Exhibit,Appendix: 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 v. Bremen House Inc., German News Company, Inc., Berrin Tekiner, Gonca Tekiner, Billur Akipek in her capacity as a Trustee of the Yasemin Tekiner 2011 Descendants Trust, Zeynep Tekiner (Intervenor Plaintiff)

• 
• 

						
                                
Preview
                                FILED:         NEW     YORK       COUNTY        CLERK        11/28/2022             03:37        PM                 INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   876                                                                                RECEIVED      NYSCEF:     11/28/2022




                                                              Berrin Tekiner, as Grantor of
                                                   The Zeynep  Tekiner  Oza1tin2011  Descendants Tisst
                                                               124 East796       Apt  12-CD
                                                                           Street,
                                                                New  York,New  York  10075

                                                                             Noven1ber 1.1, 2022

                                VIA  EMAIL   AND  PED)

                                Zeynep  Tekmer
                                31 White PlainsRoad
                                Bronxville,New  York 10708

                                       Re:    The Zeynep  Tekiner  Ozaltin2011 Descendarits Trust, dated August  1, 2011

                                De-ar Zeynep

                                       Reference ismade  to The Zeynep  Tekiner Ozaltin20 11 Descendants  Trust,Capitalized
                                terms used but not otherwisc defined herein shallhave the meanings  ascribed tothem  in the
                                Trust.

                                       I write inresponse  toyour         dated
                                                                   letters,     October 30, 2022  and November    10,2022,
                                                         member"  of"
                                purporting toget as "sole           the Trus t Committeeof the Zeynep Tekiner Oraltin 2011
                                DesceridantsTrust. As you know,  this    agreement
                                                                     trust         was  writtenforme  and at my direction
                                                                                                                        as
                                Grantor.

                                       Under ArticleNINTH   (D)(3) ofthe trustagreement,"The  Grantor directsthatthereshall
                                at alltithesbe atleast one independent member   ofthe Trust Committee  qualifiedand  acting
                                under  thisinstrument."  The  Trust  Committee  has no  power  to     absent "at  leastone
                                                                                                  act
                                            member."
                                independen t

                                       ArticleNINTH    (D)(2) demies an  independent niember of the Trust Committee   as"a
                                person who  has no  beneficial        whatsoever in such trust."         Tekiner  isnot an
                                                              interest                           Zeynep
                                independent member  of the TrustCommittee of hertrustbecause Zeynop  hasa beneficialinterest
                                in such  trust. Accordingly, Zeynep's  purported ac'tionsas the sole member   of  the Trust
                                Cormnittee were and are beyond herauthority,invalidand void.

                                                                             Very trulyyours,




                                                                             BerrinTekiner

                                cc:    ChristianaTrust,a Divisionof Wilmington  Savings Pund, PSB
                                       501 Carr noad, Suite100
                                       Wilmington, Delaware  19809                                                                  .
                                       Attn:JessicaMojica
                                       (by Fedex)