Preview
FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1034 RECEIVED NYSCEF: 01/09/2023
EXHIBIT 3
Plaintiff Yasemin Tekiner’s Third Set of Requests for Production
FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1034 RECEIVED NYSCEF: 01/09/2023
SUPREME COURT OF THE STATE OF NEW YORK
COMMERCIAL DIVISION, NEW YORK COUNTY
YASEMIN TEKINER,
Index No. 657193/2020
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 PLAINTIFF’S THIRD
shareholder or a member of the Company REQUEST FOR PRODUCTION
Defendants, OF DOCUMENTS
Plaintiff,
- against -
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, in
her capacity as a Trustee of The Yasemin Tekiner
2011 Descendants Trust,
Defendants.
PLEASE TAKE NOTICE THAT Plaintiff Yasemin Tekiner (“Yasemin”) by and through
its undersigned counsel hereby requires Defendants Bremen House, Inc., German News
Company, Inc., German News Texas, Inc., Berrin Tekiner, Gonca Tekiner and Billur Akipek
(collectively “Defendants”) to produce a copy of the following documents within twenty (20)
days.
DEFINITIONS
As used in these Document Requests, the following terms shall have the meanings set
forth below:
FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1034 RECEIVED NYSCEF: 01/09/2023
1. The term “Companies” shall refer to Defendants Bremen House, Inc., Bremen
House Texas, Inc., German News Company, Inc., German News Texas, Inc., 254 – 258 W. 35th
St. LLC, together with all of their officers, directors, employees, independent contractors, agents,
partners, corporate parents, subsidiaries, affiliates, predecessors, successors, attorneys, and any
persons acting or purporting to act on their behalf.
2. The term “Defendants” shall refer to Defendants Bremen House, Inc., German
News Company, Inc., Berrin Tekiner, Gonca Tekiner, and Billur Akipek, together with all of
their officers, directors, employees, independent contractors, agents, partners, corporate parents,
subsidiaries, affiliates, predecessors, successors, attorneys, and any persons acting or purporting
to act on their behalf.
3. The term “Yasemin” shall refer to Plaintiff Yasemin Tekiner, including partners,
employees, agents, attorneys, and any persons acting or purporting to act on her behalf.
4. The term “you” and “your” shall refer to Defendants, as defined above, and/or
and any persons acting or purporting to act on behalf of any such entity or entities.
5. The term “Trust” shall refer to The Yasemin Tekiner 2011 Descendants Trust.
6. The terms “Counterclaims” and “Counterclaim” means the counterclaims
contained in Defendants’ Verified Amended Answer, Affirmative Defenses, and Counterclaims
to the Verified Amended Complaint.
7. The term “communication” means the transmittal of information (in the form of
facts, ideas, inquiries, or otherwise), and may be written or oral.
8. The term “concerning” means relating to, referring to, reflecting, mentioning,
describing, evidencing, consisting of (in whole or in part), constituting (in whole or in part), or
containing (in whole or in part).
2
FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1034 RECEIVED NYSCEF: 01/09/2023
9. The term “document” shall be construed in its broadest sense and includes the
original and each non-identical copy and any draft of any written, typed, printed, recorded, or
graphical matter, however recorded, stored, produced, or reproduced, or any tangible thing that
in whole or in part illustrates or conveys information, including but not limited to, papers, letters,
notes, books, notebooks, diaries, journals, correspondence, interoffice and intraoffice
communications, memoranda, opinions, reports, evaluations, recommendations, reviews,
analyses, minutes, entries in personal diaries or other record books, summaries, notes, or minutes
of meetings or conversations or communications of any type or description (including, without
limitation, telephone conversations, personal conversations or interviews, meetings, conferences,
negotiations, and investigations), cablegrams, mailgrams, telegrams, facsimiles, electronic mail,
email, telexes, marginal comments or annotations appearing in any document, calendars,
appointment books, pamphlets, books, manuals, directives, bulletins, instructions, agreements,
contracts and other legal documents, news releases, advertisements, ledgers, statistics, surveys,
checks, financial statements, invoices, receipts, work sheets, bills, preliminary drafts and
working papers, drawings, sketches, charts, graphs, plans, specifications, photographs,
phonographs, films, tapes, information recorded on microfilm or microfiche, data and
information on computer-stored or computer-readable media whether tape, disk, diskette, RAM,
or other medium of storage, including but not limited to computer files and electronic mail, and
all other writings, recordings, and data compilations of every description, however denominated,
translated, or described from which information can be obtained or translated, if necessary,
through detective devices into reasonably usable form.
For purpose of the foregoing definition, the term “draft” means any earlier, preliminary,
preparatory, or tentative version of all or part of a document, whether or not such draft was
3
FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1034 RECEIVED NYSCEF: 01/09/2023
superseded by a later draft, and whether or not the terms of the draft are the same as or different
from the terms of the final document. The term “copy” means all versions of a document that is
not in every respect identical to the documents being produced.
INSTRUCTIONS FOR DOCUMENT REQUESTS
1. In answering these Document Requests, you are required to furnish all
information that is available to you or subject to reasonable inquiry by you, including
information in your possession, or the possession of your attorneys, and anyone else subject to
your or your attorney’s control.
2. Electronic records and computerized information must be produced with all
metadata preserved and intact.
3. These Document Requests should always be interpreted to be inclusive rather
than exclusive, including interpreting the following as appropriate: the singular form of a word
as plural, and vice versa; “and” to include “or,” and vice versa; the past tense to include the
present tense, and vice versa.
4. In responding to these Document Requests, preface each answer by restating the
Request to which it is addressed. If a Request has subparts, answer each subpart separately and
in full and do not limit your answer to the Request as a whole. If you are unable to answer a
Request fully, submit as much information as is available, explain why your answer is
incomplete, and state the source or sources from which a complete or more complete answer may
be obtained.
5. In responding to these Document Requests, which are continuing in nature,
Defendants shall produce all responsive documents in their possession, custody or control and shall
promptly supplement and/or correct their responses if they come into possession, custody or control
4
FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1034 RECEIVED NYSCEF: 01/09/2023
of additional documents, or learn or determine additional information, after the service of their
response.
6. If you object, in whole or in part, to any Request, state with specificity the full
objection(s) and the particularized basis for each objection in accordance with Commercial
Division Rule 11-e. To the extent that you object to any portion of a Request, you must respond
to the remaining portion of the Request to which you do not object.
7. If you object to any Request in whole or in part on the basis of any claimed
privilege, provide the following information for each communication or information of which
you claim a privilege:
a. The type of communication or information (e.g. meeting,
phone call, letter, data);
b. The date of the communication or information;
c. The identity of the author of any written communication, the
speaker of any oral communication, or the source of any
information;
d. The identity of all persons who received or had access to any
written communication or information and all persons
present during oral communication;
e. The subject matter of the communications or information;
f. The location of any information, written communications
and recordings of any oral communications; and
g. The factual and legal basis on which you claim privilege.
8. If you object, in whole or in part, to any Document Request, state with specificity the
full objection(s) and the particularized basis for each objection. To the extent that you object to any
portion of a Document Request, you must respond to the remaining portion of the Document Request
to which you do not object.
5
FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1034 RECEIVED NYSCEF: 01/09/2023
9. Electronic records and computerized information must be produced with all metadata
preserved and intact.
10. Unless otherwise specified, the Document Requests refer to the period from January
1, 2011 until the present.
REQUESTS FOR DOCUMENTS
1. All documents concerning any indemnification by or request for indemnification
from one or more of the Companies for any fees, costs, or other amounts relating to the above-
captioned action.
2. All documents concerning Defendants’ preservation, retention, destruction, or
deletion of documents.
3. All documents concerning Defendants’ document retention policies.
4. All documents concerning any instruction to Defendants to retain, preserve, or not
destroy documents.
5. All documents concerning the risk or possibility of litigation concerning
Defendants or Plaintiff.
6. Documents sufficient to show all phones and other electronic devices utilized by
Berrin Tekiner, Gonca Tekiner, Zeynep Tekiner, or Billur Akipek from January 1, 2015 to the
present.
7. Documents sufficient to show the current location of all phones and other
electronic devices utilized by Berrin Tekiner, Gonca Tekiner, Zeynep Tekiner, or Billur Akipek
from January 1, 2015 to the present.
8. All documents concerning the loss, destruction, sale, or disposition of all phones
and other electronic devices utilized by Berrin Tekiner, Gonca Tekiner, Zeynep Tekiner, or
Billur Akipek from January 1, 2015 to the present.
6
FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1034 RECEIVED NYSCEF: 01/09/2023
9. All documents concerning any icloud account utilized or accessed by Berrin
Tekiner, Gonca Tekiner, Zeynep Tekiner, or Billur Akipek from January 1, 2015 to the present.
10. All documents concerning any itunes account utilized or accessed by Berrin
Tekiner, Gonca Tekiner, Zeynep Tekiner, or Billur Akipek from January 1, 2015 to the present.
11. All documents concerning any cloud or other information storage system or
service utilized or accessed by Berrin Tekiner, Gonca Tekiner, Zeynep Tekiner, or Billur Akipek
from January 1, 2015 to the present.
12. All documents concerning any media or other object capable of storing
information utilized or accessed by Berrin Tekiner, Gonca Tekiner, Zeynep Tekiner, or Billur
Akipek from January 1, 2015 to the present.
13. All documents concerning Defendants’ defenses and Counterclaims.
14. All documents concerning the Yasemin Trust Agreement, Certificates of
Incorporation for the Companies, Corporate Bylaws of the Companies, and all other relevant
corporate agreements and amendments.
15. All documents concerning the Companies’ finances, performance, and value
between the time that Berrin Tekiner began running the business and the present.
16. Documents sufficient to show any and all properties owned by the Companies at
the time Berrin Tekiner began “running the business,” as alleged in Counterclaims paragraph 10.
17. Documents sufficient to show any and all properties currently owned by the
Companies.
18. All documents concerning the Companies compliance with and/or violation of
federal, state, and city laws and regulations.
7
FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1034 RECEIVED NYSCEF: 01/09/2023
19. All documents concerning Defendants’ allegation in Counterclaims paragraph 16
that there was an “understanding that Yasemin would regularly return to the Companies offices
to work.”
20. All documents concerning Defendants’ allegation in Counterclaims paragraph 19
that “Yasemin repeatedly interfered in leasing and maintenance of commercial space to the
detriment of the Companies.”
21. All documents concerning Defendants’ allegation in Counterclaims paragraph 19
that Yasemin objected to the retention of a male contractor and insisted that the Companies
select a female contractor.
22. All documents concerning Defendants’ allegation in Counterclaims paragraph 19
that “Yasemin similarly objected to the Companies hiring a male real estate broker.”
23. All documents concerning the determination of how much Yasemin would be
paid in gross wages, salary, pension contributions, pension benefits, and other compensation.
24. All documents concerning any amounts that Defendants paid concerning the Bel
Air house in which Yasemin lives.
25. All documents concerning the renovation(s) alleged in Counterclaims paragraph
27.
26. All documents concerning Defendants’ allegation in Counterclaims paragraph 29
that “[p]rior to 2011, Berrin owned the entire Tekiner family of companies.”
27. All documents concerning any contingent or other rights that any person other
than Berrin Tekiner had in the Tekiner family of companies at any time between 1985 and 2012.
28. All documents concerning the three grantor trusts described in Counterclaims
paragraph 30.
8
FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1034 RECEIVED NYSCEF: 01/09/2023
29. All documents concerning the amending and restating of promissory notes alleged
in Counterclaims paragraphs 31 through 34, including but not limited to all documents
concerning any related IRS audit, examination, or communication.
30. All documents concerning the “disputes” alleged in Counterclaims paragraph 43.
31. All documents concerning Counterclaims paragraph 44’s allegation that “[a]t
times, personal disputes have also bled into the family business.”
32. All documents concerning Counterclaims paragraph 49’s allegation that “Plaintiff
began to lay the ground work for suing her family to squeeze more cash out of the companies
through whatever means necessary” in “fall 2020.”
33. All documents concerning Counterclaims paragraph 54’s allegation that Yasemin
had a “history of erratic and volatile behavior towards Company employees.”
34. All documents concerning the allegations in Counterclaims paragraph 59.
35. All documents concerning the damages alleged in the Counterclaims.
36. All leases between and among the Companies, Berrin Tekiner, Gonca Tekiner,
Billur Akipek, and Zeynep Tekiner.
37. Any and all leases into which the Companies entered in connection with
properties purchased with proceeds from the sale of certain real estate to Extell.
38. Documents sufficient to show all amounts received in connection with any and all
reinvestment(s) of proceeds from the sale of certain real estate to Extell.
39. Any and all statements of any bank account, brokerage account, or other financial
account in which Defendants and/or Zeynep Tekiner have an interest and/or signature authority.
9
FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1034 RECEIVED NYSCEF: 01/09/2023
40. Any and all statements of any credit card, debit card, charge card, PayPal, Venmo,
or other payment system through which Defendants and/or Zeynep Tekiner made or received
payments or had the right to make or receive payments.
Dated: New York, New York
September 15, 2021
By: __/s/ Evan Mandel___________________
Evan Mandel
Mandel Bhandari LLP
80 Pine Street, 33rd Floor
New York, NY 10005
(212) 269-5600
(646) 964-6667 (fax)
em@mandelbhandari.com
Attorneys for Plaintiff Yasemin Tekiner
10
Preview
FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1034 RECEIVED NYSCEF: 01/09/2023 EXHIBIT 3 Plaintiff Yasemin Tekiner’s Third Set of Requests for Production FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1034 RECEIVED NYSCEF: 01/09/2023 SUPREME COURT OF THE STATE OF NEW YORK COMMERCIAL DIVISION, NEW YORK COUNTY YASEMIN TEKINER, Index No. 657193/2020 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 PLAINTIFF’S THIRD shareholder or a member of the Company REQUEST FOR PRODUCTION Defendants, OF DOCUMENTS Plaintiff, - against - 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, in her capacity as a Trustee of The Yasemin Tekiner 2011 Descendants Trust, Defendants. PLEASE TAKE NOTICE THAT Plaintiff Yasemin Tekiner (“Yasemin”) by and through its undersigned counsel hereby requires Defendants Bremen House, Inc., German News Company, Inc., German News Texas, Inc., Berrin Tekiner, Gonca Tekiner and Billur Akipek (collectively “Defendants”) to produce a copy of the following documents within twenty (20) days. DEFINITIONS As used in these Document Requests, the following terms shall have the meanings set forth below: FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1034 RECEIVED NYSCEF: 01/09/2023 1. The term “Companies” shall refer to Defendants Bremen House, Inc., Bremen House Texas, Inc., German News Company, Inc., German News Texas, Inc., 254 – 258 W. 35th St. LLC, together with all of their officers, directors, employees, independent contractors, agents, partners, corporate parents, subsidiaries, affiliates, predecessors, successors, attorneys, and any persons acting or purporting to act on their behalf. 2. The term “Defendants” shall refer to Defendants Bremen House, Inc., German News Company, Inc., Berrin Tekiner, Gonca Tekiner, and Billur Akipek, together with all of their officers, directors, employees, independent contractors, agents, partners, corporate parents, subsidiaries, affiliates, predecessors, successors, attorneys, and any persons acting or purporting to act on their behalf. 3. The term “Yasemin” shall refer to Plaintiff Yasemin Tekiner, including partners, employees, agents, attorneys, and any persons acting or purporting to act on her behalf. 4. The term “you” and “your” shall refer to Defendants, as defined above, and/or and any persons acting or purporting to act on behalf of any such entity or entities. 5. The term “Trust” shall refer to The Yasemin Tekiner 2011 Descendants Trust. 6. The terms “Counterclaims” and “Counterclaim” means the counterclaims contained in Defendants’ Verified Amended Answer, Affirmative Defenses, and Counterclaims to the Verified Amended Complaint. 7. The term “communication” means the transmittal of information (in the form of facts, ideas, inquiries, or otherwise), and may be written or oral. 8. The term “concerning” means relating to, referring to, reflecting, mentioning, describing, evidencing, consisting of (in whole or in part), constituting (in whole or in part), or containing (in whole or in part). 2 FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1034 RECEIVED NYSCEF: 01/09/2023 9. The term “document” shall be construed in its broadest sense and includes the original and each non-identical copy and any draft of any written, typed, printed, recorded, or graphical matter, however recorded, stored, produced, or reproduced, or any tangible thing that in whole or in part illustrates or conveys information, including but not limited to, papers, letters, notes, books, notebooks, diaries, journals, correspondence, interoffice and intraoffice communications, memoranda, opinions, reports, evaluations, recommendations, reviews, analyses, minutes, entries in personal diaries or other record books, summaries, notes, or minutes of meetings or conversations or communications of any type or description (including, without limitation, telephone conversations, personal conversations or interviews, meetings, conferences, negotiations, and investigations), cablegrams, mailgrams, telegrams, facsimiles, electronic mail, email, telexes, marginal comments or annotations appearing in any document, calendars, appointment books, pamphlets, books, manuals, directives, bulletins, instructions, agreements, contracts and other legal documents, news releases, advertisements, ledgers, statistics, surveys, checks, financial statements, invoices, receipts, work sheets, bills, preliminary drafts and working papers, drawings, sketches, charts, graphs, plans, specifications, photographs, phonographs, films, tapes, information recorded on microfilm or microfiche, data and information on computer-stored or computer-readable media whether tape, disk, diskette, RAM, or other medium of storage, including but not limited to computer files and electronic mail, and all other writings, recordings, and data compilations of every description, however denominated, translated, or described from which information can be obtained or translated, if necessary, through detective devices into reasonably usable form. For purpose of the foregoing definition, the term “draft” means any earlier, preliminary, preparatory, or tentative version of all or part of a document, whether or not such draft was 3 FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1034 RECEIVED NYSCEF: 01/09/2023 superseded by a later draft, and whether or not the terms of the draft are the same as or different from the terms of the final document. The term “copy” means all versions of a document that is not in every respect identical to the documents being produced. INSTRUCTIONS FOR DOCUMENT REQUESTS 1. In answering these Document Requests, you are required to furnish all information that is available to you or subject to reasonable inquiry by you, including information in your possession, or the possession of your attorneys, and anyone else subject to your or your attorney’s control. 2. Electronic records and computerized information must be produced with all metadata preserved and intact. 3. These Document Requests should always be interpreted to be inclusive rather than exclusive, including interpreting the following as appropriate: the singular form of a word as plural, and vice versa; “and” to include “or,” and vice versa; the past tense to include the present tense, and vice versa. 4. In responding to these Document Requests, preface each answer by restating the Request to which it is addressed. If a Request has subparts, answer each subpart separately and in full and do not limit your answer to the Request as a whole. If you are unable to answer a Request fully, submit as much information as is available, explain why your answer is incomplete, and state the source or sources from which a complete or more complete answer may be obtained. 5. In responding to these Document Requests, which are continuing in nature, Defendants shall produce all responsive documents in their possession, custody or control and shall promptly supplement and/or correct their responses if they come into possession, custody or control 4 FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1034 RECEIVED NYSCEF: 01/09/2023 of additional documents, or learn or determine additional information, after the service of their response. 6. If you object, in whole or in part, to any Request, state with specificity the full objection(s) and the particularized basis for each objection in accordance with Commercial Division Rule 11-e. To the extent that you object to any portion of a Request, you must respond to the remaining portion of the Request to which you do not object. 7. If you object to any Request in whole or in part on the basis of any claimed privilege, provide the following information for each communication or information of which you claim a privilege: a. The type of communication or information (e.g. meeting, phone call, letter, data); b. The date of the communication or information; c. The identity of the author of any written communication, the speaker of any oral communication, or the source of any information; d. The identity of all persons who received or had access to any written communication or information and all persons present during oral communication; e. The subject matter of the communications or information; f. The location of any information, written communications and recordings of any oral communications; and g. The factual and legal basis on which you claim privilege. 8. If you object, in whole or in part, to any Document Request, state with specificity the full objection(s) and the particularized basis for each objection. To the extent that you object to any portion of a Document Request, you must respond to the remaining portion of the Document Request to which you do not object. 5 FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1034 RECEIVED NYSCEF: 01/09/2023 9. Electronic records and computerized information must be produced with all metadata preserved and intact. 10. Unless otherwise specified, the Document Requests refer to the period from January 1, 2011 until the present. REQUESTS FOR DOCUMENTS 1. All documents concerning any indemnification by or request for indemnification from one or more of the Companies for any fees, costs, or other amounts relating to the above- captioned action. 2. All documents concerning Defendants’ preservation, retention, destruction, or deletion of documents. 3. All documents concerning Defendants’ document retention policies. 4. All documents concerning any instruction to Defendants to retain, preserve, or not destroy documents. 5. All documents concerning the risk or possibility of litigation concerning Defendants or Plaintiff. 6. Documents sufficient to show all phones and other electronic devices utilized by Berrin Tekiner, Gonca Tekiner, Zeynep Tekiner, or Billur Akipek from January 1, 2015 to the present. 7. Documents sufficient to show the current location of all phones and other electronic devices utilized by Berrin Tekiner, Gonca Tekiner, Zeynep Tekiner, or Billur Akipek from January 1, 2015 to the present. 8. All documents concerning the loss, destruction, sale, or disposition of all phones and other electronic devices utilized by Berrin Tekiner, Gonca Tekiner, Zeynep Tekiner, or Billur Akipek from January 1, 2015 to the present. 6 FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1034 RECEIVED NYSCEF: 01/09/2023 9. All documents concerning any icloud account utilized or accessed by Berrin Tekiner, Gonca Tekiner, Zeynep Tekiner, or Billur Akipek from January 1, 2015 to the present. 10. All documents concerning any itunes account utilized or accessed by Berrin Tekiner, Gonca Tekiner, Zeynep Tekiner, or Billur Akipek from January 1, 2015 to the present. 11. All documents concerning any cloud or other information storage system or service utilized or accessed by Berrin Tekiner, Gonca Tekiner, Zeynep Tekiner, or Billur Akipek from January 1, 2015 to the present. 12. All documents concerning any media or other object capable of storing information utilized or accessed by Berrin Tekiner, Gonca Tekiner, Zeynep Tekiner, or Billur Akipek from January 1, 2015 to the present. 13. All documents concerning Defendants’ defenses and Counterclaims. 14. All documents concerning the Yasemin Trust Agreement, Certificates of Incorporation for the Companies, Corporate Bylaws of the Companies, and all other relevant corporate agreements and amendments. 15. All documents concerning the Companies’ finances, performance, and value between the time that Berrin Tekiner began running the business and the present. 16. Documents sufficient to show any and all properties owned by the Companies at the time Berrin Tekiner began “running the business,” as alleged in Counterclaims paragraph 10. 17. Documents sufficient to show any and all properties currently owned by the Companies. 18. All documents concerning the Companies compliance with and/or violation of federal, state, and city laws and regulations. 7 FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1034 RECEIVED NYSCEF: 01/09/2023 19. All documents concerning Defendants’ allegation in Counterclaims paragraph 16 that there was an “understanding that Yasemin would regularly return to the Companies offices to work.” 20. All documents concerning Defendants’ allegation in Counterclaims paragraph 19 that “Yasemin repeatedly interfered in leasing and maintenance of commercial space to the detriment of the Companies.” 21. All documents concerning Defendants’ allegation in Counterclaims paragraph 19 that Yasemin objected to the retention of a male contractor and insisted that the Companies select a female contractor. 22. All documents concerning Defendants’ allegation in Counterclaims paragraph 19 that “Yasemin similarly objected to the Companies hiring a male real estate broker.” 23. All documents concerning the determination of how much Yasemin would be paid in gross wages, salary, pension contributions, pension benefits, and other compensation. 24. All documents concerning any amounts that Defendants paid concerning the Bel Air house in which Yasemin lives. 25. All documents concerning the renovation(s) alleged in Counterclaims paragraph 27. 26. All documents concerning Defendants’ allegation in Counterclaims paragraph 29 that “[p]rior to 2011, Berrin owned the entire Tekiner family of companies.” 27. All documents concerning any contingent or other rights that any person other than Berrin Tekiner had in the Tekiner family of companies at any time between 1985 and 2012. 28. All documents concerning the three grantor trusts described in Counterclaims paragraph 30. 8 FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1034 RECEIVED NYSCEF: 01/09/2023 29. All documents concerning the amending and restating of promissory notes alleged in Counterclaims paragraphs 31 through 34, including but not limited to all documents concerning any related IRS audit, examination, or communication. 30. All documents concerning the “disputes” alleged in Counterclaims paragraph 43. 31. All documents concerning Counterclaims paragraph 44’s allegation that “[a]t times, personal disputes have also bled into the family business.” 32. All documents concerning Counterclaims paragraph 49’s allegation that “Plaintiff began to lay the ground work for suing her family to squeeze more cash out of the companies through whatever means necessary” in “fall 2020.” 33. All documents concerning Counterclaims paragraph 54’s allegation that Yasemin had a “history of erratic and volatile behavior towards Company employees.” 34. All documents concerning the allegations in Counterclaims paragraph 59. 35. All documents concerning the damages alleged in the Counterclaims. 36. All leases between and among the Companies, Berrin Tekiner, Gonca Tekiner, Billur Akipek, and Zeynep Tekiner. 37. Any and all leases into which the Companies entered in connection with properties purchased with proceeds from the sale of certain real estate to Extell. 38. Documents sufficient to show all amounts received in connection with any and all reinvestment(s) of proceeds from the sale of certain real estate to Extell. 39. Any and all statements of any bank account, brokerage account, or other financial account in which Defendants and/or Zeynep Tekiner have an interest and/or signature authority. 9 FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1034 RECEIVED NYSCEF: 01/09/2023 40. Any and all statements of any credit card, debit card, charge card, PayPal, Venmo, or other payment system through which Defendants and/or Zeynep Tekiner made or received payments or had the right to make or receive payments. Dated: New York, New York September 15, 2021 By: __/s/ Evan Mandel___________________ Evan Mandel Mandel Bhandari LLP 80 Pine Street, 33rd Floor New York, NY 10005 (212) 269-5600 (646) 964-6667 (fax) em@mandelbhandari.com Attorneys for Plaintiff Yasemin Tekiner 10