Preview
FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 471 RECEIVED NYSCEF: 06/15/2022
EXHIBIT B
FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 471 RECEIVED NYSCEF: 06/15/2022
SUBP-035
ATTORNEY ORPARTYWITHOUTATTORNEY (Name,StateBarnumber,andeddress):
Chakameh Gany (StateBar No. 311720)
NORTON ROSE FULBRIGHT US LLP
555 South Flower St.,Forty-FirstFloor,Los Angeles, CA 90071
TELEPHONE NO.: (213)892-9243 FAXNO.(OptionaQ:
E-MAILADDRESS:chakameh.ganji@nortonrosefulbright.com
ATTORNEYFOR(Name):Defendants Bremen House Inc.,etal.
Courtfor countyin which is to be conducted:
discovery Santa Monica Courthouse
SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES
STREETADDRESS:1725 Main Street
MAILINGADDRESS:
CITY.STATEANDZIPCODE: Santa Monica, CA 90401
BRANCHNAME: Santa Monica Courthouse
Courtin whichactionis pending:
Name ofCourt: SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK
STREETADDRESS:60 Centre Street
MAILINGADDRESS:
CITY,STATEANDZIPCODE: New York, New York 10007
COUNTRY:United States of America
PLAINTIFF/PETITIONER: Yasemin Tekiner,etc. CALIFORNIA
CASENUMBER(if any assignedby court):
DEFENDANT/RESPONDENT: Bremen House Inc., et al. n/a
CASENUMBER(ofactionpnding ouWdeCalHenier
SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS
IN ACTION PENDING OUTSIDE CALIFORNIA Index No.: 657193/2020
THE PEOPLE OF THE STATE OF CALIFORNIA, TO (name, address, and telephone number of deponent, ifknown):
Lisa Rubin, 10819 Vicenza Way, Los Angeles, CA 90077
1. YOU ARE ORDERED TO PRODUCE THE BUSINESS RECORDS described in item3,as follows:
To (name ofdeposition officer):Express Network, (213) 835-2770
On (date):April15, 2021 At (time):10:00 a.m.
Location (address): 1605 W. Olympic Blvd.,Suite 800, Los Angeles, CA 90015
Do not release the requested records to the deposition officer prior to the date and time stated above.
a. x by deliveringa true,legible,and durable copy of the business records described initem 3,enclosed in a sealed inner
wrapper withthe title
and number ofthe action, name of witness,and date of subpoena clearlywritten on it. Theinner
wrapper shallthen be enclosed in anouter envelope or wrapper, sealed, and mailed to the depositionofficerat the
address initem 1.
b. by deliveringa true,legible,and durable copy of the business records described in item3 tothe deposition officerat
the witness's address, on receiptof payment in cash orby check ofthe reasonable costs ofpreparing the copy, as
determined under Evidence Code section 1563(b).
c. by making the originalbusiness records described in item3 availableforinspection atyour business address by the
attorney'srepresentative and permitting copying atyour business address under reasonable conditions during normal
business hours.
2. The records are tobe produced by the date and time shown in item 1 (butnot sooner than 20 days afterthe issuance of the
deposition subpoena, or 15 days afterservice, whichever date is later).
Reasonable costs oflocatingrecords, making them
available orcopying them, and postage, if any,are recoverable as set forthinEvidence Code section 1563(b). The records must
be accompanied by an affidavitofthe custodian or other qualifiedwitness pursuant to Evidence Code section1561.
3. The records to be produced are described as follows (if electronically
stored information isdemanded, the form or forms inwhich
each typeof information is tobe produced may be specified):
See Attachment 3.
× Continued on Attachment 3 (use form MC-025).
4. Attorneys of record in this
action or partieswithout attomeys are (name, address, telephone number, and name of party
represented): See Attachment 4.
× Continued on Attachment 4 (use form MC-025). eaget or a
FormAdopt r Manda se Codeof CivilProcedure,§§ 2
SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS
SUBP-035[Rev.January1,2012] IN ACTION PENDING OUTSIDE CALIFORNIA Government
Code,§ 68097.1
www.courts.ca.gov
FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 471 RECEIVED NYSCEF: 06/15/2022
SUBP-035
PLAINTIFF/PETITIONER: Yasemin Takiner,etc. CASENUMBER(ofactionpendingoutsideCaBfomia):
Index No.: 657193/2020
DEFENDANT/RESPONDENT: Bremen House et al.
Inc.,
5. If you have been served with thisenhpamrla as aCustodlan ofConsumer or employee records under Code ofCivil
Procedure section 1985.6 anda motion toquash or an objection has been served on you, a court order or agreement of
the parties, witnesses, and consumer or employee affected must be obtained before you are required to produce
consumer or employee records.
6. X Other terms orprovisions from out-of-statesubpoena, if any(specify):
See Attachment 6 forinstructionsand definitions.
x Continued on Attachment 6 (use form MC-025).
DISOBEDIENCE OF THIS SUBPOENA MAY BE PUNISHED AS CONTEMPT BY THIS COURT. YOU WILL ALSO BE LIABLE
FOR TNE SUM OF $500 AND ALL DAMAGES RESULTING FROM YOUR FAILURE TO OBEY.
Date issued: March 18, 2021
Chakameh Ganji
(TYPEORPRINTNAME) (SIGNATUREOFPERSONISSUINGSUBPOENA)
Attomey forDefendants Bremen House Inc.,etal.
(TITLE)
PROOF OF SERVICE OF SUBPOENA FOR
PRODUCTION OF BUSINESS RECORDS
1. I served thisSubpoena forProduction ofBusiness Records In ActionPanding Outside Califomia by personally deliveringa
copy to the person served as follows:
a. Person served (name): .
b. Address where served:
c. Date of delivery: d. Time of delivery:
e. Witness fees and mileage both ways (check one):
(1) were paid. Amount: . . . . . . . . . . . . . $
(2) were not paid.
(3) were tendered to thewitness's publicentityemployer as required by Govemment Code section 68097.2. The
amount tendered was(specify): $
f. Fee for service:. . . . . . . . . . . . . . . . . . . . . .
. . .$
2. I receivedthissubpoena forservice on (date):
3. I alsoserved a completed Proof ofService ofNotice to Consumer or Employee and Objection (form SUBP-025)
by personally deliveringa copy to the person served as described in 1 above.
4. Person serving:
a. Not a registered Califomia process server
b. Califomia sheriffor marshal
c. Registered Califomia process server
d. Employee or independent contractor ofa registered Califomia process server
e. Exempt from registration
under Business and Professions Code section 22350(b)
f. Registered professionalphotocopier
g. Exempt from registration
under Business and Professions Code section 22451
h. Name, address, telephone number, and, if applicable,
county of registration
and number
I declare under penalty ofperjury under the laws of theState of (For Californiasheriff or marshal use only)
Califomia thatthe foregoing istrue and correct. that
I certify the foregoing is trueand correct.
Date: Date:
(SIGNATURE) (SIGNATURE)
SUBPG [ [RmrAnuary 1,20120 Page2 of 2
SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS
IN ACTION PENDING OUTSIDE CALIFORNIA
FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 471 RECEIVED NYSCEF: 06/15/2022
MC-025
CASEWMBER:
SHORT TITLE:
Yasemin Tekiner, etc. v. Bremen House Inc., et al. Index No.: 657193/2020
ATTACHMENT (Number): 3
(ThisAttachment may be used withany JudicialCouncil form.)
REQUEST NO. 1 All documents and communications regarding the management, operations, or finances of
the Companies.
REQUEST NO. 2 All documents and communications regarding Weitzman Associates.
REQUEST NO. 3 All documents and communications regarding Marcus & Millichap, Inc.
REQUEST NO. 4 All documents and communications regarding the Extell Transaction, including but not
Companies'
limited to documents discussing the negotiations with all potential bidders, the valuation of the
properties at issue in the transaction, and the effect of the COVID-19 pandemic on the value of the properties
or the New York City real estate market.
REQUEST NO. 5 All documents and communications regarding what the Companies should do with the
proceeds of the Extell Transaction.
REQUEST NO. 6 All documents and communications regarding dividing, liquidating, or otherwise splitting up
the assets of the Companies.
REQUEST NO. 7 All documents and communications regarding the 1031 Exchange.
REQUEST NO. 8 All documents and communications regarding the operation, management, and finances of
the Trust.
REQUEST NO. 9 All documents and communications regarding distributions to Yasemin under the Trust.
REQUEST NO. 10 All documents and communications regarding the removal of Yasemin as a member of the
Trust Committee and her removal or termination as an officer and director of the Companies.
Companies'
REQUEST NO. 11 All documents and communications regarding the properties in which You
have resided or anticipated residing, including but not limited to 312¬-314 Bowery, New York, NY; 1320
Madison Avenue, New York, NY; and 10819 Vicenza Way, Los Angeles, CA.
REQUEST NO. 12 All documents and communications regarding the purchase of 10819 Vicenza Way, Los
Angeles, CA.
REQUEST NO. 13 All documents and communications regarding the amounts You have paid or pay to live at
10819 Vicenza Way, Los Angeles, CA, including but not limited to rent, lease, or mortgage payments.
REQUEST NO. 14 AII documents and communications regarding the amounts You have paid or pay in
expenses or costs related to 10819 Vicenza Way, Los Angeles, CA, including but not limited to renovation
expenses; home furnishings; home maintenance, such as plumbing, roofing, housekeeping, gardening, etc.;
home insurance; or any other services, such as electricity, gas, water, internet, garbage disposal or sewage.
(If the
item that thisAttachment concems ismade under penalty of pedury, allstatements inthis Page of 2
Attachment are made under penalty of pedury.)
(Add pages as required)
Form p ed t a se =®"*"*ª 9"
ATTACHMENT
MC-025[Rev.July1,2009] to Judicial Council Form
FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 471 RECEIVED NYSCEF: 06/15/2022
MC-025
cASE NUMBER:
SHORT TITLE:
Yasemin Tekiner, etc. v. Bremen House Inc., et al. Index No.: 657193/2020
ATTACHMENT (Number): 3
(ThisAttachment may be used with any JudicialCouncil form.)
REQUEST NO. 15 All documents and communications regarding any trips you have taken that were paid for,
in whole or in part, by the Companies or Berrin, including but not limited to documents reflecting that the
Companies paid for Your air travel, hotel accommodations, meals, and entertainment.
REQUEST NO. 16 All documents and communications regarding Your move to New York, NY in 2016 and
2017 and decision to stay in one or more Company-owned apartments, including but not limited to (1) the
reasons for Your move, (2) evidence of Your employment in New York, (3) Your filming schedule in New
York during the time You resided in a Company-owned apartment, (4) whether Your employer offered you
living expenses or an apartment/hotel while You were in New York and Your response, and (5) any other
apartments, hotels, or houses that You considered staying in while You lived in New York other than
Company-owned apartments.
REQUEST NO. 17 All documents and comrnunications regarding Your salary made during the time You
resided in Company-owned apartments in New York in 2016 and 2017.
REQUEST NO. 18 All documents and communications regarding the amounts You paid to live in
Company-owned apartments in New York in 2016 and 2017, including but not limited to lease, rent or
mortgage payments; renovation expenses; home furnishings; home maintenance; home insurance; or services,
such as electricity, gas, water, internet, garbage disposal, or sewage.
REQUEST NO. 19 All documents and communications regarding costs incurred by the Companies during
Your occupancy of 312¬-314 Bowery, New York, NY and 1320 Madison Avenue, New York, NY, including
but not limited to lease, rent or mortgage payments; renovation expenses; home furnishings; home
maintenance; home insurance; services such as electricity, gas, water, internet, garbage disposal, insurance; or
any other benefits the Companies paid for such as food, alcohol, delivery services, laundry services, or
cleaning services.
REQUEST NO. 20 All documents and communications regarding renovations or updates made to 312¬-314
Bowery, New York, NY or 1320 Madison Avenue, New York, NY in 2016 or 2017.
REQUEST NO. 21 All documents and communications regarding any direct or indirect monetary benefit You
have derived from the Companies or the Trust, including but not limited to (1) cash payments to Yasemin in
the form of salary, gifts,bonuses, dividends, distributions, or reimbursements; and (2) expenses incurred by the
Companies or the Trust on behalf of You or Yasemin, such as living, food, clothing, or travel expenses.
REQUEST NO. 22 All documents and communications regarding any living accommodations provided to You
by the Companies, including but not limited to any apartments, homes, townhomes, or hotels in which You
stayed or are staying.
REQUEST NO. 23 All documents and communications regarding the decision to file the Complaint in the
instant Action or sue the Defendants.
(iftheitem that thisAttachment concems ismade under penalty of pedury, allstatements in this Page 2 or 2
Attachment are made under penalty of perjury.)
FormApprovedforOptionalUse "°° *
ATTACHMENT
trcTådRWtoEei to Judicial Council Form
FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 471 RECEIVED NYSCEF: 06/15/2022
MC-025
CASEWMBER:
SHORT TITLE:
-
Yasemin Tekiner, etc. v. Bremen House Inc., et al. Index No.: 657193/2020
ATTACHMENT (Number): 4
(ThisAttachment may be used with any JudicialCouncil form.)
All parties are represented by counsel.
Counsel for Plaintiff Yasemin Tekiner:
Evan Mandel
Mandel Bhandari LLP
80 Pine Street, 33rd Floor
New York, NY 10005
(212) 269-5600
(646) 964-6667 (fax)
em@mandelbhandari.com
Counsel for Defendants 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:
Judith A. Archer
Victoria V. Corder
Sean M. Topping
Norton Rose Fulbright US LLP
1301 Avenue of the Americas
New York, New York 10019-6022
(212) 318-3000
(212) 318-3400 (fax)
judith.archer@nortonrosefulbright.com
victoria.corder@nortonrosefulbright.com
sean.topping@nortonrosefulbright.com
(If the
item that thisAttachment concems ismade under penalty of pedury, allstatements inthis Page 1 of
Attachment are made under penalty of pedury.)
(Add pages as required)
Fo p ed t a se ""°°'6"*"S"
ATTACHMENT
MC-025[Rev.July1,2009] to Judicial Council Form
FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 471 RECEIVED NYSCEF: 06/15/2022
MC-025
CASEMBER:
SHORT TITLE:
-
Yasemin Tekiner, etc. v. Bremen House Inc., et al. Index No.: 657193/2020
ATTACHMENT (Number): 6
(ThisAttachment may be used with any JudicialCouncil form.)
INSTRUCTIONS
In addition to the CPLR, Commercial Division Rules, Local Rules, and governing law please respond in
accordance with the following instructions:
1. Each Request shall be answered completely, separately, and fully in writing in accordance with CPLR
Article 31.
2. In responding to the Requests, You shall produce all responsive documents that are in Your possession,
custody, or control or in the possession, custody, or control of Your, agents, employees, attorneys, accountants,
financial advisors, or other representatives. A document shall be deemed to be within Your control if You
have the right to secure the document or a copy of the document from another person having possession or
custody of the document.
3. If You are unable to respond to any Request, after exercising due diligence to secure the requested
information, so state, and explain why the Request cannot be answered.
4. If no documents exist that are responsive to a particular Request, so state in writing.
5. If an objection is made to a Request, state allgrounds upon which the objection is based and, if applicable,
the extent to which the Request will nonetheless be complied with.
6. If any document is currently not available and is in the possession of another party, identify the person or
persons from whom the document may be obtained.
7. If any document which forms a part of or the entire basis for any response to a Request has been destroyed
or lost, for each such document state when itwas destroyed or lost, identify the person who destroyed or lost
the document, and the person who directed that itbe destroyed. In addition, detail the reasons for the
destruction, describe the nature of the document, identify the person(s) who created, sent and received the
document, state the date of the document, and state in as much detail as possible the contents of the document.
(If the
item that thisAttachment concems ismade under penalty of pedury, allstatements inthis Page 1 of 6
Attachment are made under penalty of pedury.)
(Add pages as required)
Form p ed t a se ""°"*"**S"
ATTACHMENT
MC-025[Rev.July1,2009] to Judicial Council Form
FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 471 RECEIVED NYSCEF: 06/15/2022
MC-025
CASEMBER:
SHORT TITLE:
Yasemin Tekiner, etc. v. Bremen House Inc., et al. Index No.: 657193/2020
ATTACHMENT (Number): 6
(ThisAttachment may be used with any JudicialCouncil form.)
INSTRUCTIONS (continued)
8. Each document is to be produced, along with all drafts thereof or attachments thereto, in itsentirety, without
abbreviation or redaction, unless withheld by You on the basis of a claim of privilege. If any portion of a
document is responsive to a Request, produce the entire document, including all attachments, enclosures,
"post-it"-type notes, and any other matter physically attached to the document, whether by paper clip or any
other manner. If documents responsive to a Request are normally kept in a fileor folder, also produce that file
or folder with any labels attached thereto and identify the company, division, department, and/or individual
from whose files the document is being produced. If responsive documents are segregated or separated from
other documents, whether by inclusion in binders, files,sub-files, or by use of dividers, tabs or any other
method, produce such documents in that form.
9. Copies of any document responsive to any Request that is not an identical duplicate of the original document
because of markings, handwritten notations, or any other difference should be considered separate documents
and should be produced. English translations or partial translations of foreign language documents should also
be considered separate documents.
10. Where a claim of privilege (which term, as used herein, includes claims that requested information is
protected from discovery under the attorney-client privilege, work product doctrine or trialpreparation
material) is asserted in objecting to any document request or portion thereof, and any requested documents are
withheld on the basis of such assertion, You shall set forth completely the grounds for the asserted privilege in
a privilege log. You shall identify as to each communication or document: (a) itsdate; (b) itsauthor(s); (c) its
recipient(s); (d) the number of pages and attachments or appendices; (e) itspresent custodian (f) itssubject
matter; (g) a description of itscontent; (h) and the legal basis upon which You claim privilege. To the extent
only a portion of a document is privileged, the non-privileged portion should be produced and any redactions
should be clearly marked and logged. Privileged documents should be logged separately, and non-privileged
portions of documents or attachments to privileged documents should be produced.
11. These Requests require production of copies of all electronically stored information in the form of
single-page TIFF images with accompanying text extraction and searchable OCR, together with load files
containing the following metadata at a minimum: BEGBATES, ENDBATES, BEGATTACH, ENDATTACH,
FILENAME, SUBJECT, DATESENT, DATELASTMOD, DATECREATED, CUSTODIAN, AUTHOR,
FROM, TO, CC, BCC, MD5HASH, and TEXTPATH. Where a custodian is a departmental file or network
drive shared by a group of users, or a FROM, TO, CC, or BCC is a group distribution list,You shall identify
allpersons with access to such files, drives or copied on such distribution list. Additionally, all Excel (or other
electronic spreadsheet files) and all PowerPoint (or other electronic slideshow files), including any such files
attached to emails, shall be produced in their native format. Defendants reserve the right to request production
in native format of any other documents produced in response to these Requests.
(If the
item that thisAttachment concems ismade under penalty of pedury, allstatements inthis Page 2 or 6
Attachment are made under penalty of pedury.)
dd n m )
Form p ed t a se =®°*" "S"
ATTACHMENT
MC-025[Rev.July1,2009] to Judicial Council Form
FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 471 RECEIVED NYSCEF: 06/15/2022
MC-025
CASEWMBER:
SHORT TITLE:
-
Yasemin Tekiner, etc. v. Bremen House Inc., et al. Index No.: 657193/2020
ATTACHMENT (Number): 6
(ThisAttachment may be used with any JudicialCouncil form.)
INSTRUCTIONS (continued)
12. Unless a different time frame is specified in a particular request, these Requests seek documents created,
modified, received, or sent during the period from January 1, 2015 to the present (the "Relevant Period").
13. Pursuant to CPLR 3101(h), these document requests are deemed to be continuing. If Plaintiff or its
representatives receive or acquire any information and/or documents responsive to these Requests after serving
responses to these Requests, such information and/or documents should be added to the responses to these
Defendants'
Requests and served upon counsel.
(If the
item that thisAttachment concems ismade under penalty of pedury, allstatements inthis Page 3 or 6
Attachment are made under penalty of pedury.)
(Add pa n r imd)
Fo p ed t a se "=®"*"*"S"
ATTACHMENT
MC-025[Rev.July1,2009] to Judicial Council Form
FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 471 RECEIVED NYSCEF: 06/15/2022
MC-025
CASEMBER:
SHORT TITLE:
-
Yasemin Tekiner, etc. v. Bremen House Inc., et al. Index No.: 657193/2020
ATTACHMENT (Number): 6
(ThisAttachment may be used with any JudicialCouncil form.)
DEFINITIONS
As used in these Requests, the following terms shall have the meanings set forth below:
"Action"
1. means Yasemin Tekiner v. Bremen House, Inc., Bremen House Texas, Inc., German News
German News 254 - 258 W. 35th St. Berrin Gonca and
Company, Inc., Texas, Inc., LLC, Tekiner, Tekiner,
Billur Akipek, Index No. 657193/2020, Supreme Court of the State of New York, County of New York
(Cohen, J.).
"Berrin"
2. means Defendant Berrin Tekiner, as well as her agents, employees, attorneys, accountants,
financial advisors, or other representatives.
"Billur"
3. means Defendant Billur Akipek, as well as her agents, employees, attorneys, accountants, financial
advisors, or other representatives.
House"
4. "Bremen means Defendant Bremen House, Inc.
Texas"
5. "Bremen House means Defendant Bremen House Texas, Inc.
"Communication"
6. means, without limitation, any written or electronic transmission of information,
including but not limited to any emails, text messages, written correspondence, memorandum, facsimile,
telephone conversation, video conference, posts or messages from social media platforms including, but not
limited to, Facebook, Instagram, LinkedIn, and Twitter, messages sent through applications such as Instagram,
Facebook, LinkedIn, and WhatsApp, or any other electronic or computer transmission.
"Companies" Defendants"
7. or "Company means Bremen House, Bremen House Texas, German News,
German News 254 - 258 W. 35th St.
Texas,
"Complaint"
8. means the Amended Verified Complaint, filed in the Action, on January 25, 2021 (Dkt. 86),
which is annexed hereto.
"Defendants"
9. refers collectively to the Company Defendants and Individual Defendants.
(If the
item that thisAttachment concems ismade under penalty of pedury, allstatements inthis Page 4 of 6
Attachment are made under penalty of pedury.)
Form p ed t a se "S"
ATTACHMENT
MC-025[Rev.July1,2009] to Judicial Council Form
FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 471 RECEIVED NYSCEF: 06/15/2022
MC-025
CASEMBER:
SHORT TITLE:
Yasemin Tekiner, etc. v. Bremen House Inc., et al. Index No.: 657193/2020
ATTACHMENT (Number): 6
(ThisAttachment may be used with any JudicialCouncil form.)
DEFINITIONS (continued)
"Document"
10. is used in the broadest sense permissible under the CPLR and includes, without limitation, all
objects tangible or intangible, from which information may be derived, however reproduced, including any
recording in any tangible form of any information, whether handwritten, typed, stored electronically, stored on
computer disks, tapes, or databases, or otherwise stored or reproduced, whether sent or received or neither,
whether within the actual or constructive possession, custody, or control of any agent, employee, consultant,
accountant or any other person, including drafts and copies bearing notations and marks not found in the
original. For the avoidance of doubt, this includes emails, text messages, writings, drawings, graphs, charts,
photographs, sound recordings, voicemails, images, and other data or data compilations, posts or messages
from social media platforms including, but not limited to, Facebook, Instagram, LinkedIn, and Twitter, and
messages sent through applications such as Instagram, Facebook, LinkedIn, and WhatsApp.
Sale" Companies'
11. "Extell refers to the attempt to sell the properties at 1653/1659 1st Avenue and 349/361
East 86th Street, 218/220 East 86th Street a/k/a 217/219 East 85th Street, 300/302 East 86th Street a/k/a 1656
2nd Avenue, 304 East 86th Street, and 128 East 91st Street a/k/a 1372/1378 Lexington Avenue, New York,
NY.
News"
12. "German means Defendant German News Company, Inc.
Texas"
13. "German News means Defendant German News Texas Company, Inc.
"Gonca"
14. means Defendant Gonca Tekiner, as well as her agents, employees, attorneys, accountants,
financial advisors, or other representatives.
"Including"
15. shall mean including, without limitation, the specific matter, documents or electronically
stored information described.
Defendants"
16. "Individual means Defendants Berrin Tekiner, Gonca Tekiner, and Billur Akipek, as well as
any of their agents, employees, attorneys, accountants, financial advisors, or other representatives.
Affidavit"
17. "Reply means the Reply Affidavit of Yasemin Tekiner, filed in the Action, on January 21, 2021
(Dkt. 41).
Agreement"
18. "Trust refers to the Yasemin Tekiner 2011 Descendants Trust Agreement.
St." -
19. "W. 35th means Defendant 254 258 W. 35th St. LLC.
(If the
item that thisAttachment concems ismade under penalty of pedury, allstatements inthis Page 5 or 6
Attachment are made under penalty of pedury.)
dd n r imd)
Form p ed t a se =®°*"*ª 9"
ATTACHMENT
MC-025[Rev.July1,2009] to Judicial Council Form
FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 471 RECEIVED NYSCEF: 06/15/2022
MC-025
CASEMBER:
SHORT TITLE:
-
Yasemin Tekiner, etc. v. Bremen House Inc., et al. Index No.: 657193/2020
ATTACHMENT (Number): 6
(ThisAttachment may be used with any JudicialCouncil form.)
DEFINITIONS (continued)
"Yasemin,"
20. refers to Plaintiff Yasemin Tekiner and/or any persons acting or purporting to act on behalf of
Plaintiff.
Trust"
21. "Yasemin refers to the Yasemin Tekiner 2011 Descendants Trust.
"You" "Your"
22. and refer to Lisa Rubin and/or any persons acting or purporting to act on behalf of You.
"Zeynep"
23. means non-party Zeynep Tekiner, as well as her agents, employees, attorneys, accountants,
financial advisors, or other representatives.
Exchange"
24. "1031 refers to the like-kind exchange under IRC Section 1031 in which the Companies intend
to engage using the proceeds from the Extell Sale.
to," to," to," "regarding," "concerning"
25. The phrases "relating "related "referring and/or means directly or
indirectly, in whole or in part, constituting, evidencing, showing, recording, substantiating, describing,
analyzing, summarizing, identifying, reflecting, arising from, connected with, commenting on, responding to,
or in any way having a logical or factual connection with the matter at issue, in any way, directly or indirectly.
concerning"
Without limiting the foregoing definition, "documents or communications a particular subject
matter include all documents or communications that comprise, record, memorialize, discuss, evaluate, report
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FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 471 RECEIVED NYSCEF: 06/15/2022 EXHIBIT B FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 471 RECEIVED NYSCEF: 06/15/2022 SUBP-035 ATTORNEY ORPARTYWITHOUTATTORNEY (Name,StateBarnumber,andeddress): Chakameh Gany (StateBar No. 311720) NORTON ROSE FULBRIGHT US LLP 555 South Flower St.,Forty-FirstFloor,Los Angeles, CA 90071 TELEPHONE NO.: (213)892-9243 FAXNO.(OptionaQ: E-MAILADDRESS:chakameh.ganji@nortonrosefulbright.com ATTORNEYFOR(Name):Defendants Bremen House Inc.,etal. Courtfor countyin which is to be conducted: discovery Santa Monica Courthouse SUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELES STREETADDRESS:1725 Main Street MAILINGADDRESS: CITY.STATEANDZIPCODE: Santa Monica, CA 90401 BRANCHNAME: Santa Monica Courthouse Courtin whichactionis pending: Name ofCourt: SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK STREETADDRESS:60 Centre Street MAILINGADDRESS: CITY,STATEANDZIPCODE: New York, New York 10007 COUNTRY:United States of America PLAINTIFF/PETITIONER: Yasemin Tekiner,etc. CALIFORNIA CASENUMBER(if any assignedby court): DEFENDANT/RESPONDENT: Bremen House Inc., et al. n/a CASENUMBER(ofactionpnding ouWdeCalHenier SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS IN ACTION PENDING OUTSIDE CALIFORNIA Index No.: 657193/2020 THE PEOPLE OF THE STATE OF CALIFORNIA, TO (name, address, and telephone number of deponent, ifknown): Lisa Rubin, 10819 Vicenza Way, Los Angeles, CA 90077 1. YOU ARE ORDERED TO PRODUCE THE BUSINESS RECORDS described in item3,as follows: To (name ofdeposition officer):Express Network, (213) 835-2770 On (date):April15, 2021 At (time):10:00 a.m. Location (address): 1605 W. Olympic Blvd.,Suite 800, Los Angeles, CA 90015 Do not release the requested records to the deposition officer prior to the date and time stated above. a. x by deliveringa true,legible,and durable copy of the business records described initem 3,enclosed in a sealed inner wrapper withthe title and number ofthe action, name of witness,and date of subpoena clearlywritten on it. Theinner wrapper shallthen be enclosed in anouter envelope or wrapper, sealed, and mailed to the depositionofficerat the address initem 1. b. by deliveringa true,legible,and durable copy of the business records described in item3 tothe deposition officerat the witness's address, on receiptof payment in cash orby check ofthe reasonable costs ofpreparing the copy, as determined under Evidence Code section 1563(b). c. by making the originalbusiness records described in item3 availableforinspection atyour business address by the attorney'srepresentative and permitting copying atyour business address under reasonable conditions during normal business hours. 2. The records are tobe produced by the date and time shown in item 1 (butnot sooner than 20 days afterthe issuance of the deposition subpoena, or 15 days afterservice, whichever date is later). Reasonable costs oflocatingrecords, making them available orcopying them, and postage, if any,are recoverable as set forthinEvidence Code section 1563(b). The records must be accompanied by an affidavitofthe custodian or other qualifiedwitness pursuant to Evidence Code section1561. 3. The records to be produced are described as follows (if electronically stored information isdemanded, the form or forms inwhich each typeof information is tobe produced may be specified): See Attachment 3. × Continued on Attachment 3 (use form MC-025). 4. Attorneys of record in this action or partieswithout attomeys are (name, address, telephone number, and name of party represented): See Attachment 4. × Continued on Attachment 4 (use form MC-025). eaget or a FormAdopt r Manda se Codeof CivilProcedure,§§ 2 SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS SUBP-035[Rev.January1,2012] IN ACTION PENDING OUTSIDE CALIFORNIA Government Code,§ 68097.1 www.courts.ca.gov FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 471 RECEIVED NYSCEF: 06/15/2022 SUBP-035 PLAINTIFF/PETITIONER: Yasemin Takiner,etc. CASENUMBER(ofactionpendingoutsideCaBfomia): Index No.: 657193/2020 DEFENDANT/RESPONDENT: Bremen House et al. Inc., 5. If you have been served with thisenhpamrla as aCustodlan ofConsumer or employee records under Code ofCivil Procedure section 1985.6 anda motion toquash or an objection has been served on you, a court order or agreement of the parties, witnesses, and consumer or employee affected must be obtained before you are required to produce consumer or employee records. 6. X Other terms orprovisions from out-of-statesubpoena, if any(specify): See Attachment 6 forinstructionsand definitions. x Continued on Attachment 6 (use form MC-025). DISOBEDIENCE OF THIS SUBPOENA MAY BE PUNISHED AS CONTEMPT BY THIS COURT. YOU WILL ALSO BE LIABLE FOR TNE SUM OF $500 AND ALL DAMAGES RESULTING FROM YOUR FAILURE TO OBEY. Date issued: March 18, 2021 Chakameh Ganji (TYPEORPRINTNAME) (SIGNATUREOFPERSONISSUINGSUBPOENA) Attomey forDefendants Bremen House Inc.,etal. (TITLE) PROOF OF SERVICE OF SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS 1. I served thisSubpoena forProduction ofBusiness Records In ActionPanding Outside Califomia by personally deliveringa copy to the person served as follows: a. Person served (name): . b. Address where served: c. Date of delivery: d. Time of delivery: e. Witness fees and mileage both ways (check one): (1) were paid. Amount: . . . . . . . . . . . . . $ (2) were not paid. (3) were tendered to thewitness's publicentityemployer as required by Govemment Code section 68097.2. The amount tendered was(specify): $ f. Fee for service:. . . . . . . . . . . . . . . . . . . . . . . . .$ 2. I receivedthissubpoena forservice on (date): 3. I alsoserved a completed Proof ofService ofNotice to Consumer or Employee and Objection (form SUBP-025) by personally deliveringa copy to the person served as described in 1 above. 4. Person serving: a. Not a registered Califomia process server b. Califomia sheriffor marshal c. Registered Califomia process server d. Employee or independent contractor ofa registered Califomia process server e. Exempt from registration under Business and Professions Code section 22350(b) f. Registered professionalphotocopier g. Exempt from registration under Business and Professions Code section 22451 h. Name, address, telephone number, and, if applicable, county of registration and number I declare under penalty ofperjury under the laws of theState of (For Californiasheriff or marshal use only) Califomia thatthe foregoing istrue and correct. that I certify the foregoing is trueand correct. Date: Date: (SIGNATURE) (SIGNATURE) SUBPG [ [RmrAnuary 1,20120 Page2 of 2 SUBPOENA FOR PRODUCTION OF BUSINESS RECORDS IN ACTION PENDING OUTSIDE CALIFORNIA FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 471 RECEIVED NYSCEF: 06/15/2022 MC-025 CASEWMBER: SHORT TITLE: Yasemin Tekiner, etc. v. Bremen House Inc., et al. Index No.: 657193/2020 ATTACHMENT (Number): 3 (ThisAttachment may be used withany JudicialCouncil form.) REQUEST NO. 1 All documents and communications regarding the management, operations, or finances of the Companies. REQUEST NO. 2 All documents and communications regarding Weitzman Associates. REQUEST NO. 3 All documents and communications regarding Marcus & Millichap, Inc. REQUEST NO. 4 All documents and communications regarding the Extell Transaction, including but not Companies' limited to documents discussing the negotiations with all potential bidders, the valuation of the properties at issue in the transaction, and the effect of the COVID-19 pandemic on the value of the properties or the New York City real estate market. REQUEST NO. 5 All documents and communications regarding what the Companies should do with the proceeds of the Extell Transaction. REQUEST NO. 6 All documents and communications regarding dividing, liquidating, or otherwise splitting up the assets of the Companies. REQUEST NO. 7 All documents and communications regarding the 1031 Exchange. REQUEST NO. 8 All documents and communications regarding the operation, management, and finances of the Trust. REQUEST NO. 9 All documents and communications regarding distributions to Yasemin under the Trust. REQUEST NO. 10 All documents and communications regarding the removal of Yasemin as a member of the Trust Committee and her removal or termination as an officer and director of the Companies. Companies' REQUEST NO. 11 All documents and communications regarding the properties in which You have resided or anticipated residing, including but not limited to 312¬-314 Bowery, New York, NY; 1320 Madison Avenue, New York, NY; and 10819 Vicenza Way, Los Angeles, CA. REQUEST NO. 12 All documents and communications regarding the purchase of 10819 Vicenza Way, Los Angeles, CA. REQUEST NO. 13 All documents and communications regarding the amounts You have paid or pay to live at 10819 Vicenza Way, Los Angeles, CA, including but not limited to rent, lease, or mortgage payments. REQUEST NO. 14 AII documents and communications regarding the amounts You have paid or pay in expenses or costs related to 10819 Vicenza Way, Los Angeles, CA, including but not limited to renovation expenses; home furnishings; home maintenance, such as plumbing, roofing, housekeeping, gardening, etc.; home insurance; or any other services, such as electricity, gas, water, internet, garbage disposal or sewage. (If the item that thisAttachment concems ismade under penalty of pedury, allstatements inthis Page of 2 Attachment are made under penalty of pedury.) (Add pages as required) Form p ed t a se =®"*"*ª 9" ATTACHMENT MC-025[Rev.July1,2009] to Judicial Council Form FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 471 RECEIVED NYSCEF: 06/15/2022 MC-025 cASE NUMBER: SHORT TITLE: Yasemin Tekiner, etc. v. Bremen House Inc., et al. Index No.: 657193/2020 ATTACHMENT (Number): 3 (ThisAttachment may be used with any JudicialCouncil form.) REQUEST NO. 15 All documents and communications regarding any trips you have taken that were paid for, in whole or in part, by the Companies or Berrin, including but not limited to documents reflecting that the Companies paid for Your air travel, hotel accommodations, meals, and entertainment. REQUEST NO. 16 All documents and communications regarding Your move to New York, NY in 2016 and 2017 and decision to stay in one or more Company-owned apartments, including but not limited to (1) the reasons for Your move, (2) evidence of Your employment in New York, (3) Your filming schedule in New York during the time You resided in a Company-owned apartment, (4) whether Your employer offered you living expenses or an apartment/hotel while You were in New York and Your response, and (5) any other apartments, hotels, or houses that You considered staying in while You lived in New York other than Company-owned apartments. REQUEST NO. 17 All documents and comrnunications regarding Your salary made during the time You resided in Company-owned apartments in New York in 2016 and 2017. REQUEST NO. 18 All documents and communications regarding the amounts You paid to live in Company-owned apartments in New York in 2016 and 2017, including but not limited to lease, rent or mortgage payments; renovation expenses; home furnishings; home maintenance; home insurance; or services, such as electricity, gas, water, internet, garbage disposal, or sewage. REQUEST NO. 19 All documents and communications regarding costs incurred by the Companies during Your occupancy of 312¬-314 Bowery, New York, NY and 1320 Madison Avenue, New York, NY, including but not limited to lease, rent or mortgage payments; renovation expenses; home furnishings; home maintenance; home insurance; services such as electricity, gas, water, internet, garbage disposal, insurance; or any other benefits the Companies paid for such as food, alcohol, delivery services, laundry services, or cleaning services. REQUEST NO. 20 All documents and communications regarding renovations or updates made to 312¬-314 Bowery, New York, NY or 1320 Madison Avenue, New York, NY in 2016 or 2017. REQUEST NO. 21 All documents and communications regarding any direct or indirect monetary benefit You have derived from the Companies or the Trust, including but not limited to (1) cash payments to Yasemin in the form of salary, gifts,bonuses, dividends, distributions, or reimbursements; and (2) expenses incurred by the Companies or the Trust on behalf of You or Yasemin, such as living, food, clothing, or travel expenses. REQUEST NO. 22 All documents and communications regarding any living accommodations provided to You by the Companies, including but not limited to any apartments, homes, townhomes, or hotels in which You stayed or are staying. REQUEST NO. 23 All documents and communications regarding the decision to file the Complaint in the instant Action or sue the Defendants. (iftheitem that thisAttachment concems ismade under penalty of pedury, allstatements in this Page 2 or 2 Attachment are made under penalty of perjury.) FormApprovedforOptionalUse "°° * ATTACHMENT trcTådRWtoEei to Judicial Council Form FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 471 RECEIVED NYSCEF: 06/15/2022 MC-025 CASEWMBER: SHORT TITLE: - Yasemin Tekiner, etc. v. Bremen House Inc., et al. Index No.: 657193/2020 ATTACHMENT (Number): 4 (ThisAttachment may be used with any JudicialCouncil form.) All parties are represented by counsel. Counsel for Plaintiff Yasemin Tekiner: Evan Mandel Mandel Bhandari LLP 80 Pine Street, 33rd Floor New York, NY 10005 (212) 269-5600 (646) 964-6667 (fax) em@mandelbhandari.com Counsel for Defendants 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: Judith A. Archer Victoria V. Corder Sean M. Topping Norton Rose Fulbright US LLP 1301 Avenue of the Americas New York, New York 10019-6022 (212) 318-3000 (212) 318-3400 (fax) judith.archer@nortonrosefulbright.com victoria.corder@nortonrosefulbright.com sean.topping@nortonrosefulbright.com (If the item that thisAttachment concems ismade under penalty of pedury, allstatements inthis Page 1 of Attachment are made under penalty of pedury.) (Add pages as required) Fo p ed t a se ""°°'6"*"S" ATTACHMENT MC-025[Rev.July1,2009] to Judicial Council Form FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 471 RECEIVED NYSCEF: 06/15/2022 MC-025 CASEMBER: SHORT TITLE: - Yasemin Tekiner, etc. v. Bremen House Inc., et al. Index No.: 657193/2020 ATTACHMENT (Number): 6 (ThisAttachment may be used with any JudicialCouncil form.) INSTRUCTIONS In addition to the CPLR, Commercial Division Rules, Local Rules, and governing law please respond in accordance with the following instructions: 1. Each Request shall be answered completely, separately, and fully in writing in accordance with CPLR Article 31. 2. In responding to the Requests, You shall produce all responsive documents that are in Your possession, custody, or control or in the possession, custody, or control of Your, agents, employees, attorneys, accountants, financial advisors, or other representatives. A document shall be deemed to be within Your control if You have the right to secure the document or a copy of the document from another person having possession or custody of the document. 3. If You are unable to respond to any Request, after exercising due diligence to secure the requested information, so state, and explain why the Request cannot be answered. 4. If no documents exist that are responsive to a particular Request, so state in writing. 5. If an objection is made to a Request, state allgrounds upon which the objection is based and, if applicable, the extent to which the Request will nonetheless be complied with. 6. If any document is currently not available and is in the possession of another party, identify the person or persons from whom the document may be obtained. 7. If any document which forms a part of or the entire basis for any response to a Request has been destroyed or lost, for each such document state when itwas destroyed or lost, identify the person who destroyed or lost the document, and the person who directed that itbe destroyed. In addition, detail the reasons for the destruction, describe the nature of the document, identify the person(s) who created, sent and received the document, state the date of the document, and state in as much detail as possible the contents of the document. (If the item that thisAttachment concems ismade under penalty of pedury, allstatements inthis Page 1 of 6 Attachment are made under penalty of pedury.) (Add pages as required) Form p ed t a se ""°"*"**S" ATTACHMENT MC-025[Rev.July1,2009] to Judicial Council Form FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 471 RECEIVED NYSCEF: 06/15/2022 MC-025 CASEMBER: SHORT TITLE: Yasemin Tekiner, etc. v. Bremen House Inc., et al. Index No.: 657193/2020 ATTACHMENT (Number): 6 (ThisAttachment may be used with any JudicialCouncil form.) INSTRUCTIONS (continued) 8. Each document is to be produced, along with all drafts thereof or attachments thereto, in itsentirety, without abbreviation or redaction, unless withheld by You on the basis of a claim of privilege. If any portion of a document is responsive to a Request, produce the entire document, including all attachments, enclosures, "post-it"-type notes, and any other matter physically attached to the document, whether by paper clip or any other manner. If documents responsive to a Request are normally kept in a fileor folder, also produce that file or folder with any labels attached thereto and identify the company, division, department, and/or individual from whose files the document is being produced. If responsive documents are segregated or separated from other documents, whether by inclusion in binders, files,sub-files, or by use of dividers, tabs or any other method, produce such documents in that form. 9. Copies of any document responsive to any Request that is not an identical duplicate of the original document because of markings, handwritten notations, or any other difference should be considered separate documents and should be produced. English translations or partial translations of foreign language documents should also be considered separate documents. 10. Where a claim of privilege (which term, as used herein, includes claims that requested information is protected from discovery under the attorney-client privilege, work product doctrine or trialpreparation material) is asserted in objecting to any document request or portion thereof, and any requested documents are withheld on the basis of such assertion, You shall set forth completely the grounds for the asserted privilege in a privilege log. You shall identify as to each communication or document: (a) itsdate; (b) itsauthor(s); (c) its recipient(s); (d) the number of pages and attachments or appendices; (e) itspresent custodian (f) itssubject matter; (g) a description of itscontent; (h) and the legal basis upon which You claim privilege. To the extent only a portion of a document is privileged, the non-privileged portion should be produced and any redactions should be clearly marked and logged. Privileged documents should be logged separately, and non-privileged portions of documents or attachments to privileged documents should be produced. 11. These Requests require production of copies of all electronically stored information in the form of single-page TIFF images with accompanying text extraction and searchable OCR, together with load files containing the following metadata at a minimum: BEGBATES, ENDBATES, BEGATTACH, ENDATTACH, FILENAME, SUBJECT, DATESENT, DATELASTMOD, DATECREATED, CUSTODIAN, AUTHOR, FROM, TO, CC, BCC, MD5HASH, and TEXTPATH. Where a custodian is a departmental file or network drive shared by a group of users, or a FROM, TO, CC, or BCC is a group distribution list,You shall identify allpersons with access to such files, drives or copied on such distribution list. Additionally, all Excel (or other electronic spreadsheet files) and all PowerPoint (or other electronic slideshow files), including any such files attached to emails, shall be produced in their native format. Defendants reserve the right to request production in native format of any other documents produced in response to these Requests. (If the item that thisAttachment concems ismade under penalty of pedury, allstatements inthis Page 2 or 6 Attachment are made under penalty of pedury.) dd n m ) Form p ed t a se =®°*" "S" ATTACHMENT MC-025[Rev.July1,2009] to Judicial Council Form FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 471 RECEIVED NYSCEF: 06/15/2022 MC-025 CASEWMBER: SHORT TITLE: - Yasemin Tekiner, etc. v. Bremen House Inc., et al. Index No.: 657193/2020 ATTACHMENT (Number): 6 (ThisAttachment may be used with any JudicialCouncil form.) INSTRUCTIONS (continued) 12. Unless a different time frame is specified in a particular request, these Requests seek documents created, modified, received, or sent during the period from January 1, 2015 to the present (the "Relevant Period"). 13. Pursuant to CPLR 3101(h), these document requests are deemed to be continuing. If Plaintiff or its representatives receive or acquire any information and/or documents responsive to these Requests after serving responses to these Requests, such information and/or documents should be added to the responses to these Defendants' Requests and served upon counsel. (If the item that thisAttachment concems ismade under penalty of pedury, allstatements inthis Page 3 or 6 Attachment are made under penalty of pedury.) (Add pa n r imd) Fo p ed t a se "=®"*"*"S" ATTACHMENT MC-025[Rev.July1,2009] to Judicial Council Form FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 471 RECEIVED NYSCEF: 06/15/2022 MC-025 CASEMBER: SHORT TITLE: - Yasemin Tekiner, etc. v. Bremen House Inc., et al. Index No.: 657193/2020 ATTACHMENT (Number): 6 (ThisAttachment may be used with any JudicialCouncil form.) DEFINITIONS As used in these Requests, the following terms shall have the meanings set forth below: "Action" 1. means Yasemin Tekiner v. Bremen House, Inc., Bremen House Texas, Inc., German News German News 254 - 258 W. 35th St. Berrin Gonca and Company, Inc., Texas, Inc., LLC, Tekiner, Tekiner, Billur Akipek, Index No. 657193/2020, Supreme Court of the State of New York, County of New York (Cohen, J.). "Berrin" 2. means Defendant Berrin Tekiner, as well as her agents, employees, attorneys, accountants, financial advisors, or other representatives. "Billur" 3. means Defendant Billur Akipek, as well as her agents, employees, attorneys, accountants, financial advisors, or other representatives. House" 4. "Bremen means Defendant Bremen House, Inc. Texas" 5. "Bremen House means Defendant Bremen House Texas, Inc. "Communication" 6. means, without limitation, any written or electronic transmission of information, including but not limited to any emails, text messages, written correspondence, memorandum, facsimile, telephone conversation, video conference, posts or messages from social media platforms including, but not limited to, Facebook, Instagram, LinkedIn, and Twitter, messages sent through applications such as Instagram, Facebook, LinkedIn, and WhatsApp, or any other electronic or computer transmission. "Companies" Defendants" 7. or "Company means Bremen House, Bremen House Texas, German News, German News 254 - 258 W. 35th St. Texas, "Complaint" 8. means the Amended Verified Complaint, filed in the Action, on January 25, 2021 (Dkt. 86), which is annexed hereto. "Defendants" 9. refers collectively to the Company Defendants and Individual Defendants. (If the item that thisAttachment concems ismade under penalty of pedury, allstatements inthis Page 4 of 6 Attachment are made under penalty of pedury.) Form p ed t a se "S" ATTACHMENT MC-025[Rev.July1,2009] to Judicial Council Form FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 471 RECEIVED NYSCEF: 06/15/2022 MC-025 CASEMBER: SHORT TITLE: Yasemin Tekiner, etc. v. Bremen House Inc., et al. Index No.: 657193/2020 ATTACHMENT (Number): 6 (ThisAttachment may be used with any JudicialCouncil form.) DEFINITIONS (continued) "Document" 10. is used in the broadest sense permissible under the CPLR and includes, without limitation, all objects tangible or intangible, from which information may be derived, however reproduced, including any recording in any tangible form of any information, whether handwritten, typed, stored electronically, stored on computer disks, tapes, or databases, or otherwise stored or reproduced, whether sent or received or neither, whether within the actual or constructive possession, custody, or control of any agent, employee, consultant, accountant or any other person, including drafts and copies bearing notations and marks not found in the original. For the avoidance of doubt, this includes emails, text messages, writings, drawings, graphs, charts, photographs, sound recordings, voicemails, images, and other data or data compilations, posts or messages from social media platforms including, but not limited to, Facebook, Instagram, LinkedIn, and Twitter, and messages sent through applications such as Instagram, Facebook, LinkedIn, and WhatsApp. Sale" Companies' 11. "Extell refers to the attempt to sell the properties at 1653/1659 1st Avenue and 349/361 East 86th Street, 218/220 East 86th Street a/k/a 217/219 East 85th Street, 300/302 East 86th Street a/k/a 1656 2nd Avenue, 304 East 86th Street, and 128 East 91st Street a/k/a 1372/1378 Lexington Avenue, New York, NY. News" 12. "German means Defendant German News Company, Inc. Texas" 13. "German News means Defendant German News Texas Company, Inc. "Gonca" 14. means Defendant Gonca Tekiner, as well as her agents, employees, attorneys, accountants, financial advisors, or other representatives. "Including" 15. shall mean including, without limitation, the specific matter, documents or electronically stored information described. Defendants" 16. "Individual means Defendants Berrin Tekiner, Gonca Tekiner, and Billur Akipek, as well as any of their agents, employees, attorneys, accountants, financial advisors, or other representatives. Affidavit" 17. "Reply means the Reply Affidavit of Yasemin Tekiner, filed in the Action, on January 21, 2021 (Dkt. 41). Agreement" 18. "Trust refers to the Yasemin Tekiner 2011 Descendants Trust Agreement. St." - 19. "W. 35th means Defendant 254 258 W. 35th St. LLC. (If the item that thisAttachment concems ismade under penalty of pedury, allstatements inthis Page 5 or 6 Attachment are made under penalty of pedury.) dd n r imd) Form p ed t a se =®°*"*ª 9" ATTACHMENT MC-025[Rev.July1,2009] to Judicial Council Form FILED: NEW YORK COUNTY CLERK 06/15/2022 09:28 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 471 RECEIVED NYSCEF: 06/15/2022 MC-025 CASEMBER: SHORT TITLE: - Yasemin Tekiner, etc. v. Bremen House Inc., et al. Index No.: 657193/2020 ATTACHMENT (Number): 6 (ThisAttachment may be used with any JudicialCouncil form.) DEFINITIONS (continued) "Yasemin," 20. refers to Plaintiff Yasemin Tekiner and/or any persons acting or purporting to act on behalf of Plaintiff. Trust" 21. "Yasemin refers to the Yasemin Tekiner 2011 Descendants Trust. "You" "Your" 22. and refer to Lisa Rubin and/or any persons acting or purporting to act on behalf of You. "Zeynep" 23. means non-party Zeynep Tekiner, as well as her agents, employees, attorneys, accountants, financial advisors, or other representatives. Exchange" 24. "1031 refers to the like-kind exchange under IRC Section 1031 in which the Companies intend to engage using the proceeds from the Extell Sale. to," to," to," "regarding," "concerning" 25. The phrases "relating "related "referring and/or means directly or indirectly, in whole or in part, constituting, evidencing, showing, recording, substantiating, describing, analyzing, summarizing, identifying, reflecting, arising from, connected with, commenting on, responding to, or in any way having a logical or factual connection with the matter at issue, in any way, directly or indirectly. concerning" Without limiting the foregoing definition, "documents or communications a particular subject matter include all documents or communications that comprise, record, memorialize, discuss, evaluate, report