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 11/28/2022 03:37 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 872 RECEIVED NYSCEF: 11/28/2022
Michele Kahn
From: Mojica, Jessica
Sent: Wednesday, October 26, 2022 6:03 PM
To: Zeynep Tekiner
Cc: Michele Kahn; Mojica, Jessica
Subject: RE: Zeynep Tekiner Trust
Categories: TO DO
Dear Mrs. Tekiner:
I hope allis well with you. We are in receipt of the Court Order issued by the Supreme Court of the state of New York,
County of New York granting the removal of Billur Akipek as a member of the Trust Committee in your trust. Before
taking any actions at the direction of the Trust Committee, we feel itnecessary to engage Delaware Counsel regarding
appropriate compliance with the Order and any appeals. Pursuant to Article SEVENTEENTH, Subsections (B) and (C) of
the trust agreement, allexpenses related to the engagement of Delaware counsel by us as Trustee in connection with
the performance of our duties as a fiduciary are considered trust expenses. Given the trust has limited liquidityat each
trust level,we would request that one or more of the underlying assets of the trusts provide liquidity to cover the
payment of these expenses. We believe a reserve of $25K is appropriate at this time.
Please respond with your acknowledgement of thisemail and let me know ifthere are any concerns with providing
liquidityto the trusts by any of the entities to pay these expected expenses. We would appreciate a response by
Monday, October 315t.
Kind regards,
Jess
B R Y N ..
Jessica Mopca
M A W.R Vice Presideni Team Senior Trust Adnin
Lead.
T R U ST
O: 302.088.7440 J F:302.4215815
A W$ (ORPAN Y
WSFSBankd/btaBrynMawrTrustdoesnotprovidetaxadvice.Accordingly,
anydiscussionof U.S.taxmatterscontainedherein(includinganyattachments)
is notintendedorwrittentobe used,and
cannotbe used,in connection
withthe promotion,marketingor recommendation
by anyoneunaffiliated
withBrynMawrTrustor any ofthemattersaddressedhereinor forthepurposeof avoidingU.S.
tax-relatedpenaltles.Youshouldseekadvicebasedon yourparticularcircumstances
taxadvisor.Thismessagecontahsconfidentialinformallonandis intendedonlyforthe
froman Independent
IndMdualnamed.Ifyouarenotthenamedaddresseeyoushouldnot disseminate,
distributeor copythise-mail.PleasenotifythesenderImmediately
by e-mailIfyouhavereceivedthisemail by mistake
anddeletethise-mailfromyoursystem.
Bryn MawrTrustwill not executetradeorder Instructionssentvia e-rnall Investmentand Insuranceproductsarenot a deposit,not FDICinsured, not Insuredby any federalgovemment
agency,not guaranteedby any bank, and rnaygo down in value.
from: Mojica, Jessica
Sent: Monday, October 24, 2022 10:00 PM
To: Zeynep Tekiner
Cc: Michele Kahn ; Mojica, Jessica
Subject: RE: Zeynep Tekiner Trust
1
FILED: NEW YORK COUNTY CLERK 11/28/2022 03:37 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 872 RECEIVED NYSCEF: 11/28/2022
HI Zeynep,
Thank you for forwarding along. Please give me a time
little to review and get back to you.
Jess
B R Y N
Jessica Mojica
M A W R Via Pre erd few Led Seux MM /enin
T RU ST
O: 302.888Pi40 { F:302321.5815
A W$55 cÆM ANY
anydiscussionat U.S.taxmatterscontainedherein(includnganyattachments)
WSFSBankd/blaBrynMawrTrustdoesnotprovidetaxadvice.Accordingly, is notintendedorwrittento be used,and
withthe promotion,marketingor recommendation
cannotbe used,in connection by anyoneunaffiliated
withBrynMawrTrustor any ofthemattersaddressedhereinorforthepurposeof avoidingU.S.
taxadvisor.ThismessagecontainscanlidentialInformation
tax-relatedpenaitles.Youshouldasekadvicebasedonyourparticularcircumstances
fromanindependent andis intendedonlyforthe
distributeor copythisemall. PleasenotifythesenderImmediately
Ifyouarenotthenamedaddresseeyoushouldnot disseminate,
Individua1named, by e-maiiifyouhavereceivedthise-mailby mistake
f
romyoursystem.
anddeletethise-mait
Bryn MawrTrustwill not executetradeorder instructionssentvia e-mail.Investrnentandinsuranceproductsarenot a deposit,not FDICinsured,not insuredby any federalgovemment
agency,not guaranteedby anybank, and may go down In value.
From: Zeynep Tekiner
Sent: Monday, October 24, 2022 1:51 PM
To: Mojica, Jessica
Cc: Michele Kahn
Subject: Zeynep Tekiner Trust
EXTERNAL EMAIL: Do not click any links or open any attachments unless you trust the sender and know the content is
safe. Please forward any suspicious emails to phish@wsfsbank.com
Jessica. As you may know, on October 19, 2022, the Honorable Joel M. Cohen, J.S.C.,issued a Decision & Order which
removed BillurAkipek as a member of the Trust Committee of my Trust and leftme as the sole member of the Trust
Committee of my Trust.
Attached is a formal letter of direction regarding the indemnification and advancement of fees and regarding other
matters.
In addition, since I am now the sole member of the Trust Committee for my Trust, I would liketo speak to you next week
regarding the future of my trust. Would you please let me know what dates and times you are available?
Thank you,
Zeynep Tekiner
2
Preview
FILED: NEW YORK COUNTY CLERK 11/28/2022 03:37 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 872 RECEIVED NYSCEF: 11/28/2022 Michele Kahn From: Mojica, Jessica Sent: Wednesday, October 26, 2022 6:03 PM To: Zeynep Tekiner Cc: Michele Kahn; Mojica, Jessica Subject: RE: Zeynep Tekiner Trust Categories: TO DO Dear Mrs. Tekiner: I hope allis well with you. We are in receipt of the Court Order issued by the Supreme Court of the state of New York, County of New York granting the removal of Billur Akipek as a member of the Trust Committee in your trust. Before taking any actions at the direction of the Trust Committee, we feel itnecessary to engage Delaware Counsel regarding appropriate compliance with the Order and any appeals. Pursuant to Article SEVENTEENTH, Subsections (B) and (C) of the trust agreement, allexpenses related to the engagement of Delaware counsel by us as Trustee in connection with the performance of our duties as a fiduciary are considered trust expenses. Given the trust has limited liquidityat each trust level,we would request that one or more of the underlying assets of the trusts provide liquidity to cover the payment of these expenses. We believe a reserve of $25K is appropriate at this time. Please respond with your acknowledgement of thisemail and let me know ifthere are any concerns with providing liquidityto the trusts by any of the entities to pay these expected expenses. We would appreciate a response by Monday, October 315t. Kind regards, Jess B R Y N .. Jessica Mopca M A W.R Vice Presideni Team Senior Trust Adnin Lead. T R U ST O: 302.088.7440 J F:302.4215815 A W$ (ORPAN Y WSFSBankd/btaBrynMawrTrustdoesnotprovidetaxadvice.Accordingly, anydiscussionof U.S.taxmatterscontainedherein(includinganyattachments) is notintendedorwrittentobe used,and cannotbe used,in connection withthe promotion,marketingor recommendation by anyoneunaffiliated withBrynMawrTrustor any ofthemattersaddressedhereinor forthepurposeof avoidingU.S. tax-relatedpenaltles.Youshouldseekadvicebasedon yourparticularcircumstances taxadvisor.Thismessagecontahsconfidentialinformallonandis intendedonlyforthe froman Independent IndMdualnamed.Ifyouarenotthenamedaddresseeyoushouldnot disseminate, distributeor copythise-mail.PleasenotifythesenderImmediately by e-mailIfyouhavereceivedthisemail by mistake anddeletethise-mailfromyoursystem. Bryn MawrTrustwill not executetradeorder Instructionssentvia e-rnall Investmentand Insuranceproductsarenot a deposit,not FDICinsured, not Insuredby any federalgovemment agency,not guaranteedby any bank, and rnaygo down in value. from: Mojica, Jessica Sent: Monday, October 24, 2022 10:00 PM To: Zeynep Tekiner Cc: Michele Kahn ; Mojica, Jessica Subject: RE: Zeynep Tekiner Trust 1 FILED: NEW YORK COUNTY CLERK 11/28/2022 03:37 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 872 RECEIVED NYSCEF: 11/28/2022 HI Zeynep, Thank you for forwarding along. Please give me a time little to review and get back to you. Jess B R Y N Jessica Mojica M A W R Via Pre erd few Led Seux MM /enin T RU ST O: 302.888Pi40 { F:302321.5815 A W$55 cÆM ANY anydiscussionat U.S.taxmatterscontainedherein(includnganyattachments) WSFSBankd/blaBrynMawrTrustdoesnotprovidetaxadvice.Accordingly, is notintendedorwrittento be used,and withthe promotion,marketingor recommendation cannotbe used,in connection by anyoneunaffiliated withBrynMawrTrustor any ofthemattersaddressedhereinorforthepurposeof avoidingU.S. taxadvisor.ThismessagecontainscanlidentialInformation tax-relatedpenaitles.Youshouldasekadvicebasedonyourparticularcircumstances fromanindependent andis intendedonlyforthe distributeor copythisemall. PleasenotifythesenderImmediately Ifyouarenotthenamedaddresseeyoushouldnot disseminate, Individua1named, by e-maiiifyouhavereceivedthise-mailby mistake f romyoursystem. anddeletethise-mait Bryn MawrTrustwill not executetradeorder instructionssentvia e-mail.Investrnentandinsuranceproductsarenot a deposit,not FDICinsured,not insuredby any federalgovemment agency,not guaranteedby anybank, and may go down In value. From: Zeynep Tekiner Sent: Monday, October 24, 2022 1:51 PM To: Mojica, Jessica Cc: Michele Kahn Subject: Zeynep Tekiner Trust EXTERNAL EMAIL: Do not click any links or open any attachments unless you trust the sender and know the content is safe. Please forward any suspicious emails to phish@wsfsbank.com Jessica. As you may know, on October 19, 2022, the Honorable Joel M. Cohen, J.S.C.,issued a Decision & Order which removed BillurAkipek as a member of the Trust Committee of my Trust and leftme as the sole member of the Trust Committee of my Trust. Attached is a formal letter of direction regarding the indemnification and advancement of fees and regarding other matters. In addition, since I am now the sole member of the Trust Committee for my Trust, I would liketo speak to you next week regarding the future of my trust. Would you please let me know what dates and times you are available? Thank you, Zeynep Tekiner 2