Motion,Ex Parte: 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 05/19/2023 12:03 AM                                             INDEX NO. 657193/2020
NYSCEF DOC. NO. 1636                                                                 RECEIVED NYSCEF: 05/19/2023




          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     Index No. 657193/2020
                  of equitable interests in a shareholder or a
                  member of the Company Defendants,                  Commercial Division Part 3

                                                          Plaintiff, Hon. Joel M. Cohen

                                  -against-                          Motion Seq. No. 63

           BREMEN HOUSE INC., GERMAN NEWS
           COMPANY, INC., BERRIN TEKINER, GONCA
           TEKINER, and BILLUR AKIPEK, in her capacity as            EMERGENCY AFFIRMATION OF
           a Trustee of The Yasemin Tekiner 2011 Descendants             SCOTT W. PARKER
           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 Yasemin Tekiner 2011 Descendants
           Trust,

                                                  Defendants.

                 SCOTT W. PARKER, Esq., an attorney duly admitted to practice before the Courts of

          the State of New York, affirms under the penalty of perjury, pursuant to CPLR § 2106:




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FILED: NEW YORK COUNTY CLERK 05/19/2023 12:03 AM                                                 INDEX NO. 657193/2020
NYSCEF DOC. NO. 1636                                                                     RECEIVED NYSCEF: 05/19/2023




                  1.      I am a partner of the law firm Parker Ibrahim & Berg LLP, co-counsel for plaintiff

          Yasemin Tekiner (“Yasemin”) in the above-captioned matter. I submit this affirmation in support

          of co-plaintiffs Yasemin’s and Zeynep Tekiner’s (“Zeynep”) Order to Show Cause (“OTSC”) for

          Leave to Renew Application for a Preliminary Injunction with Temporary Restraining Order to

          Enjoin Defendants’ Threatened Sale of Plaintiffs’ Homes and Their Eviction Therefrom.

                  2.      I am fully familiar with the facts and circumstances of this action, as set forth

          herein, by virtue of my personal involvement as counsel and a review of the case files.

                  3.      This request for an order to show cause is made on an emergency basis because of

          Defendants’ threat to imminently sell Plaintiffs’ homes and evict them, despite Defendants’ prior

          representations to the Court and Plaintiffs to the contrary. Such actions would have irreversible

          consequences and would cause Plaintiffs irreparable harm.

                  4.      No prior application for this relief has been sought in this or any other Court.

                  WHEREFORE, Yasemin and Zeynep respectfully request that this application to, inter

          alia: (i) enjoin Defendants from marketing or selling the Yasemin Residence1 and Zeynep

          Residence during the pendency of this case, (ii) enjoin Defendants from taking any action to

          remove or evict Yasemin or Zeynep from the Yasemin Residence or Zeynep Residence, or in any

          way deprive Yasemin or Zeynep of their right to reside in the Yasemin Residence and Zeynep

          Residence, during the pendency of this case, and (iii) grant Yasemin and Zeynep such other and

          further relief as is just, proper and equitable.




          1
            Capitalized terms used but not otherwise defined herein shall have the meanings ascribed to
          them in Plaintiffs’ accompanying Memorandum of Law in support of OTSC.


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FILED: NEW YORK COUNTY CLERK 05/19/2023 12:03 AM                       INDEX NO. 657193/2020
NYSCEF DOC. NO. 1636                                             RECEIVED NYSCEF: 05/19/2023




          Dated: New York, New York
                 May 18, 2023




                                               Scott W. Parker




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FILED: NEW YORK COUNTY CLERK 05/19/2023 12:03 AM                                             INDEX NO. 657193/2020
NYSCEF DOC. NO. 1636                                                                   RECEIVED NYSCEF: 05/19/2023




                  CERTIFICATION PURSUANT TO COMMERCIAL DIVISION RULE 17

                 I hereby certify that the foregoing Emergency Affirmation complies with Rule 17 of

          subdivision (g) of section 202.70 of the Uniform Rules for the Supreme Court and County Court

          (Rules of Practice for the Commercial Division of the Supreme Court), and has a word of less than

          7,000 words.



          Dated: New York, New York
                 May 18, 2023




                                                                     Scott W. Parker




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