On December 21, 2020 a
Exhibit,Appendix
was filed
involving a dispute between
Yasemin Tekiner,
Yasemin Tekiner
In Her Individual Capacity, As A Beneficiary And A Trustee Of The Yasemin Tekiner 2011 Descendants Trust And Derivatively As A Holder Of Equitable Interests In A Shareholder Or A Member Of The Company Defendants,
and
254-258 W. 35Th St. Llc,
Berrin Tekiner,
Billur Akipek
In Her Capacity As A Trustee Of The Yasemin Tekiner 2011 Descendants Trust,
Bremen House Inc.,
Bremen House Texas, Inc.,
German News Company, Inc.,
German News Texas, Inc.,
Gonca Tekiner,
Zeynep Tekiner,
for Commercial Division
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 06/29/2022 09:01 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 606 RECEIVED NYSCEF: 06/29/2022
EXHIBIT A
FILED: NEW YORK COUNTY CLERK 06/29/2022 09:01 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 606 RECEIVED NYSCEF: 06/29/2022
1
1 SUPREME COURT OF THE STATE OF NEW YORK
2 COMMERCIAL DIVISION, NEW YORK COUNTY
3 Index No. 657193/20
4 ------------------------------------------------x
5 YASEMIN TEKINER,
in her individual capacity, as a beneficiary and
6 a Trustee of The Yasemin Tekiner 2011
Descendants Trust and derivatively as a holder
7 of equitable interests in a shareholder or a
member of the Company Defendants,
8 Plaintiff,
9 - against –
10 BREMEN HOUSE INC., BREMEN HOUSE TEXAS,
INC., GERMAN NEWS COMPANY, INC., GERMAN
11 NEWS TEXAS, INC., 254 - 258 W. 35TH ST. LLC,
BERRIN TEKINER, GONCA TEKINER, and
12 BILLUR AKIPEK, in her capacity as a Trustee of
The Yasemin Tekiner 2011 Descendants Trust,
13 Defendants.
14 ------------------------------------------------x
15 Remote Deposition
16 December 22, 2021
17 9:37 a.m.
18
19 DEPOSITION of ZEYNEP TEKINER, taken by
20 Plaintiff, via Zoom, before Eleanor Greenhouse, a
21 Shorthand Reporter and Notary Public within and
22 for the State of New York.
23
GREENHOUSE REPORTING, INC.
24 313 West 118th Street - Unit 4C
New York, New York 10026
25 (212) 279-5108
Greenhouse Reporting, Inc. (212) 279-5108
www.GreenhouseReporting.com
FILED: NEW YORK COUNTY CLERK 06/29/2022 09:01 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 606 RECEIVED NYSCEF: 06/29/2022
2
1 A P P E A R A N C E S:
2 FOLEY HOAG LLP
3 Attorneys for Plaintiff
1301 Avenue of the Americas
4 New York, New York 10019
5 STEPHEN P. YOUNGER, ESQ.
6
7 MANDEL BHANDARI LLP
8 Attorneys for Plaintiff
80 Pine Street, 33rd Floor
9 New York, New York 10005
10 BY: EVAN MANDEL, ESQ.
11 DONALD CONKLIN, ESQ.
12
13 NORTON ROSE FULBRIGHT US LLP
14 Attorneys for Defendants
1301 Avenue of the Americas
15 New York, New York 10019-6022
16 BY: JUDITH A. ARCHER, ESQ.
17 VICTORIA V. CORDER, ESQ.
18
19 SCHOEMAN UPDIKE KAUFMAN & GERBER LLP
20 Attorneys for the Witness
551 Fifth Avenue, 12th Floor
21 New York, New York 10176
22 BY: BETH L. KAUFMAN, ESQ.
23
24 ALSO PRESENT:
25 GEORGE LIBBARES, Videographer
Greenhouse Reporting, Inc. (212) 279-5108
www.GreenhouseReporting.com
FILED: NEW YORK COUNTY CLERK 06/29/2022 09:01 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 606 RECEIVED NYSCEF: 06/29/2022
322
1 answers; is that correct?
2 MS. ARCHER: Object to the form.
3 A. That's correct.
4 Q. And is one of the things you asked
5 him whether Billur, who was one of your trustees,
6 had a conflict? Did you ask him that?
7 A. Bahar brought that up, she did, yes.
8 MS. ARCHER: Object to the form.
9 Q. Did he say he would look into it?
10 MS. ARCHER: The same objection.
11 A. I think he said -- he might have
12 said he will look into it. He didn't really --
13 you know, a lot of thought.
14 Q. So he didn't give you an adequate
15 answer to that question; did he?
16 MS. KAUFMAN: Objection.
17 MS. ARCHER: Object to the form.
18 Mischaracterizes the testimony.
19 A. No, he didn't.
20 MR. YOUNGER: Let's go back to what
21 was Tab 68 which is Plaintiff's Exhibit
22 something or other. It's Tekiner 2717.
23 Can you find it Evan?
24 MR. MANDEL: We're up to Exhibit 49
25 at this point.
Greenhouse Reporting, Inc. (212) 279-5108
www.GreenhouseReporting.com
FILED: NEW YORK COUNTY CLERK 06/29/2022 09:01 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 606 RECEIVED NYSCEF: 06/29/2022
392
1 C E R T I F I C A T E
2 STATE OF NEW YORK )
3 :
4 COUNTY OF NEW YORK)
5 I, ELEANOR GREENHOUSE, a Shorthand
6 Reporter and Notary Public within and for the
7 State of New York, do hereby certify:
8 That, ZEYNEP TEKINER, the witness
9 whose deposition is hereinbefore set forth, was
10 duly sworn by me and that such deposition is a
11 true record of the testimony given by such
12 witness.
13 I further certify that I am not
14 related to any of the parties to this action by
15 blood or marriage, and that I am in no way
16 interested in the outcome of this matter.
17 IN WITNESS WHEREOF, I have hereunto
18 set my hand this 2nd day of January, 2022.
19
20
21 ______________________________
22 ELEANOR GREENHOUSE
23
24
25
Greenhouse Reporting, Inc. (212) 279-5108
www.GreenhouseReporting.com
Preview
FILED: NEW YORK COUNTY CLERK 06/29/2022 09:01 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 606 RECEIVED NYSCEF: 06/29/2022 EXHIBIT A FILED: NEW YORK COUNTY CLERK 06/29/2022 09:01 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 606 RECEIVED NYSCEF: 06/29/2022 1 1 SUPREME COURT OF THE STATE OF NEW YORK 2 COMMERCIAL DIVISION, NEW YORK COUNTY 3 Index No. 657193/20 4 ------------------------------------------------x 5 YASEMIN TEKINER, in her individual capacity, as a beneficiary and 6 a Trustee of The Yasemin Tekiner 2011 Descendants Trust and derivatively as a holder 7 of equitable interests in a shareholder or a member of the Company Defendants, 8 Plaintiff, 9 - against – 10 BREMEN HOUSE INC., BREMEN HOUSE TEXAS, INC., GERMAN NEWS COMPANY, INC., GERMAN 11 NEWS TEXAS, INC., 254 - 258 W. 35TH ST. LLC, BERRIN TEKINER, GONCA TEKINER, and 12 BILLUR AKIPEK, in her capacity as a Trustee of The Yasemin Tekiner 2011 Descendants Trust, 13 Defendants. 14 ------------------------------------------------x 15 Remote Deposition 16 December 22, 2021 17 9:37 a.m. 18 19 DEPOSITION of ZEYNEP TEKINER, taken by 20 Plaintiff, via Zoom, before Eleanor Greenhouse, a 21 Shorthand Reporter and Notary Public within and 22 for the State of New York. 23 GREENHOUSE REPORTING, INC. 24 313 West 118th Street - Unit 4C New York, New York 10026 25 (212) 279-5108 Greenhouse Reporting, Inc. (212) 279-5108 www.GreenhouseReporting.com FILED: NEW YORK COUNTY CLERK 06/29/2022 09:01 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 606 RECEIVED NYSCEF: 06/29/2022 2 1 A P P E A R A N C E S: 2 FOLEY HOAG LLP 3 Attorneys for Plaintiff 1301 Avenue of the Americas 4 New York, New York 10019 5 STEPHEN P. YOUNGER, ESQ. 6 7 MANDEL BHANDARI LLP 8 Attorneys for Plaintiff 80 Pine Street, 33rd Floor 9 New York, New York 10005 10 BY: EVAN MANDEL, ESQ. 11 DONALD CONKLIN, ESQ. 12 13 NORTON ROSE FULBRIGHT US LLP 14 Attorneys for Defendants 1301 Avenue of the Americas 15 New York, New York 10019-6022 16 BY: JUDITH A. ARCHER, ESQ. 17 VICTORIA V. CORDER, ESQ. 18 19 SCHOEMAN UPDIKE KAUFMAN & GERBER LLP 20 Attorneys for the Witness 551 Fifth Avenue, 12th Floor 21 New York, New York 10176 22 BY: BETH L. KAUFMAN, ESQ. 23 24 ALSO PRESENT: 25 GEORGE LIBBARES, Videographer Greenhouse Reporting, Inc. (212) 279-5108 www.GreenhouseReporting.com FILED: NEW YORK COUNTY CLERK 06/29/2022 09:01 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 606 RECEIVED NYSCEF: 06/29/2022 322 1 answers; is that correct? 2 MS. ARCHER: Object to the form. 3 A. That's correct. 4 Q. And is one of the things you asked 5 him whether Billur, who was one of your trustees, 6 had a conflict? Did you ask him that? 7 A. Bahar brought that up, she did, yes. 8 MS. ARCHER: Object to the form. 9 Q. Did he say he would look into it? 10 MS. ARCHER: The same objection. 11 A. I think he said -- he might have 12 said he will look into it. He didn't really -- 13 you know, a lot of thought. 14 Q. So he didn't give you an adequate 15 answer to that question; did he? 16 MS. KAUFMAN: Objection. 17 MS. ARCHER: Object to the form. 18 Mischaracterizes the testimony. 19 A. No, he didn't. 20 MR. YOUNGER: Let's go back to what 21 was Tab 68 which is Plaintiff's Exhibit 22 something or other. It's Tekiner 2717. 23 Can you find it Evan? 24 MR. MANDEL: We're up to Exhibit 49 25 at this point. Greenhouse Reporting, Inc. (212) 279-5108 www.GreenhouseReporting.com FILED: NEW YORK COUNTY CLERK 06/29/2022 09:01 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 606 RECEIVED NYSCEF: 06/29/2022 392 1 C E R T I F I C A T E 2 STATE OF NEW YORK ) 3 : 4 COUNTY OF NEW YORK) 5 I, ELEANOR GREENHOUSE, a Shorthand 6 Reporter and Notary Public within and for the 7 State of New York, do hereby certify: 8 That, ZEYNEP TEKINER, the witness 9 whose deposition is hereinbefore set forth, was 10 duly sworn by me and that such deposition is a 11 true record of the testimony given by such 12 witness. 13 I further certify that I am not 14 related to any of the parties to this action by 15 blood or marriage, and that I am in no way 16 interested in the outcome of this matter. 17 IN WITNESS WHEREOF, I have hereunto 18 set my hand this 2nd day of January, 2022. 19 20 21 ______________________________ 22 ELEANOR GREENHOUSE 23 24 25 Greenhouse Reporting, Inc. (212) 279-5108 www.GreenhouseReporting.com