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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
YASEMIN TEKINER,
Index No.: 657193/2020
in her individual capacity, as a beneficiary
and a Trustee of The Yasemin Tekiner Motion Sequence No. ___
2011 Descendants Trust and derivatively as
a holder of equitable interests in a PLAINTIFF ZEYNEP
shareholder or a member of the Company TEKINER’SORDER TO SHOW
Defendants, CAUSE MOTION FOR ORDER,
IN FURTHERANCE OF COURT’S
Plaintiff,
NOVEMBER 19, 2022 ORDERS,
-against- IRECTING DEFENDANTS TO
FOLLOW THE DIRECTIONS
BREMEN HOUSE INC., GERMAN NEWS OF ZEYNEP TEKINER AS
COMPANY, INC., BERRIN TEKINER, GONCA THE SOLE MEMBER OF
TEKINER, and BILLUR AKIPEK, in her capacity THE TRUSTEE COMMITTEE
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.
Plaintiff Zeynep Tekiner (“Plaintiff”), by her attorneys, Kahn & Goldberg LLP, having
moved this Court for an Order to Show Cause why a further Order should not be issued directing
Defendants to follow the directions of Zeynep Tekiner as the sole member of the Trust
Committee or the Zeynep Tekiner 2011 Descendants Trust.
UPON THE ANNEXED AFFIDAVIT of Zeynep Tekiner, sworn to November 28, the
annexed affidavit of Gary Tannenbaum, sworn to November 28, 2022, the annexed affirmation
of Michele Kahn dated November 28, 2022, the emergency affirmation of Michele Kahn dated
November 28, 2022, and all of the exhibits annexed thereto, and upon the Memorandum of Law
submitted herewith, and upon all prior pleadings and proceedings herein,
LET the defendants 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, appear and show cause before this Court, at Part ___, at the
Courthouse, 60 Centre Street, Room ___, New York, New York, or virtually or otherwise as the
Court may direct, on _________________, 2022, at 9:30 a.m. or as soon thereafter as counsel may
be heard,
WHY an Order should not be issued in furtherance of the Court’s November 19, 2022
Decision and Order Removing Billur Akipek as a Member of the Trustee Committee of the
Zeynep Tekiner 2011 Descendants Trust directing Defendants to follow the directions of Zeynep
Tekiner as the sole member of the Trust Committee or the Zeynep Tekiner 2011 Descendants
Trust;
IT IS HEREBY ORDERED that any responsive papers to this motion 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 any reply papers on this motion shall be served by electronic mail on
counsel for Defendants and filed with the Clerk on or before_______________, 2022; and it is
further
ORDERED service of a conformed copy of this Order and of the papers upon which it is
granted by ECF and email upon Defendants’ attorney, sent on or before _____________, 2022
be deemed good and sufficient service hereof.
E N T E R:
J.S.C.
Tekiner/Z-M Direct Def Comply Z Sole Member/OSC 11-28-22 for filing
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SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK YASEMIN TEKINER, Index No.: 657193/2020 in her individual capacity, as a beneficiary and a Trustee of The Yasemin Tekiner Motion Sequence No. ___ 2011 Descendants Trust and derivatively as a holder of equitable interests in a PLAINTIFF ZEYNEP shareholder or a member of the Company TEKINER’SORDER TO SHOW Defendants, CAUSE MOTION FOR ORDER, IN FURTHERANCE OF COURT’S Plaintiff, NOVEMBER 19, 2022 ORDERS, -against- IRECTING DEFENDANTS TO FOLLOW THE DIRECTIONS BREMEN HOUSE INC., GERMAN NEWS OF ZEYNEP TEKINER AS COMPANY, INC., BERRIN TEKINER, GONCA THE SOLE MEMBER OF TEKINER, and BILLUR AKIPEK, in her capacity THE TRUSTEE COMMITTEE 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. Plaintiff Zeynep Tekiner (“Plaintiff”), by her attorneys, Kahn & Goldberg LLP, having moved this Court for an Order to Show Cause why a further Order should not be issued directing Defendants to follow the directions of Zeynep Tekiner as the sole member of the Trust Committee or the Zeynep Tekiner 2011 Descendants Trust. UPON THE ANNEXED AFFIDAVIT of Zeynep Tekiner, sworn to November 28, the annexed affidavit of Gary Tannenbaum, sworn to November 28, 2022, the annexed affirmation of Michele Kahn dated November 28, 2022, the emergency affirmation of Michele Kahn dated November 28, 2022, and all of the exhibits annexed thereto, and upon the Memorandum of Law submitted herewith, and upon all prior pleadings and proceedings herein, LET the defendants 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, appear and show cause before this Court, at Part ___, at the Courthouse, 60 Centre Street, Room ___, New York, New York, or virtually or otherwise as the Court may direct, on _________________, 2022, at 9:30 a.m. or as soon thereafter as counsel may be heard, WHY an Order should not be issued in furtherance of the Court’s November 19, 2022 Decision and Order Removing Billur Akipek as a Member of the Trustee Committee of the Zeynep Tekiner 2011 Descendants Trust directing Defendants to follow the directions of Zeynep Tekiner as the sole member of the Trust Committee or the Zeynep Tekiner 2011 Descendants Trust; IT IS HEREBY ORDERED that any responsive papers to this motion 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 any reply papers on this motion shall be served by electronic mail on counsel for Defendants and filed with the Clerk on or before_______________, 2022; and it is further ORDERED service of a conformed copy of this Order and of the papers upon which it is granted by ECF and email upon Defendants’ attorney, sent on or before _____________, 2022 be deemed good and sufficient service hereof. E N T E R: J.S.C. Tekiner/Z-M Direct Def Comply Z Sole Member/OSC 11-28-22 for filing