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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                                FILED: NEW YORK COUNTY CLERK 03/03/2023 01:47 PM                                                          INDEX NO. 657193/2020
NYSCEF DOC. NO. 1363                                                                              RECEIVED NYSCEF: 03/03/2023




          SUPREME COURT OF THE STATE OF NEW YORK
          COUNTY OF NEW YORK
           ---------------------------------------------------------------------   X
           YASEMIN TEKINER,                                                            Index No.: 657193/2020

           in her individual capacity, as a beneficiary and a Trustee of               Hon. Joel M. Cohen, J.S.C. (Part 3)
           The Yasemin Tekiner 2011 Descendants Trust and
           derivatively as a holder of equitable interests in a                        Motion Seq. No. ___
           shareholder or a member of the Company Defendants,
                                                                                       AFFIRMATION OF SCOTT W.
                                                Plaintiff,                             PARKER IN SUPPORT OF
                                                                                       PARKER IBRAHIM & BERG
                              - against -                                              LLP’S MOTION, BY ORDER TO
                                                                                       SHOW CAUSE, WHY IT
           BREMEN HOUSE INC., GERMAN NEWS COMPANY,                                     SHOULD NOT BE PERMITTED
           INC., BERRIN TEKINER, GONCA TEKINER, and                                    TO FILE ITS REDACTED
           BILLUR AKIPEK, in her capacity as a Trustee of The                          MOTION TO WITHDRAW AS
           Yasemin Tekiner 2011 Descendants Trust,                                     CO-COUNSEL OF RECORD FOR
                                                                                       PLAINTIFF YASEMIN TEKINER
                                                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

                  SCOTT W. PARKER, an attorney duly admitted to practice law in the Courts of the State

          of New York, hereby affirms the following under the penalties of perjury pursuant to CPLR 2106:




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FILED: NEW YORK COUNTY CLERK 03/03/2023 01:47 PM                                                INDEX NO. 657193/2020
NYSCEF DOC. NO. 1363                                                                   RECEIVED NYSCEF: 03/03/2023




                 1.      I am a partner of Parker Ibrahim & Berg LLP (“PIB”), co-counsel for Plaintiff

          Yasemin Tekiner (“Yasemin”), and am fully familiar with the matters set forth herein, having

          represented Yasemin in the course of the litigation.

                 2.      In accordance with this Court’s Notice dated and e-filed March 2, 2023 (NYSCEF

          Doc. No. 1358), I respectfully submit this Affirmation in support of PIB’s emergency motion, by

          Order to Show Cause, to (i) permit PIB to file its motion to withdraw as co-counsel of record to

          Yasemin on NYSCEF and to redact from such motion any and all privileged and confidential

          information; (ii) permit PIB to submit confidentially to the Chambers of the Honorable Joel M.

          Cohen and to serve via email on Yasemin’s co-counsel and Plaintiff Zeynep Tekiner’s counsel an

          unredacted hard copy of such motion, with any responses or reply to the withdrawal motion to be

          filed in the same manner; and (iii) fix as the PIB withdrawal motion briefing schedule the same

          agreed-upon briefing schedule as provided in PIB counsel’s February 27, 2023 letter to this Court

          (motion responses on March 22, motion reply on March 29, and motion return date on March 30).

                 3.      As noted in PIB’s February 13 withdrawal motion, Yasemin has stopped paying

          PIB’s invoices for services rendered and PIB has advised Yasemin that it would have no alternative

          but to seek withdrawal as her co-counsel if its outstanding invoices were not paid.

                 4.      Moreover, PIB’s relationship with Yasemin has been materially affected as a result

          of her retention of independent counsel, Anthony J. Harwood.

                 5.      In order for the Court to have a full picture of the circumstances leading to PIB’s

          request to withdraw as Yasemin’s counsel, certain relevant, confidential, and privileged facts

          (some of which were mentioned, outside of the presence of Defendants’ counsel, at the February

          17 Chambers conference I attended) must be confidentially disclosed to this Court but should not

          be revealed to Defendants’ counsel since such disclosure could prejudice Yasemin.




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FILED: NEW YORK COUNTY CLERK 03/03/2023 01:47 PM                                      INDEX NO. 657193/2020
NYSCEF DOC. NO. 1363                                                           RECEIVED NYSCEF: 03/03/2023




               WHEREFORE.PIB respectfully requests that the Couil grant this Motion in all respects.

         Dated: New York. New York
                March _3_- 2023



                                                  SCOTT W.PARKER




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FILED: NEW YORK COUNTY CLERK 03/03/2023 01:47 PM                                              INDEX NO. 657193/2020
NYSCEF DOC. NO. 1363                                                                RECEIVED NYSCEF: 03/03/2023




                                        CERTIFICATION OF COUNSEL

                   This Affirmation was prepared on a computer using Microsoft Word. Pursuant to the word

          count system in Microsoft Word, the total number of words in this Affirmation, excluding the

          caption and signature block, is 376 words.

          Dated:    New York, New York
                    March 3, 2023


                                                                     /s/ Scott W. Parker___
                                                                     SCOTT W. PARKER




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