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 10/25/2022 03:01 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 830 RECEIVED NYSCEF: 10/25/2022
EXHIBIT 16
FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 830 RECEIVED NYSCEF: 10/25/2022
1
1
2 CONSENT: By opening and opting for this rough
draft transcript, you have agreed: (1) To pay the
3 fee associated with such rough draft request, (2)
To purchase the final transcript at the
4 agreed-upon rate; (3) Not to furnish this rough
draft transcript, either in whole or in part, on
5 disk or hard copy, via modem or computer, or by
any other means, to any party or counsel to the
6 case.
7
DISCLAIMER: This uncertified rough draft
8 transcript is unedited and uncertified and may
contain un-translated words, a note made by the
9 reporter, a misspelled proper name, and/or word
combinations that do not make sense. All such
10 entries will be corrected on the final certified
transcript which we will deliver to you in
11 accordance with your requested delivery
arrangements. Due to the need to correct entries
12 prior to certification, this rough draft
transcript can be used only for the purposes of
13 annotating counsel's notes and cannot be used or
cited in any court proceedings or to distribute
14 to other parties in the case who have not
purchased a transcript copy
15
16 VOLUME II
17 GONCA TEKINER CHELSEA
18 REPORTED BY MICHELE MOSKOWITZ
19 MAGNA LEGAL SERVICES
20 EXAMINATION BY
21 MR. YOUNGER:
22 MR. YOUNGER: We're back on the
23 record.
24 Q. Is it okay if I call you Gonca?
25 A. Sure.
2
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2 Q. Gonca, you understand you're still
3 under oath?
4 A. Yes.
5 Q. Did you talk to anybody during the
6 break?
7 A. Yes.
8 Q. Who?
9 A. Meghan, Brian, my mother.
10 Q. What did you talk --
11 A. Just about kids and food, people's
12 dietary restrictions.
13 Q. Did you talk to your mother about
14 anything else?
15 A. I don't think so. I mean, we talked
16 about our kids talked about food we talked
17 about -- I think that was it.
18 Q. When did you first --
19 A. Baseball game.
20 Q. When did you first meet Megan?
21 A. When did I first meet Megan? I don't
22 remember sometime this year.
23 Q. Did you meet her before you met
24 Mr. So way?
25 A. I met them at the same time in
3
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FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 830 RECEIVED NYSCEF: 10/25/2022
25 A. I'm not sure how involved she was. I
27
1 ROUGH - GONCA
2 would have been like 10 or 11.
3 Q. Do you have any reason to believe she
4 had involvement before then?
5 A. She might have been interested. I
6 can't speak for her. I don't know.
7 Q. When your dad got Alzheimer's your
8 mom became president, correct?
9 A. I don't know. I don't know what her
10 title was when my got Alzheimer's.
11 Q. She began working in the business
12 full-time, correct?
13 A. She began working in the business I
14 don't know if it was full-time or part-time or
15 what.
16 Q. And around when was that?
17 A. When was that?
18 Q. Yes.
19 A. I don't remember.
20 Q. Late 1980s?
21 A. It's possible.
22 Q. Did your mom buy a house in Scarsdale
23 once your dad got Alzheimer's?
24 MR. MOHLER: Objection. Lacks
25 foundation.
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FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 830 RECEIVED NYSCEF: 10/25/2022
28
1 ROUGH - GONCA
2 Q. You can answer.
3 A. Can you repeat the question, please?
4 MR. YOUNGER: Read it back.
5 (The record is read back by the
6 reporter.)
7 A. I don't know the timing of it so I
8 don't know.
9 Q. When did you move to Scarsdale?
10 A. I don't remember exactly. Maybe
11 1986, 7.
12 Q. What grade were new?
13 A. I had finished sixth grade.
14 Q. And so how old were you? What year
15 would that be?
16 A. What year would what be?
17 Q. That you finished sixth grade?
18 A. '87 I guess.
19 Q. Is that a picture of the house?
20 A. I'm sorry I didn't hear you.
21 Q. Is that a picture of the house that
22 your mom bought?
23 A. I believe so. There was -- it was a
24 copy of the house. I don't know if it's that one
25 or the copy, but it looks like that house.
29
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FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 830 RECEIVED NYSCEF: 10/25/2022
1 ROUGH - GONCA
2 Q. It was owned by the company right?
3 A. I have no idea.
4 Q. I'm going to show you what's been
5 marked Exhibit 330.
6 MR. MOHLER: Steve, is there a
7 question pending?
8 Q. If you look at the top there is texts
9 here in 2015?
10 A. I can't see it.
11 MR. MOHLER: You need to make it
12 bigger.
13 MR. YOUNGER: Go to the second page.
14 Q. Is that your e-mail -- your text I
15 mean?
16 A. I'm still reading it. If you just
17 hold on a second, please. Okay.
18 MR. YOUNGER: Go down to page 329.
19 Q. You say at the top, "I think she's
20 very, very sick. It's the BPD coupled with the
21 narcissism." What did you mean by that?
22 MR. MOHLER: Do you want to read the
23 entire text?
24 THE WITNESS: Yeah, I'm going to read
25 it.
30
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Document Filed Date
October 25, 2022
Case Filing Date
December 21, 2020
Category
Commercial Division
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 830 RECEIVED NYSCEF: 10/25/2022 EXHIBIT 16 FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 830 RECEIVED NYSCEF: 10/25/2022 1 1 2 CONSENT: By opening and opting for this rough draft transcript, you have agreed: (1) To pay the 3 fee associated with such rough draft request, (2) To purchase the final transcript at the 4 agreed-upon rate; (3) Not to furnish this rough draft transcript, either in whole or in part, on 5 disk or hard copy, via modem or computer, or by any other means, to any party or counsel to the 6 case. 7 DISCLAIMER: This uncertified rough draft 8 transcript is unedited and uncertified and may contain un-translated words, a note made by the 9 reporter, a misspelled proper name, and/or word combinations that do not make sense. All such 10 entries will be corrected on the final certified transcript which we will deliver to you in 11 accordance with your requested delivery arrangements. Due to the need to correct entries 12 prior to certification, this rough draft transcript can be used only for the purposes of 13 annotating counsel's notes and cannot be used or cited in any court proceedings or to distribute 14 to other parties in the case who have not purchased a transcript copy 15 16 VOLUME II 17 GONCA TEKINER CHELSEA 18 REPORTED BY MICHELE MOSKOWITZ 19 MAGNA LEGAL SERVICES 20 EXAMINATION BY 21 MR. YOUNGER: 22 MR. YOUNGER: We're back on the 23 record. 24 Q. Is it okay if I call you Gonca? 25 A. Sure. 2 file:///C/Users/mhershewe/Desktop/SCOTT/TEKINER/Sup%20Reply%20Aff%20Ex/GONCA-ROUGH.txt[10/24/2022 10:25:36 PM] FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 830 RECEIVED NYSCEF: 10/25/2022 1 ROUGH - GONCA 2 Q. Gonca, you understand you're still 3 under oath? 4 A. Yes. 5 Q. Did you talk to anybody during the 6 break? 7 A. Yes. 8 Q. Who? 9 A. Meghan, Brian, my mother. 10 Q. What did you talk -- 11 A. Just about kids and food, people's 12 dietary restrictions. 13 Q. Did you talk to your mother about 14 anything else? 15 A. I don't think so. I mean, we talked 16 about our kids talked about food we talked 17 about -- I think that was it. 18 Q. When did you first -- 19 A. Baseball game. 20 Q. When did you first meet Megan? 21 A. When did I first meet Megan? I don't 22 remember sometime this year. 23 Q. Did you meet her before you met 24 Mr. So way? 25 A. I met them at the same time in 3 1 ROUGH - GONCA file:///C/Users/mhershewe/Desktop/SCOTT/TEKINER/Sup%20Reply%20Aff%20Ex/GONCA-ROUGH.txt[10/24/2022 10:25:36 PM] FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 830 RECEIVED NYSCEF: 10/25/2022 25 A. I'm not sure how involved she was. I 27 1 ROUGH - GONCA 2 would have been like 10 or 11. 3 Q. Do you have any reason to believe she 4 had involvement before then? 5 A. She might have been interested. I 6 can't speak for her. I don't know. 7 Q. When your dad got Alzheimer's your 8 mom became president, correct? 9 A. I don't know. I don't know what her 10 title was when my got Alzheimer's. 11 Q. She began working in the business 12 full-time, correct? 13 A. She began working in the business I 14 don't know if it was full-time or part-time or 15 what. 16 Q. And around when was that? 17 A. When was that? 18 Q. Yes. 19 A. I don't remember. 20 Q. Late 1980s? 21 A. It's possible. 22 Q. Did your mom buy a house in Scarsdale 23 once your dad got Alzheimer's? 24 MR. MOHLER: Objection. Lacks 25 foundation. file:///C/Users/mhershewe/Desktop/SCOTT/TEKINER/Sup%20Reply%20Aff%20Ex/GONCA-ROUGH.txt[10/24/2022 10:25:36 PM] FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 830 RECEIVED NYSCEF: 10/25/2022 28 1 ROUGH - GONCA 2 Q. You can answer. 3 A. Can you repeat the question, please? 4 MR. YOUNGER: Read it back. 5 (The record is read back by the 6 reporter.) 7 A. I don't know the timing of it so I 8 don't know. 9 Q. When did you move to Scarsdale? 10 A. I don't remember exactly. Maybe 11 1986, 7. 12 Q. What grade were new? 13 A. I had finished sixth grade. 14 Q. And so how old were you? What year 15 would that be? 16 A. What year would what be? 17 Q. That you finished sixth grade? 18 A. '87 I guess. 19 Q. Is that a picture of the house? 20 A. I'm sorry I didn't hear you. 21 Q. Is that a picture of the house that 22 your mom bought? 23 A. I believe so. There was -- it was a 24 copy of the house. I don't know if it's that one 25 or the copy, but it looks like that house. 29 file:///C/Users/mhershewe/Desktop/SCOTT/TEKINER/Sup%20Reply%20Aff%20Ex/GONCA-ROUGH.txt[10/24/2022 10:25:36 PM] FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 830 RECEIVED NYSCEF: 10/25/2022 1 ROUGH - GONCA 2 Q. It was owned by the company right? 3 A. I have no idea. 4 Q. I'm going to show you what's been 5 marked Exhibit 330. 6 MR. MOHLER: Steve, is there a 7 question pending? 8 Q. If you look at the top there is texts 9 here in 2015? 10 A. I can't see it. 11 MR. MOHLER: You need to make it 12 bigger. 13 MR. YOUNGER: Go to the second page. 14 Q. Is that your e-mail -- your text I 15 mean? 16 A. I'm still reading it. If you just 17 hold on a second, please. Okay. 18 MR. YOUNGER: Go down to page 329. 19 Q. You say at the top, "I think she's 20 very, very sick. It's the BPD coupled with the 21 narcissism." What did you mean by that? 22 MR. MOHLER: Do you want to read the 23 entire text? 24 THE WITNESS: Yeah, I'm going to read 25 it. 30 1 ROUGH - GONCA file:///C/Users/mhershewe/Desktop/SCOTT/TEKINER/Sup%20Reply%20Aff%20Ex/GONCA-ROUGH.txt[10/24/2022 10:25:36 PM]