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FILED: NEW YORK COUNTY CLERK 01/27/2023 01:36 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1120 RECEIVED NYSCEF: 01/27/2023
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, J.S.C.
Plaintiff,
Motion Seq. Nos.:
-against- 44, 45, 47, 48
BREMEN HOUSE INC., GERMAN NEWS STIPULATION
COMPANY, INC., BERRIN TEKINER, GONCA GOVERNING BRIEFING
TEKINER, and BILLUR AKIPEK, in her capacity SCHEDULES AND WORD
as a Trustee of The Yasemin Tekiner 2011 LIMITS FOR PENDING
Descendants Trust, MOTIONS
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.
IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiffs, Yasemin
Tekiner and Zeynep Tekiner (“Plaintiffs”), and Defendants, Bremen House, Inc., German News
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FILED: NEW YORK COUNTY CLERK 01/27/2023 01:36 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1120 RECEIVED NYSCEF: 01/27/2023
Company, Inc., Berrin Tekiner, Gonca Tekiner, and Billur Akipek (“Defendants”) (each
individually a “Party” and collectively the “Parties”), through their undersigned counsel, hereby
jointly agree to the following motion submission schedule:
Plaintiffs’ Motions to Compel (motion sequence nos. 44, 45 and 47) (the “Motions to
Compel”):
1. The date by which Defendants must submit and serve their combined opposition to
the Motions to Compel via NYSCEF is Tuesday, January 31, 2023, at 10:00am;
2. The date by which Plaintiffs must submit and serve their combined reply in further
support of their Motions to Compel via NYSCEF is Tuesday, February 14, 2023,
at 10:00am;
3. The return date of the Motions to Compel is Friday, February 17, 2023, at
2:30pm; and
Motion for Leave to Amend the First Amended Complaint (motion sequence no. 48) (filed
by Plaintiff Zeynep Tekiner dated January 9, 2023) (the “Motion for Leave to Amend”):
4. The date by which Defendants must submit and serve their opposition to the Motion
for Leave to Amend via NYSCEF is Tuesday, January 31, 2023, at 10:00am;
5. The date by which Plaintiff Zeynep Tekiner must submit and serve her reply papers
in further support of the Motion for Leave to Amend via NYSCEF is Tuesday,
February 14, 2023, at 10:00am; and
6. The return date of the Motion for Leave to Amend is Friday, February 17, 2023,
at 2:30pm.
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FILED: NEW YORK COUNTY CLERK 01/27/2023 01:36 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1120 RECEIVED NYSCEF: 01/27/2023
7. This Stipulation may be signed in counterparts, which, when fully executed, shall
constitute a single original, and electronic signatures shall be deemed original
signatures.
Dated: January 27, 2023 Dated: January 27, 2023
/s/ Benjamin Weissman /s/ Bryan T. Mohler
Benjamin Weissman Bryan T. Mohler
FOLEY HOAG LLP PRYOR CASHMAN LLP
1301 Avenue of the Americas 7 Times Square |
25th Floor New York, New York 10036
New York, NY 10019 (212) 326-0466 |
(212) 812-0400 bmohler@pryorcashman.com
bweissman@foleyhoag.com
Attorneys for Defendants
Attorneys for Plaintiff Yasemin Tekiner
Dated: January 27, 2023
/s/ Michele Kahn
Michele Kahn
Kahn & Goldberg, LLP
555 Fifth Avenue, 14th Floor
New York, NY 10017
Tel. (212) 687-5066
mk@kahngoldberg.com
Attorney for Plaintiff Zeynep Tekiner
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Preview
FILED: NEW YORK COUNTY CLERK 01/27/2023 01:36 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1120 RECEIVED NYSCEF: 01/27/2023 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, J.S.C. Plaintiff, Motion Seq. Nos.: -against- 44, 45, 47, 48 BREMEN HOUSE INC., GERMAN NEWS STIPULATION COMPANY, INC., BERRIN TEKINER, GONCA GOVERNING BRIEFING TEKINER, and BILLUR AKIPEK, in her capacity SCHEDULES AND WORD as a Trustee of The Yasemin Tekiner 2011 LIMITS FOR PENDING Descendants Trust, MOTIONS 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. IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiffs, Yasemin Tekiner and Zeynep Tekiner (“Plaintiffs”), and Defendants, Bremen House, Inc., German News 1 of 3 FILED: NEW YORK COUNTY CLERK 01/27/2023 01:36 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1120 RECEIVED NYSCEF: 01/27/2023 Company, Inc., Berrin Tekiner, Gonca Tekiner, and Billur Akipek (“Defendants”) (each individually a “Party” and collectively the “Parties”), through their undersigned counsel, hereby jointly agree to the following motion submission schedule: Plaintiffs’ Motions to Compel (motion sequence nos. 44, 45 and 47) (the “Motions to Compel”): 1. The date by which Defendants must submit and serve their combined opposition to the Motions to Compel via NYSCEF is Tuesday, January 31, 2023, at 10:00am; 2. The date by which Plaintiffs must submit and serve their combined reply in further support of their Motions to Compel via NYSCEF is Tuesday, February 14, 2023, at 10:00am; 3. The return date of the Motions to Compel is Friday, February 17, 2023, at 2:30pm; and Motion for Leave to Amend the First Amended Complaint (motion sequence no. 48) (filed by Plaintiff Zeynep Tekiner dated January 9, 2023) (the “Motion for Leave to Amend”): 4. The date by which Defendants must submit and serve their opposition to the Motion for Leave to Amend via NYSCEF is Tuesday, January 31, 2023, at 10:00am; 5. The date by which Plaintiff Zeynep Tekiner must submit and serve her reply papers in further support of the Motion for Leave to Amend via NYSCEF is Tuesday, February 14, 2023, at 10:00am; and 6. The return date of the Motion for Leave to Amend is Friday, February 17, 2023, at 2:30pm. 2 2 of 3 FILED: NEW YORK COUNTY CLERK 01/27/2023 01:36 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1120 RECEIVED NYSCEF: 01/27/2023 7. This Stipulation may be signed in counterparts, which, when fully executed, shall constitute a single original, and electronic signatures shall be deemed original signatures. Dated: January 27, 2023 Dated: January 27, 2023 /s/ Benjamin Weissman /s/ Bryan T. Mohler Benjamin Weissman Bryan T. Mohler FOLEY HOAG LLP PRYOR CASHMAN LLP 1301 Avenue of the Americas 7 Times Square | 25th Floor New York, New York 10036 New York, NY 10019 (212) 326-0466 | (212) 812-0400 bmohler@pryorcashman.com bweissman@foleyhoag.com Attorneys for Defendants Attorneys for Plaintiff Yasemin Tekiner Dated: January 27, 2023 /s/ Michele Kahn Michele Kahn Kahn & Goldberg, LLP 555 Fifth Avenue, 14th Floor New York, NY 10017 Tel. (212) 687-5066 mk@kahngoldberg.com Attorney for Plaintiff Zeynep Tekiner 3 3 of 3