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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Preview
                                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        day of                   , 2023.

                  SUPREME COURT OF THE STATE OF NEW YORK
                  COMMERCIAL DIVISION: NEW YORK COUNTY
                   --------------------------------------------------------------    x
                   YASEMIN TEKINER, in her individual capacity, as                   :
                   a beneficiary and a Trustee of The Yasemin Tekiner                :   Index No.: 657193/2020
                   2011 Descendants Trust and derivatively as a holder               :
                   of equitable interests in a shareholder or a member               :   Commercial Division Part 3
                   of the Company Defendants,                                        :
                                                                       Plaintiff,    :   Hon. Joel M. Cohen, J.S.C.
                                                                                     :
                            - against –                                              :   Motion Seq. No.:
                                                                                     :
                   BREMEN HOUSE INC., GERMAN NEWS                                    :    ORDER TO SHOW CAUSE TO
                   COMPANY, INC., BERRIN TEKINER, GONCA                              :    VACATE DEFENDANTS’ AND
                   TEKINER, and BILLUR AKIPEK, in her capacity                       :   PLAINTIFFS’ NOTES OF ISSUE
                   as a Trustee of The Yasemin Tekiner 2011                          :        AND CERTIFICATES OF
                   Descendants Trust,                                                :                 READINESS
                                                                    Defendants.      :
                   --------------------------------------------------------------    x

                   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.      x
                   --------------------------------------------------------------
                           Plaintiffs, Yasemin Tekiner and Zeynep Tekiner (“Plaintiffs”), by their attorneys, having

                  moved this Court for an        Order vacating the     Note   of  Issue and Certificate     of Readiness filed by

                  Defendants Bremen House Inc., German News Company, Inc., Berrin Tekiner, Gonca Chelsea,

                  and Billur Akipek (collectively, “Defendants”) (NYSCEF Doc. No. 997) (“Defendants’ Note of

                  Issue”) and vacating the Note of Issue and Certificate of Readiness filed by Plaintiffs (NYSCEF

                  Doc. No. 998) (“Plaintiffs’ Note of Issue”), extending discovery by sixty (60) days from the latest

                  decision   by   the Court    on  Plaintiffs’  pending    discovery    motions,    and  granting   such   other   and

                  different relief as the Court may deem just and proper.

                           UPON the annexed affirmation of Stephen P. Younger, sworn to on January 10, 2023, the

                  accompanying memorandum of law, and upon all papers filed and proceedings 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                                   , 2023 at 9:30 a.m., or as soon thereafter as counsel

                  can be heard,

                           WHY an order should not be made and entered:

                           1.       Vacating Defendants’ Note of Issue and Plaintiffs’ Note of Issue; and

                           2.       Extending discovery by sixty (60) days from the latest decision by the Court on

                                    Plaintiffs’ pending discovery motions; and

                           3.       Granting such other and further relief as this Court deems just and proper.

                           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 Plaintiffs and filed with the Clerk

                  on or before                                 , 2023; and it is further
                           ORDERED that any reply papers in further support of this motion made by Order to

                  Show Cause shall be served by electronic mail on counsel for Defendants and filed with the

                  Clerk on or before                                    , 2023; 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

                                                      , 2023, and such service shall be deemed good and sufficient

                  service hereof.



                  Dated:                                       , 2023
                                                                                 ENTER:




                                                                                                                     , J.S.C.