On December 21, 2020 a
No Value
was filed
involving a dispute between
Yasemin Tekiner,
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,
and
254-258 W. 35Th St. Llc,
Berrin Tekiner,
Billur Akipek
In Her Capacity As A Trustee Of The Yasemin Tekiner 2011 Descendants Trust,
Bremen House Inc.,
Bremen House Texas, Inc.,
German News Company, Inc.,
German News Texas, Inc.,
Gonca Tekiner,
Zeynep Tekiner,
for Commercial Division
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 01/13/2023 04:28 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1112 RECEIVED NYSCEF: 01/13/2023
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 Commercial Division Part 3
The Yasemin Tekiner 2011 Descendants Trust and
derivatively as a holder of equitable interests in a shareholder Hon. Joel M. Cohen
or a member of the Company Defendants,
Mot. Seq. No. 42
Plaintiff,
-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,
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 Yasemin Tekiner
2011 Descendants Trust.
Defendants.
EMERGENCY AFFIRMATION OF BRYAN T. MOHLER IN SUPPORT OF
DEFENDANTS’ MOTION TO SEAL CERTAIN DOCUMENTS RELATING TO
HEALTH INFORMATION
1 of 4
FILED: NEW YORK COUNTY CLERK 01/13/2023 04:28 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1112 RECEIVED NYSCEF: 01/13/2023
BRYAN T. MOHLER, ESQ., an attorney duly admitted to practice before the Courts of
the State of New York, affirms under the penalty of perjury, pursuant to CPLR § 2106 as follows:
1. I am a partner of the law firm Pryor Cashman LLP, co-counsel for defendants
Bremen House Inc., German News, Inc., Berrin Tekiner, Gonca Tekiner, and Billur Akipek
(collectively, “Defendants”) in the above-captioned matter.
2. I submit this affirmation in support of Defendants’ application to file under seal:
(1) Defendants’ Memorandum of Law in Opposition to Plaintiff Yasemin Tekiner and Intervenor-
Plaintiff Zeynep Tekiner’s Motion for an Order Seeking Leave to take Post-Note of Issue
Discovery, and Alternatively, for a Case Management Conference and/or to Appoint a Special
Master, (2) the Affirmation of Bryan T. Mohler in Opposition, and (3) certain exhibits to the
Affirmation of Bryan T. Mohler in Opposition, each filed January 9, 2023 (collectively, the
“Sealed Documents”), to be filed under seal, and granting such other relief as the Court may deem
just and proper.
3. These filings contain information that has designated as protected health
information – attorneys’ eyes only pursuant to the Amended Stipulation and Order for the
Production and Exchange of Confidential Information (NYSCEF Dkt. No. 856) (the
“Confidentiality Stipulation”) in this case, because these documents contain sensitive information
regarding the personal health and treatment information of Defendants Berrin Tekiner and Gonca
Tekiner.
4. Accordingly, Defendants respectfully request that the Court issue an order
permitting the Sealed Documents to be filed under seal in order to protect the confidentiality of
the documents and information as provided for in the Confidentiality Stipulation.
1
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FILED: NEW YORK COUNTY CLERK 01/13/2023 04:28 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1112 RECEIVED NYSCEF: 01/13/2023
5. No prior application for the relief sought herein has been made to this or any other
Court.
Dated: New York, New York PRYOR CASHMAN LLP
January 10, 2023
By: /s/ Bryan T. Mohler________
Todd E. Soloway
Bryan T. Mohler
Rachel E. Shaw
7 Times Square
New York, New York 10036-6569
Tel: (212) 421-4100
Fax: (212) 326-0806
Attorneys for Defendants
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FILED: NEW YORK COUNTY CLERK 01/13/2023 04:28 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1112 RECEIVED NYSCEF: 01/13/2023
Certification Required by Rule 17 of the
Rules of the Commercial Division of the Supreme Court
I am the attorney who is filing this document. I hereby certify that this document, exclusive
of the caption, table of contents, table of authorities, and signature block contains 285 words as
counted by the word-processing system used to prepare the document.
/s/ Bryan T. Mohler
Bryan T. Mohler
4 of 4
Preview
FILED: NEW YORK COUNTY CLERK 01/13/2023 04:28 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1112 RECEIVED NYSCEF: 01/13/2023 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 Commercial Division Part 3 The Yasemin Tekiner 2011 Descendants Trust and derivatively as a holder of equitable interests in a shareholder Hon. Joel M. Cohen or a member of the Company Defendants, Mot. Seq. No. 42 Plaintiff, -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, 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 Yasemin Tekiner 2011 Descendants Trust. Defendants. EMERGENCY AFFIRMATION OF BRYAN T. MOHLER IN SUPPORT OF DEFENDANTS’ MOTION TO SEAL CERTAIN DOCUMENTS RELATING TO HEALTH INFORMATION 1 of 4 FILED: NEW YORK COUNTY CLERK 01/13/2023 04:28 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1112 RECEIVED NYSCEF: 01/13/2023 BRYAN T. MOHLER, ESQ., an attorney duly admitted to practice before the Courts of the State of New York, affirms under the penalty of perjury, pursuant to CPLR § 2106 as follows: 1. I am a partner of the law firm Pryor Cashman LLP, co-counsel for defendants Bremen House Inc., German News, Inc., Berrin Tekiner, Gonca Tekiner, and Billur Akipek (collectively, “Defendants”) in the above-captioned matter. 2. I submit this affirmation in support of Defendants’ application to file under seal: (1) Defendants’ Memorandum of Law in Opposition to Plaintiff Yasemin Tekiner and Intervenor- Plaintiff Zeynep Tekiner’s Motion for an Order Seeking Leave to take Post-Note of Issue Discovery, and Alternatively, for a Case Management Conference and/or to Appoint a Special Master, (2) the Affirmation of Bryan T. Mohler in Opposition, and (3) certain exhibits to the Affirmation of Bryan T. Mohler in Opposition, each filed January 9, 2023 (collectively, the “Sealed Documents”), to be filed under seal, and granting such other relief as the Court may deem just and proper. 3. These filings contain information that has designated as protected health information – attorneys’ eyes only pursuant to the Amended Stipulation and Order for the Production and Exchange of Confidential Information (NYSCEF Dkt. No. 856) (the “Confidentiality Stipulation”) in this case, because these documents contain sensitive information regarding the personal health and treatment information of Defendants Berrin Tekiner and Gonca Tekiner. 4. Accordingly, Defendants respectfully request that the Court issue an order permitting the Sealed Documents to be filed under seal in order to protect the confidentiality of the documents and information as provided for in the Confidentiality Stipulation. 1 2 of 4 FILED: NEW YORK COUNTY CLERK 01/13/2023 04:28 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1112 RECEIVED NYSCEF: 01/13/2023 5. No prior application for the relief sought herein has been made to this or any other Court. Dated: New York, New York PRYOR CASHMAN LLP January 10, 2023 By: /s/ Bryan T. Mohler________ Todd E. Soloway Bryan T. Mohler Rachel E. Shaw 7 Times Square New York, New York 10036-6569 Tel: (212) 421-4100 Fax: (212) 326-0806 Attorneys for Defendants 3 of 4 FILED: NEW YORK COUNTY CLERK 01/13/2023 04:28 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1112 RECEIVED NYSCEF: 01/13/2023 Certification Required by Rule 17 of the Rules of the Commercial Division of the Supreme Court I am the attorney who is filing this document. I hereby certify that this document, exclusive of the caption, table of contents, table of authorities, and signature block contains 285 words as counted by the word-processing system used to prepare the document. /s/ Bryan T. Mohler Bryan T. Mohler 4 of 4