On December 21, 2020 a
Exhibit,Appendix
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 04/03/2023 06:24 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1507 RECEIVED NYSCEF: 04/03/2023
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, Mot. Seq. No. __
-against- SEALING CHART
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 Zeynep Tekiner
2011 Descendants Trust.
Defendants.
1
FILED: NEW YORK COUNTY CLERK 04/03/2023 06:24 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1507 RECEIVED NYSCEF: 04/03/2023
EXHIBIT A – SEALING CHART
Document NYSCEF Redaction Basis
Number
Ex. 2 - 2020 W- 1458 Entire Contains information that has been designated as
2 and Earnings Document confidential information in the case as
Summary containing trade secrets, proprietary business
information, competitively sensitive information
or other information the disclosure of which
would be detrimental to the conduct of
Defendants’ business
Ex. 3 - Offer 1459 Entire Contains information that has been designated as
Matrix Document confidential information in the case as
containing trade secrets, proprietary business
information, competitively sensitive information
or other information the disclosure of which
would be detrimental to the conduct of
Defendants’ business
Ex. 4 - Sep. 3, 1460 Entire Contains information that has been designated as
2020 Written Document confidential information in the case as
Consent of containing trade secrets, proprietary business
Bremen House information, competitively sensitive information
Inc. or other information the disclosure of which
would be detrimental to the conduct of
Defendants’ business
Affidavit of 1462 Partial Contains information subject to the attorney–
Billur Akipek in Redaction client privilege
Opposition
Ex. 6 - Balance 1463 Entire Contains information that has been designated as
Sheet of Document confidential information in the case as
German News containing trade secrets, proprietary business
Inc. dated information, competitively sensitive information
December 31, or other information the disclosure of which
2021 would be detrimental to the conduct of
Defendants’ business
Ex. 8 - Nov. 13, 1465 Entire Contains information that has been designated as
2019 Email Document confidential information in the case as
From B. Akipek containing trade secrets, proprietary business
information, competitively sensitive information
or other information the disclosure of which
would be detrimental to the conduct of
Defendants’ business
Ex. 10 - Chart 1467 Entire Contains information that has been designated as
Showing Document confidential information in the case as
Combined containing trade secrets, proprietary business
information, competitively sensitive information
2
FILED: NEW YORK COUNTY CLERK 04/03/2023 06:24 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1507 RECEIVED NYSCEF: 04/03/2023
Value of Post- or other information the disclosure of which
Extell Purchases would be detrimental to the conduct of
Defendants’ business
Affirmation of 1468 Entire Contains information that has been designated as
Lawrence Document confidential information in the case as
Shepps in containing trade secrets, proprietary business
Opposition information, competitively sensitive information
or other information the disclosure of which
would be detrimental to the conduct of
Defendants’ business; in addition, contains
information subject to the attorney client
privilege
Ex. 11 - Oct. 12, 1469 Entire Contains information that has been designated as
2022 Email Document confidential information in the case as
from G. Chelsea containing trade secrets, proprietary business
information, competitively sensitive information
or other information the disclosure of which
would be detrimental to the conduct of
Defendants’ business; in addition, contains
information subject to the attorney–client
privilege
Ex. 12 - Oct. 12, 1470 Entire Contains information that has been designated as
2022 Email Document confidential information in the case as
from L. Shepps containing trade secrets, proprietary business
information, competitively sensitive information
or other information the disclosure of which
would be detrimental to the conduct of
Defendants’ business; in addition, contains
information subject to the attorney–client
privilege
Ex. 13 - Oct. 12, 1471 Entire Contains information that has been designated as
2022 Email Document confidential information in the case as
from L. Shepps containing trade secrets, proprietary business
information, competitively sensitive information
or other information the disclosure of which
would be detrimental to the conduct of
Defendants’ business; in addition, contains
information subject to the attorney–client
privilege
Ex. 25 - Feb. 16, 1484 Entire Contains information that has been designated as
2023 Deposition Document confidential information in the case as
Transcript of containing trade secrets, proprietary business
John Stewart information, competitively sensitive information
or other information the disclosure of which
would be detrimental to the conduct of
Defendants’ business
3
FILED: NEW YORK COUNTY CLERK 04/03/2023 06:24 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1507 RECEIVED NYSCEF: 04/03/2023
Ex. 27 - Bremen 1486 Entire Contains information that has been designated as
House Annual Document confidential information in the case as
Financial containing trade secrets, proprietary business
Statements, information, competitively sensitive information
2017 or other information the disclosure of which
would be detrimental to the conduct of
Defendants’ business
4
Preview
FILED: NEW YORK COUNTY CLERK 04/03/2023 06:24 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1507 RECEIVED NYSCEF: 04/03/2023 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, Mot. Seq. No. __ -against- SEALING CHART 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 Zeynep Tekiner 2011 Descendants Trust. Defendants. 1 FILED: NEW YORK COUNTY CLERK 04/03/2023 06:24 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1507 RECEIVED NYSCEF: 04/03/2023 EXHIBIT A – SEALING CHART Document NYSCEF Redaction Basis Number Ex. 2 - 2020 W- 1458 Entire Contains information that has been designated as 2 and Earnings Document confidential information in the case as Summary containing trade secrets, proprietary business information, competitively sensitive information or other information the disclosure of which would be detrimental to the conduct of Defendants’ business Ex. 3 - Offer 1459 Entire Contains information that has been designated as Matrix Document confidential information in the case as containing trade secrets, proprietary business information, competitively sensitive information or other information the disclosure of which would be detrimental to the conduct of Defendants’ business Ex. 4 - Sep. 3, 1460 Entire Contains information that has been designated as 2020 Written Document confidential information in the case as Consent of containing trade secrets, proprietary business Bremen House information, competitively sensitive information Inc. or other information the disclosure of which would be detrimental to the conduct of Defendants’ business Affidavit of 1462 Partial Contains information subject to the attorney– Billur Akipek in Redaction client privilege Opposition Ex. 6 - Balance 1463 Entire Contains information that has been designated as Sheet of Document confidential information in the case as German News containing trade secrets, proprietary business Inc. dated information, competitively sensitive information December 31, or other information the disclosure of which 2021 would be detrimental to the conduct of Defendants’ business Ex. 8 - Nov. 13, 1465 Entire Contains information that has been designated as 2019 Email Document confidential information in the case as From B. Akipek containing trade secrets, proprietary business information, competitively sensitive information or other information the disclosure of which would be detrimental to the conduct of Defendants’ business Ex. 10 - Chart 1467 Entire Contains information that has been designated as Showing Document confidential information in the case as Combined containing trade secrets, proprietary business information, competitively sensitive information 2 FILED: NEW YORK COUNTY CLERK 04/03/2023 06:24 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1507 RECEIVED NYSCEF: 04/03/2023 Value of Post- or other information the disclosure of which Extell Purchases would be detrimental to the conduct of Defendants’ business Affirmation of 1468 Entire Contains information that has been designated as Lawrence Document confidential information in the case as Shepps in containing trade secrets, proprietary business Opposition information, competitively sensitive information or other information the disclosure of which would be detrimental to the conduct of Defendants’ business; in addition, contains information subject to the attorney client privilege Ex. 11 - Oct. 12, 1469 Entire Contains information that has been designated as 2022 Email Document confidential information in the case as from G. Chelsea containing trade secrets, proprietary business information, competitively sensitive information or other information the disclosure of which would be detrimental to the conduct of Defendants’ business; in addition, contains information subject to the attorney–client privilege Ex. 12 - Oct. 12, 1470 Entire Contains information that has been designated as 2022 Email Document confidential information in the case as from L. Shepps containing trade secrets, proprietary business information, competitively sensitive information or other information the disclosure of which would be detrimental to the conduct of Defendants’ business; in addition, contains information subject to the attorney–client privilege Ex. 13 - Oct. 12, 1471 Entire Contains information that has been designated as 2022 Email Document confidential information in the case as from L. Shepps containing trade secrets, proprietary business information, competitively sensitive information or other information the disclosure of which would be detrimental to the conduct of Defendants’ business; in addition, contains information subject to the attorney–client privilege Ex. 25 - Feb. 16, 1484 Entire Contains information that has been designated as 2023 Deposition Document confidential information in the case as Transcript of containing trade secrets, proprietary business John Stewart information, competitively sensitive information or other information the disclosure of which would be detrimental to the conduct of Defendants’ business 3 FILED: NEW YORK COUNTY CLERK 04/03/2023 06:24 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1507 RECEIVED NYSCEF: 04/03/2023 Ex. 27 - Bremen 1486 Entire Contains information that has been designated as House Annual Document confidential information in the case as Financial containing trade secrets, proprietary business Statements, information, competitively sensitive information 2017 or other information the disclosure of which would be detrimental to the conduct of Defendants’ business 4