Stipulation,Agreement: 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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                                (FILED: NEW YORK COUNTY CLERK 0173172023 04:42 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1216 RECEIVED NYSCEF: 01/31/2023

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 a holder of equitable
interests in a shareholder or a member of the

Index No.: 657193/2020

Company Defendants, | Commercial Division Part 3
Plaintiff, | Hon. Joel M. Cohen, J.S.C.
~ against -
STIPULATION AND ORDER

BREMEN HOUSE INC., GERMAN NEWS COMPANY, | GOVERNING BRIEFING SCHEDULE

INC., BERRIN TEKINER, GONCA TEKINER, and | FOR PLAINTIFFS’ MOTION

BILLUR AKIPEK, in her capacity as a Trustee of The TO VACATE NOTES OF ISSUE

Yasemin Tekiner 2011 Descendants Trust, (MOTION SEQUENCE NO. 46)
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 Company, Inc., Berrin Tekiner, Gonca Tekiner, and Billur Akipek

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NYSCEF DOC. NO. 1216 RECEIVED NYSCEF: 01/31/2023

(“Defendants”), through their undersigned counsel, who hereby jointly agree to the following
motion submission schedule for Motion Sequence No. 46 (Plaintiffs’ Motion to Vacate Notes of
Tssue):

1. Defendants shall submit and serve their opposition to Plaintiffs’ Motion to Vacate
Notes of Issue on February 2, 2023.

2. Plaintiffs’ shall submit and serve their reply in further support of their Motion to
Vacate Notes of Issue on February 14, 2023 by 10 am.

3. This Stipulation may be executed in counterparts and when taken together shall
constitute one original document, and any signatures transmitted via facsimile or other electronic

means may be deemed an original.

Dated: January 30, 2023

KAHN & GOLDBERG, LLP PRYOR CASHMAN LLP

s/Michele Kahn s/Bryan Mohler

Michele Kahn Bryan Mohler

555 Fifth Avenue — 14 Floor 7 Times Square

New York, New York 10017 New York, NY 10036-6569

212-687-5066 212) 326-0466 |

mk@kahngoldberg.com bmohle: orcashman.c

Attorneys for Plaintiff Zeynep Tekiner Attorneys for Defendants
FOLEY HOAG LLP

s/Benjamin Weissman

Benjamin Weissman

1301 Avenue of the Americas SO ORDERED:
New York, New York 10019

(212) 812-0365

spyounger@foleyhoag.com CO
Attorneys for Plaintiff Yasemin Tekiner  fal faoaa

stip brief schedule m-vacate notes issue

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