31, 2022, I caused to be served Plaintiff’s: (i) Order to Show Cause;
(ii) Memorandum in Support; (iii)Emergency Affirmation of Scott W. Parker in Support; and
(iv) this Affirmation of Service as follows:
VIA NYSCEF
Pryor Cashman LLP
Todd E. Soloway, Esq.
7 Times Square
New York, New York 10036-6569
Attorneys for Defendants,
Bremen House Inc., Bremen House Texas, Inc., German News Company, Inc., German
th
News Texas, Inc., 254 – 258 W. 35 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
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 10/31/2022 01:02 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 848 RECEIVED NYSCEF: 10/31/2022
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
October 31, 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
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Preview
FILED: NEW YORK COUNTY CLERK 10/31/2022 01:02 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 848 RECEIVED NYSCEF: 10/31/2022 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. 36 -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 1 of 3 FILED: NEW YORK COUNTY CLERK 10/31/2022 01:02 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 848 RECEIVED NYSCEF: 10/31/2022 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 October 31, 2022, I caused to be served Plaintiff’s: (i) Order to Show Cause; (ii) Memorandum in Support; (iii)Emergency Affirmation of Scott W. Parker in Support; and (iv) this Affirmation of Service as follows: VIA NYSCEF Pryor Cashman LLP Todd E. Soloway, Esq. 7 Times Square New York, New York 10036-6569 Attorneys for Defendants, Bremen House Inc., Bremen House Texas, Inc., German News Company, Inc., German th News Texas, Inc., 254 – 258 W. 35 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 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 10/31/2022 01:02 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 848 RECEIVED NYSCEF: 10/31/2022 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 October 31, 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 3 of 3