Preview
FILED: NEW YORK COUNTY CLERK 01/04/2021 11:01 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 01/04/2021
SUPREME COURT OF THE STATE OF NEW YORK
COMMERCIAL DIVISION, NEW YORK COUNTY
-------------------------------------- x
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, :
:
Plaintiff, :
: Index No. 657193/20
- against – :
:
BREMEN HOUSE INC., BREMEN HOUSE TEXAS, :
INC., GERMAN NEWS COMPANY, INC., GERMAN :
NEWS TEXAS, INC., 254 - 258 W. 35TH ST. LLC, :
BERRIN TEKINER, GONCA TEKINER, and :
BILLUR AKIPEK, in her capacity as a Trustee of :
The Yasemin Tekiner 2011 Descendants Trust, :
:
Defendants. :
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AFFIDAVIT OF YASEMIN TEKINER
STATE OF CALIFORNIA )
:
COUNTY OF LOS ANGELES )
YASEMIN TEKINER, being duly sworn, deposes and says:
1. I am the plaintiff in this action. Since its inception, I have been a beneficiary and
also a Trustee of The Yasemin Tekiner 2011 Descendants Trust (the “Trust”) (except for one
period of time when I was previously removed as Trustee of the Trust). The Trust holds major
interests in the Company Defendants named in this action, directly and indirectly, for the benefit
of me and my descendants. I am also a director or officer of certain of the Company Defendants,
as they are defined below.
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2. I make this affidavit in support of my emergency application for an order to show
cause for a preliminary injunction with temporary restraining order to enjoin and restrain
Defendants from taking further acts of retaliation against me, and to enjoin and restrain the
Individual Defendants, as they are defined below, from using any funds or other assets of the
Company Defendants to defend this action. I have personal knowledge of the matters set forth
herein.
3. Defendants, Bremen House, Inc. (“Bremen House”), Bremen House Texas, Inc.,
German News Company, Inc. (German News”), German News Texas, Inc., and 254 – 258 W.
35th St. LLC (collectively the “Company Defendants” or “Companies”) own valuable New York
and Texas real estate. These companies own properties that were assembled by my father, Sami
Tekiner (“Sami”), over a 70-year period during his lifetime working in the real estate business.
4. Following Sami’s death, my mother, Defendant Berrin Tekiner (“Berrin”) took
over the formal management of the Companies and their properties, although she had been
running them already as my father suffered from Alzheimer’s disease. In the early 2000s, my
sister, Defendant Gonca Tekiner (“Gonca”), began working at the Companies. Neither my
mother nor my sister have any formal training in real estate management or investment and they
both suffer from personal health issues which has made their conduct erratic.
5. I have been concerned for several years that the Companies have not been
managed properly and that Berrin and Gonca (collectively the “ Individual Defendants”) have
been using funds of the Companies as their own personal piggy bank. For example, in recent
years, the Company Defendants have experienced negative cash flow and have thus been losing
over $1 million per year. The Companies’ investment properties have substantial debt and large
expenses, which makes it difficult if not impossible for the Companies to turn a profit. Among
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the expenses paid for by the companies is a wide assortment of personal expenses for Berrin and
Gonca, including large phone bills, housekeeping and landscaping expenses for their homes and
even pet food.
6. From time to time, I have raised questions about these matters but have been left
uninformed by the management of the Companies and my questioning has frequently been met
with acts of personal retaliation taken against me. Notably, in 2017, in breach of her duties as
Chair of the Bremen House Board, Berrin removed me as both a director of Bremen House and
as a Trustee of my own Trust in response to my raising legitimate questions about the business
and finances of the Companies.
7. One of my concerns back in 2017 was that the Companies had taken out a $6
million blanket mortgage over the Companies’ properties in order to, among other things, buy a
home in Bronxville, New York for my sister, Gonca, to live in -- even though Gonca already
benefited from a multi-million dollar Manhattan apartment that the Companies had purchased for
her. Upon raising my concerns, I was immediately met with threats from my mother.
8. Berrin thereafter sent me a July 2017 email apologizing for her threats, saying that
she had “looked through all of the e mails and texts” on the issue and then acknowledging that
she had done “the most scary part … by threatening you cutting you off.” Berrin admitted that
“it was wrong. I thought you knew me better and ignore my empty threats. But it was WRONG
and SMALL of me.” She added that I was “right” when I said “let’s cool off, and do whatever
we can to make everyone feel secure and feel better.” Berrin concluded her email to me by
saying: “I am sorry and apologize for speaking so carelessly and unnecessarily.” Attached as
Exhibit A is a true and correct copy of this email.
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9. Despite this apology, in acts of utter retaliation, Berrin instructed me not to ask
questions of the Companies’ employees and ultimately removed me as a Director of Bremen
House and as a Trustee of the Yasemin Trust. Berrin has removed other trustees in the past who
questioned her actions.
10. It was only after I had patched up my relationship with my mother Berrin and
Berrin had become worried about the businesses’ growing financial difficulties, that she
reinstated me in these roles.
11. This was not my family’s only act of retaliation taken toward me that year. In
April 2017, I had objected to racist comments that Gonca made at a family dinner, which I and
my other sister, Zeynep Tekiner, found to be offensive. Shortly thereafter, Berrin texted me
saying that I was being evicted from a family-owned apartment in Manhattan. My other sister,
Zeynep, called this eviction “unnecessarily punitive.”
12. Additionally, Gonca was hired as Bremen House’s President and CEO at a highly
favorable salary of $480,000 (since raised further) plus bonus and expense reimbursements.
Unbeknownst to me, the company also signed an employment contract with Gonca which gave
her ten years of guaranteed severance should she leave the company in the future. The cost of
this excessive severance would effectively preclude the company from engaging professional
management should it choose to do so.
13. In late 2019 and early 2020, Gonca suffered a relapse of her personal health
problems. In the fits of these issues, Gonca tried to fire my mother from her roles with the
Company Defendants and kick her out of the companies’ offices, exclaiming to her: “You and
your gay family [a reference to me and my partner] don’t belong here.” Shortly after this
incident, Berrin announced that she wanted to fire Gonca from her positions with the Company
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Defendants. In reaction, Berrin stated in an email: Gonca “will be getting more than 20 million
dollars in addition to other benefits, to the detriment of the company and her sisters, while being
very mean and disrespectful of the whole family especially me, who gave her this trust.” Berrin
exclaimed that “the family is totally upset” with Gonca. Around this time, Berrin also told me
that Gonca had mismanaged the companies and faulted Gonca for their expenses being so high.
14. Berrin’s personal lawyers, who also serve as company counsel and are the same
lawyers who put Gonca’s sweetheart employment contract in place, were worried that firing her
could trigger the lucrative ten-year severance payments that this contract afforded her.
15. But Berrin pushed back, saying that leaving Gonca in her role as President “will
leave her with a lot of authority” and that her counsel’s recommended action was “just the
opposite of what I want to achieve.” Ultimately, Berrin did fire Gonca as President and CEO of
the company.
16. Gonca’s personal issues became so bad that she again checked into a facility.
Gonca begged my mother to reinstate her back into her company positions. Berrin eventually
did so despite my pointing out to her that Gonca’s circumstances satisfied one of the limited
grounds on which Bremen House could fire Gonca without paying her severance.
17. Moreover, at my recommendation, the Companies engaged a real estate adviser.
Berrin and Gonca objected to the scope of the adviser’s assignment and it was narrowed
considerably as a result. Nonetheless, the adviser prepared a proposed strategy for re-investment
of the Companies’ properties. However, Berrin terminated the adviser’s services shortly before
they were to present their strategic plan to us. Berrin and Gonca have chosen not to follow the
adviser’s advice.
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18. Bremen House and German News recently looked to sell some of their valuable
development properties in order to take steps toward returning to profitability. For example, the
company reached a deal to sell certain of its Manhattan properties to Extell Acquisitions LLC
(“Extell”), a major developer, in two tranches for a total sales price of $60 million. I understand
that this price was below the sales prices of recent transactions involving comparable properties
in the area.
19. I was asked to sign a consent to these transactions based on that $60 million price.
However, when she got to the signing, Berrin – without consulting me – agreed to drop the price
of one of these sales by $10 million. Even the company’s real estate lawyer recommended
against acceding to this request, absent receipt of some additional consideration from the buyer
in exchange for doing so. The lawyer called Extell’s conduct in lowering the price “disgusting”
and “underhanded.”
20. Upon learning of the Extell sales price reduction, I recently asked Bremen
House’s accountant and bookkeeper for access to certain books and records of the Companies so
that I could satisfy myself that the Company Defendants’ affairs were being run properly. This
request was overruled by Berrin, in her role as Chair of the company’s Board of Directors.
Attached as Exhibit B is a true and correct copy of an email from Bremen House’s accountant to
me on October 15, 2020.
21. The denial of this request left me no choice but to make a formal books and
records demand to ensure that my legal right to review company records was honored. As a
result, pursuant to my rights as a director of Bremen House and treasurer of German News, and
also as Trustee of a Trust holding substantial shares in the Companies for my benefit, on
November 11, 2020, through my counsel, I formally requested access to various corporate books
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and records for the time period January 1, 2017 to the present. Attached as Exhibit C is a true
and correct copy of this request. I understand that this request, too, has been denied.
22. In an additional act of retaliation, in mid-October 2020, after objection to the
Extell price drop, I was locked out of Bremen House’s email account in order to keep me from
accessing company communications. When I raised this, my access to the server was
temporarily restored but I was recently locked out of my account again.
23. On December 10, 2020, in retaliation for my efforts to inquire into and question
her management of the Companies, Berrin signed a document purporting to remove me as a
Trustee of my Trust. Berrin concealed the existence of this removal document until it recently
came to light in connection with a communication with the corporate trustee of my Trust. I
believe that Berrin’s acts in removing me as a Trustee of her Trust and concealing this action
constitute an abuse of trust and a breach of her multiple fiduciary duties.
24. I am also fearful that the Individual Defendants, given their past histories of
retaliation toward me and their pattern of erratic behavior, will take other retaliatory actions
against me unless they are restrained from doing so by this Court.
25. In the past Berrin removed me as a director and officer of the Companies when I
raised questions about company management. I fear that she will do so again in retaliation for
the issues I am raising in this lawsuit.
26. I also earn a salary for my work on behalf of the Companies. I live, pursuant to a
lease on which I make annual rental payments, in a house that is owned by Bremen House. That
house was purchased with the proceeds from the sale of an apartment in which I lived in New
York City.
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27. I am quite concerned that the Defendants will retaliate against me by taking
actions to hold back my income or deprive me of my property rights to my home, unless this
Court restrains them from taking such actions.
28. In addition, the Individual Defendants have an extensive history of using
company funds to pay their personal expenses, even paying Berrin’s personal driver and
housekeeper with company funds. I am fearful that, unless restrained from doing so by this
Court, the Individual Defendants will try to use company funds or assets to pay for their defense
of this lawsuit. Given that my complaint raises issues about their misuse of company funds and
assets, it would be improper to allow them to do so.
WHEREFORE, I respectfully request that this Court enter an order temporarily,
preliminarily and permanently restraining and enjoining the Defendants: 1. from taking any acts
to retaliate against me, including but not limited to terminating me as a director, officer or
employee of the Company Defendants, reducing my salary and bonus payable by the Company
Defendants or impairing my right to occupy my home; and 2. from using any funds or assets of
the Company Defendants to pay any of the Individual Defendants’ legal fees and expenses in
defending this action; and grant such other and further relief as may be just and proper.
Dated: December 31, 2020
_____________________________
Yasemin Tekiner
Sworn to before me this
__ day of ___________, 2020
________________________
Notary Public
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Preview
FILED: NEW YORK COUNTY CLERK 01/04/2021 11:01 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 01/04/2021 SUPREME COURT OF THE STATE OF NEW YORK COMMERCIAL DIVISION, NEW YORK COUNTY -------------------------------------- x 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, : : Plaintiff, : : Index No. 657193/20 - against – : : BREMEN HOUSE INC., BREMEN HOUSE TEXAS, : INC., GERMAN NEWS COMPANY, INC., GERMAN : NEWS TEXAS, INC., 254 - 258 W. 35TH ST. LLC, : BERRIN TEKINER, GONCA TEKINER, and : BILLUR AKIPEK, in her capacity as a Trustee of : The Yasemin Tekiner 2011 Descendants Trust, : : Defendants. : -------------------------------------- x AFFIDAVIT OF YASEMIN TEKINER STATE OF CALIFORNIA ) : COUNTY OF LOS ANGELES ) YASEMIN TEKINER, being duly sworn, deposes and says: 1. I am the plaintiff in this action. Since its inception, I have been a beneficiary and also a Trustee of The Yasemin Tekiner 2011 Descendants Trust (the “Trust”) (except for one period of time when I was previously removed as Trustee of the Trust). The Trust holds major interests in the Company Defendants named in this action, directly and indirectly, for the benefit of me and my descendants. I am also a director or officer of certain of the Company Defendants, as they are defined below. 1 12230698v.6 1 of 8 FILED: NEW YORK COUNTY CLERK 01/04/2021 11:01 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 01/04/2021 2. I make this affidavit in support of my emergency application for an order to show cause for a preliminary injunction with temporary restraining order to enjoin and restrain Defendants from taking further acts of retaliation against me, and to enjoin and restrain the Individual Defendants, as they are defined below, from using any funds or other assets of the Company Defendants to defend this action. I have personal knowledge of the matters set forth herein. 3. Defendants, Bremen House, Inc. (“Bremen House”), Bremen House Texas, Inc., German News Company, Inc. (German News”), German News Texas, Inc., and 254 – 258 W. 35th St. LLC (collectively the “Company Defendants” or “Companies”) own valuable New York and Texas real estate. These companies own properties that were assembled by my father, Sami Tekiner (“Sami”), over a 70-year period during his lifetime working in the real estate business. 4. Following Sami’s death, my mother, Defendant Berrin Tekiner (“Berrin”) took over the formal management of the Companies and their properties, although she had been running them already as my father suffered from Alzheimer’s disease. In the early 2000s, my sister, Defendant Gonca Tekiner (“Gonca”), began working at the Companies. Neither my mother nor my sister have any formal training in real estate management or investment and they both suffer from personal health issues which has made their conduct erratic. 5. I have been concerned for several years that the Companies have not been managed properly and that Berrin and Gonca (collectively the “ Individual Defendants”) have been using funds of the Companies as their own personal piggy bank. For example, in recent years, the Company Defendants have experienced negative cash flow and have thus been losing over $1 million per year. The Companies’ investment properties have substantial debt and large expenses, which makes it difficult if not impossible for the Companies to turn a profit. Among 2 12230698v.6 2 of 8 FILED: NEW YORK COUNTY CLERK 01/04/2021 11:01 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 01/04/2021 the expenses paid for by the companies is a wide assortment of personal expenses for Berrin and Gonca, including large phone bills, housekeeping and landscaping expenses for their homes and even pet food. 6. From time to time, I have raised questions about these matters but have been left uninformed by the management of the Companies and my questioning has frequently been met with acts of personal retaliation taken against me. Notably, in 2017, in breach of her duties as Chair of the Bremen House Board, Berrin removed me as both a director of Bremen House and as a Trustee of my own Trust in response to my raising legitimate questions about the business and finances of the Companies. 7. One of my concerns back in 2017 was that the Companies had taken out a $6 million blanket mortgage over the Companies’ properties in order to, among other things, buy a home in Bronxville, New York for my sister, Gonca, to live in -- even though Gonca already benefited from a multi-million dollar Manhattan apartment that the Companies had purchased for her. Upon raising my concerns, I was immediately met with threats from my mother. 8. Berrin thereafter sent me a July 2017 email apologizing for her threats, saying that she had “looked through all of the e mails and texts” on the issue and then acknowledging that she had done “the most scary part … by threatening you cutting you off.” Berrin admitted that “it was wrong. I thought you knew me better and ignore my empty threats. But it was WRONG and SMALL of me.” She added that I was “right” when I said “let’s cool off, and do whatever we can to make everyone feel secure and feel better.” Berrin concluded her email to me by saying: “I am sorry and apologize for speaking so carelessly and unnecessarily.” Attached as Exhibit A is a true and correct copy of this email. 3 12230698v.6 3 of 8 FILED: NEW YORK COUNTY CLERK 01/04/2021 11:01 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 01/04/2021 9. Despite this apology, in acts of utter retaliation, Berrin instructed me not to ask questions of the Companies’ employees and ultimately removed me as a Director of Bremen House and as a Trustee of the Yasemin Trust. Berrin has removed other trustees in the past who questioned her actions. 10. It was only after I had patched up my relationship with my mother Berrin and Berrin had become worried about the businesses’ growing financial difficulties, that she reinstated me in these roles. 11. This was not my family’s only act of retaliation taken toward me that year. In April 2017, I had objected to racist comments that Gonca made at a family dinner, which I and my other sister, Zeynep Tekiner, found to be offensive. Shortly thereafter, Berrin texted me saying that I was being evicted from a family-owned apartment in Manhattan. My other sister, Zeynep, called this eviction “unnecessarily punitive.” 12. Additionally, Gonca was hired as Bremen House’s President and CEO at a highly favorable salary of $480,000 (since raised further) plus bonus and expense reimbursements. Unbeknownst to me, the company also signed an employment contract with Gonca which gave her ten years of guaranteed severance should she leave the company in the future. The cost of this excessive severance would effectively preclude the company from engaging professional management should it choose to do so. 13. In late 2019 and early 2020, Gonca suffered a relapse of her personal health problems. In the fits of these issues, Gonca tried to fire my mother from her roles with the Company Defendants and kick her out of the companies’ offices, exclaiming to her: “You and your gay family [a reference to me and my partner] don’t belong here.” Shortly after this incident, Berrin announced that she wanted to fire Gonca from her positions with the Company 4 12230698v.6 4 of 8 FILED: NEW YORK COUNTY CLERK 01/04/2021 11:01 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 01/04/2021 Defendants. In reaction, Berrin stated in an email: Gonca “will be getting more than 20 million dollars in addition to other benefits, to the detriment of the company and her sisters, while being very mean and disrespectful of the whole family especially me, who gave her this trust.” Berrin exclaimed that “the family is totally upset” with Gonca. Around this time, Berrin also told me that Gonca had mismanaged the companies and faulted Gonca for their expenses being so high. 14. Berrin’s personal lawyers, who also serve as company counsel and are the same lawyers who put Gonca’s sweetheart employment contract in place, were worried that firing her could trigger the lucrative ten-year severance payments that this contract afforded her. 15. But Berrin pushed back, saying that leaving Gonca in her role as President “will leave her with a lot of authority” and that her counsel’s recommended action was “just the opposite of what I want to achieve.” Ultimately, Berrin did fire Gonca as President and CEO of the company. 16. Gonca’s personal issues became so bad that she again checked into a facility. Gonca begged my mother to reinstate her back into her company positions. Berrin eventually did so despite my pointing out to her that Gonca’s circumstances satisfied one of the limited grounds on which Bremen House could fire Gonca without paying her severance. 17. Moreover, at my recommendation, the Companies engaged a real estate adviser. Berrin and Gonca objected to the scope of the adviser’s assignment and it was narrowed considerably as a result. Nonetheless, the adviser prepared a proposed strategy for re-investment of the Companies’ properties. However, Berrin terminated the adviser’s services shortly before they were to present their strategic plan to us. Berrin and Gonca have chosen not to follow the adviser’s advice. 5 12230698v.6 5 of 8 FILED: NEW YORK COUNTY CLERK 01/04/2021 11:01 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 01/04/2021 18. Bremen House and German News recently looked to sell some of their valuable development properties in order to take steps toward returning to profitability. For example, the company reached a deal to sell certain of its Manhattan properties to Extell Acquisitions LLC (“Extell”), a major developer, in two tranches for a total sales price of $60 million. I understand that this price was below the sales prices of recent transactions involving comparable properties in the area. 19. I was asked to sign a consent to these transactions based on that $60 million price. However, when she got to the signing, Berrin – without consulting me – agreed to drop the price of one of these sales by $10 million. Even the company’s real estate lawyer recommended against acceding to this request, absent receipt of some additional consideration from the buyer in exchange for doing so. The lawyer called Extell’s conduct in lowering the price “disgusting” and “underhanded.” 20. Upon learning of the Extell sales price reduction, I recently asked Bremen House’s accountant and bookkeeper for access to certain books and records of the Companies so that I could satisfy myself that the Company Defendants’ affairs were being run properly. This request was overruled by Berrin, in her role as Chair of the company’s Board of Directors. Attached as Exhibit B is a true and correct copy of an email from Bremen House’s accountant to me on October 15, 2020. 21. The denial of this request left me no choice but to make a formal books and records demand to ensure that my legal right to review company records was honored. As a result, pursuant to my rights as a director of Bremen House and treasurer of German News, and also as Trustee of a Trust holding substantial shares in the Companies for my benefit, on November 11, 2020, through my counsel, I formally requested access to various corporate books 6 12230698v.6 6 of 8 FILED: NEW YORK COUNTY CLERK 01/04/2021 11:01 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 01/04/2021 and records for the time period January 1, 2017 to the present. Attached as Exhibit C is a true and correct copy of this request. I understand that this request, too, has been denied. 22. In an additional act of retaliation, in mid-October 2020, after objection to the Extell price drop, I was locked out of Bremen House’s email account in order to keep me from accessing company communications. When I raised this, my access to the server was temporarily restored but I was recently locked out of my account again. 23. On December 10, 2020, in retaliation for my efforts to inquire into and question her management of the Companies, Berrin signed a document purporting to remove me as a Trustee of my Trust. Berrin concealed the existence of this removal document until it recently came to light in connection with a communication with the corporate trustee of my Trust. I believe that Berrin’s acts in removing me as a Trustee of her Trust and concealing this action constitute an abuse of trust and a breach of her multiple fiduciary duties. 24. I am also fearful that the Individual Defendants, given their past histories of retaliation toward me and their pattern of erratic behavior, will take other retaliatory actions against me unless they are restrained from doing so by this Court. 25. In the past Berrin removed me as a director and officer of the Companies when I raised questions about company management. I fear that she will do so again in retaliation for the issues I am raising in this lawsuit. 26. I also earn a salary for my work on behalf of the Companies. I live, pursuant to a lease on which I make annual rental payments, in a house that is owned by Bremen House. That house was purchased with the proceeds from the sale of an apartment in which I lived in New York City. 7 12230698v.6 7 of 8 FILED: NEW YORK COUNTY CLERK 01/04/2021 11:01 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 7 RECEIVED NYSCEF: 01/04/2021 27. I am quite concerned that the Defendants will retaliate against me by taking actions to hold back my income or deprive me of my property rights to my home, unless this Court restrains them from taking such actions. 28. In addition, the Individual Defendants have an extensive history of using company funds to pay their personal expenses, even paying Berrin’s personal driver and housekeeper with company funds. I am fearful that, unless restrained from doing so by this Court, the Individual Defendants will try to use company funds or assets to pay for their defense of this lawsuit. Given that my complaint raises issues about their misuse of company funds and assets, it would be improper to allow them to do so. WHEREFORE, I respectfully request that this Court enter an order temporarily, preliminarily and permanently restraining and enjoining the Defendants: 1. from taking any acts to retaliate against me, including but not limited to terminating me as a director, officer or employee of the Company Defendants, reducing my salary and bonus payable by the Company Defendants or impairing my right to occupy my home; and 2. from using any funds or assets of the Company Defendants to pay any of the Individual Defendants’ legal fees and expenses in defending this action; and grant such other and further relief as may be just and proper. Dated: December 31, 2020 _____________________________ Yasemin Tekiner Sworn to before me this __ day of ___________, 2020 ________________________ Notary Public 8 12230698v.6 8 of 8