Preview
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
YASEMIN TEKINER, in her individual capacity, Index No. 657193/2020
as a beneficiary and a Trustee of The Yasemin
Tekiner 2011 Descendants Trust and derivatively Commercial Division Part 3
as a holder of equitable interests in a shareholder
or a member of the Company Defendants, Hon. Joel M. Cohen
Plaintiff, STIPULATION AND ORDER
FOR SEALING DOCUMENTS
-against- RELATING TO MENTAL HEALTH
AND SENSITIVE AND
BREMEN HOUSE INC., GERMAN NEWS CONFIDENTIAL BUSINESS
COMPANY, INC., BERRIN TEKINER, INFORMATION
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 Zeynep Tekiner
2011 Descendants Trust.
Defendants.
WHEREAS, on March 29, 2023, the Court granted Plaintiff Yasemin Tekiner’s motion to
seal the document filed at Dkt. 978 pursuant to Motion Sequence No. 43, and further ordered that,
1
as it relates to “future submissions, made by any party, that contain subject matter that the Court
has authorized to be sealed by this Order, parties may file a joint stipulation, to be So Ordered,
which will authorize the filing of such future submissions to be filed in redacted form on NYSCEF,
provided that an unredacted copy of any redacted document is contemporaneously filed under seal”
(Dkt. 1489);
WHEREAS, on March 27, 2023, Defendants filed under seal at Dkt. 1464, a document
containing the same subject matter as Dkt. 978, i.e. sensitive and confidential business information,
including bank records, which the Court authorized to be sealed in its order filed at Dkt. 1489;
WHEREAS, on March 29, 2023, in an order filed at Dkt. 1493, the Court granted in part
Defendants’ motion to seal certain documents pursuant to Motion Sequence No. 49 and further
ordered Defendants to refile redacted versions of, inter alia, Dkts. 1141 (deposition transcript of
Zeynep Tekiner) and 1199 (Oct. 12, 2022 deposition transcript of Gonca Chelsea) with the
Defendants’ medical information appropriately redacted within ten (10) days, and further ordered
that as it relates to “future submissions, made by any party, that contain subject matter that the
Court has authorized to be sealed by this Order, parties may file a joint stipulation, to be So
Ordered, which will authorize the filing of such future submissions to be filed in redacted form on
NYSCEF, provided that an unredacted copy of any redacted document is contemporaneously filed
under seal”(Dkt. 1493);
WHEREAS, on March 27, 2023, Defendants filed under seal at Dkt. 1483 a document
identical to the document filed at Dkt. 1141, and at Dkt. 1479 a document identical to the document
filed at Dkt. 1199;
2
WHEREAS, pursuant to the Court’s order filed at Dkt. 1493, Defendants shall refile the
documents filed at Dkts. 1141 and 1199 with the appropriate redactions on or before April 10,
2023;
WHEREAS, on March 27, 2023, Defendants filed under seal at Dkts. 1480 (Oct. 14, 2022
deposition transcript of Berrin Tekiner), 1481 (Mar. 14, 2023 deposition transcript of Billur
Akipek) and 1482 (deposition transcript of Yasemin Tekiner) documents that contain subject
matter that the Court has authorized to be sealed by its order filed at Dkt. 1493, i.e. that contain
Defendants’ medical information;
NOW, THEREFORE, based upon the foregoing, the parties stipulate as follows:
1. The document filed at Dkt. 1464 shall remain under seal, pursuant to the Court’s
order at Dkt. 1489.
2. Defendants shall refile Dkts. 1479 and 1492, in compliance with the Court’s
direction in its order filed at Dkt. 1493, as that order related to Dkts. 1141 and 1199, on or before
April 10, 2023.
3. If the Court so-orders this stipulation, Defendants shall refile Dkts. 1480, 1481, and
1482 with Defendants’ medical information appropriately redacted, within ten (10) days of its
entry.
3
4. This Stipulation shall be deemed to be mutually drafted so that no negative
inference shall arise against either side.
Dated: New York, New York
April 3, 2023
KAHN & GOLDBERG, LLP PRYOR CASHMAN LLP
/s/ Michele Kahn /s/ Bryan Mohler
Michele Kahn Todd E. Soloway
555 Fifth Avenue, 14th Floor Bryan Mohler
New York, New York 10017 Meghan E. Hill
212-687-5066 7 Times Square
mk@khangoldberg.com New York, New York 10036-6569
Attorneys for Plaintiff Zeynep Tekiner 212-326-0466
tsoloway@pryorcashman.com
bmohler@pryorcashman.com
mhill@pryorcashman.com
Attorneys for Defendants
FOLEY HOAG LLP
/s/ Benjamin Weissman
Benjamin Weissman
1301 Avenue of the Americas
New York, New York 10019
212-812-0365
bweissman@foleyhoag.com
Attorneys for Plaintiff Yasemin Tekiner
SO ORDERED
____________________
J.S.C.
4
Preview
SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK YASEMIN TEKINER, in her individual capacity, Index No. 657193/2020 as a beneficiary and a Trustee of The Yasemin Tekiner 2011 Descendants Trust and derivatively Commercial Division Part 3 as a holder of equitable interests in a shareholder or a member of the Company Defendants, Hon. Joel M. Cohen Plaintiff, STIPULATION AND ORDER FOR SEALING DOCUMENTS -against- RELATING TO MENTAL HEALTH AND SENSITIVE AND BREMEN HOUSE INC., GERMAN NEWS CONFIDENTIAL BUSINESS COMPANY, INC., BERRIN TEKINER, INFORMATION 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 Zeynep Tekiner 2011 Descendants Trust. Defendants. WHEREAS, on March 29, 2023, the Court granted Plaintiff Yasemin Tekiner’s motion to seal the document filed at Dkt. 978 pursuant to Motion Sequence No. 43, and further ordered that, 1 as it relates to “future submissions, made by any party, that contain subject matter that the Court has authorized to be sealed by this Order, parties may file a joint stipulation, to be So Ordered, which will authorize the filing of such future submissions to be filed in redacted form on NYSCEF, provided that an unredacted copy of any redacted document is contemporaneously filed under seal” (Dkt. 1489); WHEREAS, on March 27, 2023, Defendants filed under seal at Dkt. 1464, a document containing the same subject matter as Dkt. 978, i.e. sensitive and confidential business information, including bank records, which the Court authorized to be sealed in its order filed at Dkt. 1489; WHEREAS, on March 29, 2023, in an order filed at Dkt. 1493, the Court granted in part Defendants’ motion to seal certain documents pursuant to Motion Sequence No. 49 and further ordered Defendants to refile redacted versions of, inter alia, Dkts. 1141 (deposition transcript of Zeynep Tekiner) and 1199 (Oct. 12, 2022 deposition transcript of Gonca Chelsea) with the Defendants’ medical information appropriately redacted within ten (10) days, and further ordered that as it relates to “future submissions, made by any party, that contain subject matter that the Court has authorized to be sealed by this Order, parties may file a joint stipulation, to be So Ordered, which will authorize the filing of such future submissions to be filed in redacted form on NYSCEF, provided that an unredacted copy of any redacted document is contemporaneously filed under seal”(Dkt. 1493); WHEREAS, on March 27, 2023, Defendants filed under seal at Dkt. 1483 a document identical to the document filed at Dkt. 1141, and at Dkt. 1479 a document identical to the document filed at Dkt. 1199; 2 WHEREAS, pursuant to the Court’s order filed at Dkt. 1493, Defendants shall refile the documents filed at Dkts. 1141 and 1199 with the appropriate redactions on or before April 10, 2023; WHEREAS, on March 27, 2023, Defendants filed under seal at Dkts. 1480 (Oct. 14, 2022 deposition transcript of Berrin Tekiner), 1481 (Mar. 14, 2023 deposition transcript of Billur Akipek) and 1482 (deposition transcript of Yasemin Tekiner) documents that contain subject matter that the Court has authorized to be sealed by its order filed at Dkt. 1493, i.e. that contain Defendants’ medical information; NOW, THEREFORE, based upon the foregoing, the parties stipulate as follows: 1. The document filed at Dkt. 1464 shall remain under seal, pursuant to the Court’s order at Dkt. 1489. 2. Defendants shall refile Dkts. 1479 and 1492, in compliance with the Court’s direction in its order filed at Dkt. 1493, as that order related to Dkts. 1141 and 1199, on or before April 10, 2023. 3. If the Court so-orders this stipulation, Defendants shall refile Dkts. 1480, 1481, and 1482 with Defendants’ medical information appropriately redacted, within ten (10) days of its entry. 3 4. This Stipulation shall be deemed to be mutually drafted so that no negative inference shall arise against either side. Dated: New York, New York April 3, 2023 KAHN & GOLDBERG, LLP PRYOR CASHMAN LLP /s/ Michele Kahn /s/ Bryan Mohler Michele Kahn Todd E. Soloway 555 Fifth Avenue, 14th Floor Bryan Mohler New York, New York 10017 Meghan E. Hill 212-687-5066 7 Times Square mk@khangoldberg.com New York, New York 10036-6569 Attorneys for Plaintiff Zeynep Tekiner 212-326-0466 tsoloway@pryorcashman.com bmohler@pryorcashman.com mhill@pryorcashman.com Attorneys for Defendants FOLEY HOAG LLP /s/ Benjamin Weissman Benjamin Weissman 1301 Avenue of the Americas New York, New York 10019 212-812-0365 bweissman@foleyhoag.com Attorneys for Plaintiff Yasemin Tekiner SO ORDERED ____________________ J.S.C. 4