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 01/09/2023 07:07 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1075 RECEIVED NYSCEF: 01/09/2023
EXHIBIT 44
December 20, 2022 Notice of Deposition Served on Sadan Gurbuzturk
FILED: NEW YORK COUNTY CLERK 01/09/2023 07:07 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1075 RECEIVED NYSCEF: 01/09/2023
SUPREME COURT OF THE STATE OF NEW YORK
COMMERCIAL DIVISION, NEW YORK COUNTY
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 Index No. 657193/2020
shareholder or a member of the Company
Defendants, Commercial Division Part 3
Plaintiff, Hon. Joel M. Cohen, J.S.C.
-against- NOTICE OF DEPOSITION
OF SADAN GURBUZTURK
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.
ZEYNEP TEKINER,
in her individual capacity, as a beneficiary
and a Trustee of The Zeynep Tekiner 2011
Descendants Trust and derivatively as a
holder of equitable interests in a
shareholder or a member of the Company
Defendants,
Intervenor-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.
FH11228017.1
FILED: NEW YORK COUNTY CLERK 01/09/2023 07:07 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1075 RECEIVED NYSCEF: 01/09/2023
PLEASE TAKE NOTICE that, pursuant to Article 31 of the New York Civil Practice
Law and Rules, Plaintiff Yasemin Tekiner, by her undersigned counsel will take the deposition of
Sadan Gurbuzturk, beginning at 9 a.m. on December 27, 2022, before a notary public or other
officer authorized to administer oaths. The deposition will continue from day to day until
completed.
PLEASE TAKE FURTHER NOTICE, that the deposition may be video recorded
pursuant to CPLR 3113 and the Uniform Civil Rules for the Supreme Court and the County Court
by an employee of the undersigned counsel or the court reporter.
PLEASE TAKE FURTHER NOTICE, that this is the second notice of deposition for
Sadan Gurbuzturk. Defendants previously substituted Gonca Chelsea (formerly Tekiner), but she
did not have the appropriate knowledge of company bookkeeping. Consequently, the court granted
leave to depose Sadan once document discovery was complete.
Dated: New York, New York
December 20, 2022
By: /s/ Stephen P. Younger
Stephen P. Younger
FOLEY HOAG LLP
1301 Avenue of the Americas, 25th Floor
New York, New York 10019
(212) 812-0400
spyounger@foleyhoag.com
Attorneys for Plaintiff
FH11228017.1
Preview
FILED: NEW YORK COUNTY CLERK 01/09/2023 07:07 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1075 RECEIVED NYSCEF: 01/09/2023 EXHIBIT 44 December 20, 2022 Notice of Deposition Served on Sadan Gurbuzturk FILED: NEW YORK COUNTY CLERK 01/09/2023 07:07 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1075 RECEIVED NYSCEF: 01/09/2023 SUPREME COURT OF THE STATE OF NEW YORK COMMERCIAL DIVISION, NEW YORK COUNTY 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 Index No. 657193/2020 shareholder or a member of the Company Defendants, Commercial Division Part 3 Plaintiff, Hon. Joel M. Cohen, J.S.C. -against- NOTICE OF DEPOSITION OF SADAN GURBUZTURK 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. ZEYNEP TEKINER, in her individual capacity, as a beneficiary and a Trustee of The Zeynep Tekiner 2011 Descendants Trust and derivatively as a holder of equitable interests in a shareholder or a member of the Company Defendants, Intervenor-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. FH11228017.1 FILED: NEW YORK COUNTY CLERK 01/09/2023 07:07 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1075 RECEIVED NYSCEF: 01/09/2023 PLEASE TAKE NOTICE that, pursuant to Article 31 of the New York Civil Practice Law and Rules, Plaintiff Yasemin Tekiner, by her undersigned counsel will take the deposition of Sadan Gurbuzturk, beginning at 9 a.m. on December 27, 2022, before a notary public or other officer authorized to administer oaths. The deposition will continue from day to day until completed. PLEASE TAKE FURTHER NOTICE, that the deposition may be video recorded pursuant to CPLR 3113 and the Uniform Civil Rules for the Supreme Court and the County Court by an employee of the undersigned counsel or the court reporter. PLEASE TAKE FURTHER NOTICE, that this is the second notice of deposition for Sadan Gurbuzturk. Defendants previously substituted Gonca Chelsea (formerly Tekiner), but she did not have the appropriate knowledge of company bookkeeping. Consequently, the court granted leave to depose Sadan once document discovery was complete. Dated: New York, New York December 20, 2022 By: /s/ Stephen P. Younger Stephen P. Younger FOLEY HOAG LLP 1301 Avenue of the Americas, 25th Floor New York, New York 10019 (212) 812-0400 spyounger@foleyhoag.com Attorneys for Plaintiff FH11228017.1