Preview
FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023
EXHIBIT 38
FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023
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 Commercial Division Part 3
2011 Descendants Trust and derivatively
as a holder of equitable interests in a Hon. Joel M. Cohen, J.S.C.
shareholder or a member of the Company
Defendants, SUBPOENA DUCES TECUM
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.
TO: Santander Bank, N.A.
222 Broadway
New York, New York 10038
WE HEREBY COMMAND YOU that, all business and excuses being laid aside, to
produce at Foley Hoag LLP, 1301 Avenue of the Americas, New York, New York 10019, on or
before September 1, 2022 the documents requested in Schedule A annexed hereto.
PLEASE TAKE NOTICE that failure to comply with this subpoena may be punishable
as a contempt of court and may make you liable to the person on whose behalf this subpoena
was issued. Pursuant to CPLR § 3101(a)(4), your documents are required in order to establish
certain facts in the above-captioned action relating, inter alia, to accounts at issue therein and
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FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023
transactions in same that are pertinent to the parties’ claims and defenses, including, but not
limited to, those concerning the alleged corporate waste, mismanagement, and misuse of funds
by the named defendants.
Dated: New York, New York Respectfully submitted,
August 9, 2022
/s/ Stephen P. Younger
Stephen P. Younger
FOLEY HOAG LLP
1301 Avenue of the Americas, 25th Floor
New York, New York 10019
Telephone: (212) 812-0365
spyounger@foleyhoag.com
Co-Counsel for Plaintiff 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
2
FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023
cc: Meghan E. Hill
Pryor Cashman LLP
7 Times Square
New York, NY 10036-6569
Attorneys for Defendants
Michele Kahn, Esq.
Kahn & Goldberg, LLP
555 5th Avenue, 14th Floor
New York, New York 10017
Attorneys for Intervenor Plaintiff
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FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023
SCHEDULE A
DEFINITIONS
As used in these Document Requests, the following terms shall have the meanings set forth
below:
1. The term “Action” shall mean any and all proceedings related to the above-
captioned litigation.
2. The term “communication” means the transmittal of information (in the form of
facts, ideas, inquiries, or otherwise), and may be written or oral.
3. 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).
4. 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,
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NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023
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
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.
5. The term “Person” means a natural person, group of natural persons acting as
individuals, group of persons acting in a collective capacity (e.g., as a committee, board of
directors, etc.), corporation, partnership, limited partnership, joint venture, limited liability
\corporation, government or governmental agency, and/or any other incorporated or
unincorporated business or entity.
6. The term “Plaintiff” means the plaintiff in the above-captioned action, Yasemin
Tekiner, along with any of her representatives, agents, attorneys, assigns, and any other entities or
Persons acting or purporting to act on her behalf.
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7. The term “Santander” refers to Santander Bank, N.A. along with any of its
shareholders, employees, representatives, officers, directors, managers, agents, attorneys, assigns,
predecessors, affiliates, parents, subsidiaries, and any other entities or Persons acting or purporting
to act on its behalf.
INSTRUCTIONS
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. In answering these Document Requests, you are required to comply with the so-
ordered Stipulation and Order for the Production and Exchange of Electronically Stored
Information, filed June 28, 2021, and all applicable Commercial Division Rules.
3. Electronic records and computerized information must be produced with all
metadata preserved and intact.
4. 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.
5. 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.
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FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023
6. 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 of additional
documents, or learn or determine additional information, after the service of their response.
7. 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.
8. 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.
9. Unless otherwise specified, the Document Requests refer to the period from
January 1, 2014 until the present.
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FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023
SPECIFIC REQUESTS
1. Unredacted and complete version of the Santander bank statement of an account
held by Berrin Tekiner, Statement Period of November 16, 2015 to December 15, 2015, attached
as Exhibit 1, and copies of any checks referenced thereon.
2. Unredacted and complete version of the Santander bank statement of accounts held
by Berrin Tekiner and/or Gonca H. Hartmann, with Account Nos. ending 3922 and 2579,
Statement Period of December 22, 2014 to January 21, 2015, attached as Exhibit 2, and copies of
any checks referenced thereon.
3. Unredacted and complete version of the Santander bank statement of an account
held by Berrin Tekiner, with an Account No. ending in 5069, Statement Period of April 16, 2017
to May 15, 2017, attached as Exhibit 3, and copies of any checks referenced thereon.
4. All documents that show or tend to show movement of funds, including, but not
limited to, monthly, quarterly, or other periodic account statements, check images, cancelled
checks, deposit slips, and/or wire transfers associated with an account held by Residuary Trust of
Sami S. Tekiner Berrin Tekiner Trustee, with an Account No. ending in 9285, including, but not
limited to the following unredacted and complete Santander bank statements: Statement Period of
January 1, 2018 to January 31, 2018, attached as Exhibit 4; Statement Period of February 1, 2018
to February 28, 2018, attached as Exhibit 5; Statement Period of March 1, 2018 to March 31, 2018,
attached as Exhibit 6; Statement Period of April 1, 2018 to April 30, 2018, attached as Exhibit 7;
Statement Period of May 1, 2018 to May 31, 2018, attached as Exhibit 8, and; Statement Period
of March 1, 2020 to March 31, 2020, attached as Exhibit 9.
5. All documents that show or tend to show movement of funds, including, but not
limited to, monthly, quarterly, or other periodic account statements, check images, cancelled
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FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020
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checks, deposit slips, and/or wire transfers associated with an account held by 254-258 W. 35th
Street, LLC, with an Account No. ending in 4194, including, but not limited to, the following
unredacted and complete Santander bank statements: Statement Period of December 28, 2017 to
December 31, 2017, attached as Exhibit 10; Statement Period of January 1, 2018 to January 31,
2018, attached as Exhibit 11; Statement Period of February 1, 2018 to February 28, 2018, attached
as Exhibit 12; Statement Period of March 1, 2018 to March 31, 2018, attached as Exhibit 13;
Statement Period of April 1, 2018 to April 30, 2018, attached as Exhibit 14; and; Statement Period
of March 1, 2020 to March 31, 2020, attached as Exhibit 15.
6. All documents that show or tend to show movement of funds, including, but not
limited to, monthly, quarterly, or other periodic account statements, check images, cancelled
checks, deposit slips, and/or wire transfers associated with an account held by German News
Texas, Inc., with an Account No. ending in 4003, including, but not limited to, the following
unredacted and complete Santander Bank statements: Statement Period of May 1, 2018 to May 31,
2018, attached as Exhibit 16, and; Statement Period of March 1, 2020 to March 31, 2020, attached
as Exhibit 17.
7. All documents that show or tend to show movement of funds, including. but not
limited to, monthly, quarterly, or other periodic account statements, check images, cancelled
checks, deposit slips, and/or wire transfers associated with an account held by German News, Inc.,
With an Account No. ending in 0897, including, but not limited to, the following unredacted and
complete Santander Bank statement: Statement Period of March 1, 2020 to March 31, 2020,
attached as Exhibit 18.
8. All documents that show or tend to show movement of funds, including, but not
limited to, monthly, quarterly, or other periodic account statements, check images, cancelled
9
FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023
checks, deposit slips, and/or wire transfers associated with an account held by Bremen House Inc.,
with an Account No. ending in 0900.
9. All documents that show or tend to show movement of funds, including, but not
limited to, monthly, quarterly, or other periodic account statements, check images, cancelled
checks, deposit slips, and/or wire transfers associated with an account held by Bremen House Inc.,
with an Account No. ending in 3639.
10. All documents that show or tend to show movement of funds, including, but not
limited to, monthly, quarterly, or other periodic account statements, check images, cancelled
checks, deposit slips, and/or wire transfers associated with an account held by Bremen House
Texas Inc., with an Account No. ending in 0889, including, but not limited to, the following
unredacted and complete Santander Bank statement: Statement Period of March 1, 2020 to March
31, 2020, attached as Exhibit 19.
11. All documents that show or tend to show movement of funds, including, but not
limited to, monthly, quarterly, or other periodic account statements, check images, cancelled
checks, deposit slips, and/or wire transfers associated with an account held by Bremen House Inc.,
with an Account No. ending in 7909, including, but not limited to, the following unredacted and
complete Santander Bank Statements: Statement Period of March 1, 2020 to March 31, 2020,
attached as Exhibit 20, and; Statement Period of April 1, 2018 to April 30, 2018.
12. All documents that show or tend to show movement of funds, including, but not
limited to, monthly, quarterly, or other periodic account statements, check images, cancelled
checks, deposit slips, and/or wire transfers associated with an account held by Bremen House Inc.,
with an Account No. ending in 0978, including but not limited to, the following unredacted and
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FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023
complete Santander Bank statement: Statement Period of March 1, 2020 to March 31, 2020,
attached as Exhibit 21.
13. All documents that show or tend to show movement of funds, including, but not
limited to, monthly, quarterly, or other periodic account statements, check images, cancelled
checks, deposit slips, and/or wire transfers associated with an account held by German News Inc.,
with an Account No. ending in 5360, including, but not limited to, the following unredacted and
complete Santander Bank statement: Statement Period of March 1, 2020 to March 31, 2020,
attached as Exhibit 22.
14. All documents that show or tend to show movement of funds, including, but not
limited to, monthly, quarterly, or other periodic account statements, check images, cancelled
checks, deposit slips, and/or wire transfers associated with an account held by Bremen House
Texas Inc., with an Account No. ending in 3589, including, but not limited to, the following
unredacted and complete Santander Bank statement: Statement Period of March 1, 2020 to March
31, 2020 attached as Exhibit 23.
15. All documents that show or tend to show movement of funds, including, but not
limited to, monthly, quarterly, or other periodic account statements, check images, cancelled
checks, deposit slips, and/or wire transfers associated with a Santander small business account held
by Berrin Tekiner and/or Gonca H. Hartmann with an Account No. ending in 5142.
16. All documents that show or tend to show movement of funds, including, but not
limited to, monthly, quarterly, or other periodic account statements, check images, cancelled
checks, deposit slips, and/or wire transfers associated with a Santander small business account held
by Berrin Tekiner, Gonca H. Hartmann, and/or Billur Akipek with an Account No. ending in 5088.
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FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023
17. All documents that show or tend to show movement of funds, including, but not
limited to, monthly, quarterly, or other periodic account statements, check images, cancelled
checks, deposit slips, and/or wire transfers associated with a Santander small business account held
by Berrin Tekiner and Gonca H. Hartmann, with an Account No. ending in 5142.
18. All documents that show or tend to show movement of funds, including, but not
limited to, monthly, quarterly, or other periodic account statements, check images, cancelled
checks, deposit slips, and/or wire transfers associated with a Santander small business account held
by Billur Akipek, with an Account No. ending in 9900.
19. All documents that show or tend to show movement of funds, including, but not
limited to, monthly, quarterly, or other periodic account statements, check images, cancelled
checks, deposit slips, and/or wire transfers associated with a Santander small business account held
by Billur Akipek, with an Account No. ending in 0891.
20. All signature cards for the accounts identified in Request Nos. 1-19.
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FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023
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 shareholder or a Index No. 657193/2020
member of the Company Defendants,
Commercial Division Part 3
Plaintiff,
Hon. Joel M. Cohen
-against-
BREMEN HOUSE INC., BREMEN HOUSE TEXAS,
INC., GERMAN NEWS COMPANY, INC., AFFIRMATION OF SERVICE
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.
I, Stephen P. Younger, Esq., hereby affirm under penalty of perjury as follows:
1. I am an attorney-at-law admitted to practice in the State of New York, and am a
partner of the law firm of Foley Hoag LLP, co-counsel for Plaintiff 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 in the above-captioned action.
2. On August 9, 2022, I caused to be served a Subpoena Duces Tecum and this
Affirmation of Service, as follows:
VIA PERSONAL SERVICE
Santander Bank, N.A.
222 Broadway
New York, New York 10038
VIA FEDEX
Meghan E. Hill, Esq.
Pryor Cashman LLP
7 Times Square
New York, New York 10036-6569
Attorneys for Defendants
Michele Kahn, Esq.
Kahn & Goldberg, LLP
555 5th Avenue, 14th Floor
New York, New York 10017
Attorneys for Intervenor-Plaintiff
3. I hereby affirm that the foregoing statements made by me are true. I am aware that
if any of the foregoing statements made by me are willfully false I may be subject to punishment.
1
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FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023
Dated: New York, New York
August 9, 2022
FOLEY HOAG LLP
Co-Counsel for Plaintiff,
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
/s/ Stephen P. Younger
Stephen P. Younger, Esq.
1301 Avenue of the Americas, 25th Floor
New York, New York 10019
Telephone: (212) 812-0365
spyounger@foleyhoag.com
2
Index No. 657193/2020
FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023
EXHIBIT 1
FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020
d
NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023
Santanc er
Statement Period 11/16/1570 12/15/15
SANTANDER PREMlER CHECKING
our Customer
For your convenience ContactCenter
7 am- 8 pm EST, 7 days a week
is available from
Call us at 1-877-768-1143.
(TTY/TTD).
may call 1-800-428-9121
Hearing impaired
www.santanderbank.com
BERRIN TEKINER
40 E 787H ST # 4H 0000
NEW YORK NY 19075-18310 7 0 15
PROSPERIT
n
S HIR PSION
PROGRESS
T FRIENDS TOGETHERNESS OY
n other words
Seasorts Greetmgs from Santander
ACCEPTANCE GRACE RESOLUTIONS PASSION
BB LNR AO
AERNE1EKINE Account Identi..
Personally
4arned thisyeriod $190 E)ast Yea dDd
* The iriterest eamed and the
nterest paid may differ
depend n on when inteestis
Bredited to your account
. SantanderNA.isaMember
3arik, PDid
andawheny
owned ofBanco
subsidiary SA.02015
Santander, Santander
. Bank A.
Allrights
reserved. Santander
Santander, theRame
Bank, LogoandExtra
20(forchecking
account
D Ge 1of 5 -a arereaistered
semces) andExtra
trademarks, 20(forsavings
account isaservice
servicesí mark
ofBanco
Santander,
CONFIDENTIAL Brem00249870
FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020
d
NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023
Santancer
Checks Posted
Check # Date Paid Amount Reference Check # Date Paid Amount Reference
. . . mma-weawamm---mm-mamwmawamamummemum
112* 12/08 $239.27 0985333570 167* 12/07 $30,000.00 0984864105
4 Check(s) Posted=$40,349.27
An asterisk (*) indicates a skip in sequential check numbers.
Account Activity
Date Description Additions Subtractions Balance
11-16Beginninq Balance $441,867.53
11 27 RUFLED FEAT ER914 725 6880 /NY US CARD Pi RCHA (22 73 $484 650 90
12-03 BRANCH MIXED DEPOSITAT UPPEREASTSIDE $140.25 $483,612.29
TPAN5FERFROV ACCOUNT *3922 $ G 25
12 04 GERMAN NEWS CD ! DiRECT DEM Si204 50024248656E $5 904 27 $ 496 738.02
12 07 AMEX EPayment AC A PVT 15 204 v3150 519 999 85 $46b /38.16
12-08 CHECK 000000000112 $239.27 $436,498.89
12-15 JOSHUAS RESTAURWOODSTOCK /NY US CARD PURCHASE $89.13 439,656.76
12- 5 EndingBalance $439,546.76
Dane 2 of5 'ersmallyIdentifiah.
CONFIDENTIAL Brem00249871
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NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023
PREMIER MONEY MARKET SAVINGS Statement Period 12/16/15 - 01/15/16
. ..
BERRIN TEKINER Account # 695
Balances
Beginn ng Ba!anS 11,76$ 31 tunent Balance $1,76575
Deposits!Credits +$0 44 Average Dai y Balance $ 1,765 75
Wdhdrawals/Debas -$0 00
Interest
Paid this Penod * 10 44 Annual PerentageYeld Eamed 0 29%
Earned (nis Period 10 44 Paid last Year 53 53
Paid Year-To-Date $0 00
* Tno interest eamed and the interest paid :nterest is creciited to your account
may dif fer depending
on when
Account Activity
Date Description Additions Subtractions Balance
12-16Beginning Balance $;765.31
01-15 EndingBalance $1,76575
pace 2 of 4
CONFIDENTIAL Brem00249872
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NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023
EXHIBIT 2
FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023
Statement Period12/22/14T001/21/15
PREMlER MONEY MARKET- PROMO
For your convenienceour
Customer ContactCenter
7arn-
is available from 8pm EST, 7 daysa week
Call usat1-877-768-1143.
MSBG11AFO20122105204-00001217-o03--1000 may call 1-800-428-9121
Hearing impaired
Preview
FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023 EXHIBIT 38 FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023 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 Commercial Division Part 3 2011 Descendants Trust and derivatively as a holder of equitable interests in a Hon. Joel M. Cohen, J.S.C. shareholder or a member of the Company Defendants, SUBPOENA DUCES TECUM 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. TO: Santander Bank, N.A. 222 Broadway New York, New York 10038 WE HEREBY COMMAND YOU that, all business and excuses being laid aside, to produce at Foley Hoag LLP, 1301 Avenue of the Americas, New York, New York 10019, on or before September 1, 2022 the documents requested in Schedule A annexed hereto. PLEASE TAKE NOTICE that failure to comply with this subpoena may be punishable as a contempt of court and may make you liable to the person on whose behalf this subpoena was issued. Pursuant to CPLR § 3101(a)(4), your documents are required in order to establish certain facts in the above-captioned action relating, inter alia, to accounts at issue therein and 1 FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023 transactions in same that are pertinent to the parties’ claims and defenses, including, but not limited to, those concerning the alleged corporate waste, mismanagement, and misuse of funds by the named defendants. Dated: New York, New York Respectfully submitted, August 9, 2022 /s/ Stephen P. Younger Stephen P. Younger FOLEY HOAG LLP 1301 Avenue of the Americas, 25th Floor New York, New York 10019 Telephone: (212) 812-0365 spyounger@foleyhoag.com Co-Counsel for Plaintiff 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 2 FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023 cc: Meghan E. Hill Pryor Cashman LLP 7 Times Square New York, NY 10036-6569 Attorneys for Defendants Michele Kahn, Esq. Kahn & Goldberg, LLP 555 5th Avenue, 14th Floor New York, New York 10017 Attorneys for Intervenor Plaintiff 3 FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023 SCHEDULE A DEFINITIONS As used in these Document Requests, the following terms shall have the meanings set forth below: 1. The term “Action” shall mean any and all proceedings related to the above- captioned litigation. 2. The term “communication” means the transmittal of information (in the form of facts, ideas, inquiries, or otherwise), and may be written or oral. 3. 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). 4. 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, 4 FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023 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 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. 5. The term “Person” means a natural person, group of natural persons acting as individuals, group of persons acting in a collective capacity (e.g., as a committee, board of directors, etc.), corporation, partnership, limited partnership, joint venture, limited liability \corporation, government or governmental agency, and/or any other incorporated or unincorporated business or entity. 6. The term “Plaintiff” means the plaintiff in the above-captioned action, Yasemin Tekiner, along with any of her representatives, agents, attorneys, assigns, and any other entities or Persons acting or purporting to act on her behalf. 5 FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023 7. The term “Santander” refers to Santander Bank, N.A. along with any of its shareholders, employees, representatives, officers, directors, managers, agents, attorneys, assigns, predecessors, affiliates, parents, subsidiaries, and any other entities or Persons acting or purporting to act on its behalf. INSTRUCTIONS 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. In answering these Document Requests, you are required to comply with the so- ordered Stipulation and Order for the Production and Exchange of Electronically Stored Information, filed June 28, 2021, and all applicable Commercial Division Rules. 3. Electronic records and computerized information must be produced with all metadata preserved and intact. 4. 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. 5. 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. 6 FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023 6. 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 of additional documents, or learn or determine additional information, after the service of their response. 7. 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. 8. 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. 9. Unless otherwise specified, the Document Requests refer to the period from January 1, 2014 until the present. 7 FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023 SPECIFIC REQUESTS 1. Unredacted and complete version of the Santander bank statement of an account held by Berrin Tekiner, Statement Period of November 16, 2015 to December 15, 2015, attached as Exhibit 1, and copies of any checks referenced thereon. 2. Unredacted and complete version of the Santander bank statement of accounts held by Berrin Tekiner and/or Gonca H. Hartmann, with Account Nos. ending 3922 and 2579, Statement Period of December 22, 2014 to January 21, 2015, attached as Exhibit 2, and copies of any checks referenced thereon. 3. Unredacted and complete version of the Santander bank statement of an account held by Berrin Tekiner, with an Account No. ending in 5069, Statement Period of April 16, 2017 to May 15, 2017, attached as Exhibit 3, and copies of any checks referenced thereon. 4. All documents that show or tend to show movement of funds, including, but not limited to, monthly, quarterly, or other periodic account statements, check images, cancelled checks, deposit slips, and/or wire transfers associated with an account held by Residuary Trust of Sami S. Tekiner Berrin Tekiner Trustee, with an Account No. ending in 9285, including, but not limited to the following unredacted and complete Santander bank statements: Statement Period of January 1, 2018 to January 31, 2018, attached as Exhibit 4; Statement Period of February 1, 2018 to February 28, 2018, attached as Exhibit 5; Statement Period of March 1, 2018 to March 31, 2018, attached as Exhibit 6; Statement Period of April 1, 2018 to April 30, 2018, attached as Exhibit 7; Statement Period of May 1, 2018 to May 31, 2018, attached as Exhibit 8, and; Statement Period of March 1, 2020 to March 31, 2020, attached as Exhibit 9. 5. All documents that show or tend to show movement of funds, including, but not limited to, monthly, quarterly, or other periodic account statements, check images, cancelled 8 FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023 checks, deposit slips, and/or wire transfers associated with an account held by 254-258 W. 35th Street, LLC, with an Account No. ending in 4194, including, but not limited to, the following unredacted and complete Santander bank statements: Statement Period of December 28, 2017 to December 31, 2017, attached as Exhibit 10; Statement Period of January 1, 2018 to January 31, 2018, attached as Exhibit 11; Statement Period of February 1, 2018 to February 28, 2018, attached as Exhibit 12; Statement Period of March 1, 2018 to March 31, 2018, attached as Exhibit 13; Statement Period of April 1, 2018 to April 30, 2018, attached as Exhibit 14; and; Statement Period of March 1, 2020 to March 31, 2020, attached as Exhibit 15. 6. All documents that show or tend to show movement of funds, including, but not limited to, monthly, quarterly, or other periodic account statements, check images, cancelled checks, deposit slips, and/or wire transfers associated with an account held by German News Texas, Inc., with an Account No. ending in 4003, including, but not limited to, the following unredacted and complete Santander Bank statements: Statement Period of May 1, 2018 to May 31, 2018, attached as Exhibit 16, and; Statement Period of March 1, 2020 to March 31, 2020, attached as Exhibit 17. 7. All documents that show or tend to show movement of funds, including. but not limited to, monthly, quarterly, or other periodic account statements, check images, cancelled checks, deposit slips, and/or wire transfers associated with an account held by German News, Inc., With an Account No. ending in 0897, including, but not limited to, the following unredacted and complete Santander Bank statement: Statement Period of March 1, 2020 to March 31, 2020, attached as Exhibit 18. 8. All documents that show or tend to show movement of funds, including, but not limited to, monthly, quarterly, or other periodic account statements, check images, cancelled 9 FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023 checks, deposit slips, and/or wire transfers associated with an account held by Bremen House Inc., with an Account No. ending in 0900. 9. All documents that show or tend to show movement of funds, including, but not limited to, monthly, quarterly, or other periodic account statements, check images, cancelled checks, deposit slips, and/or wire transfers associated with an account held by Bremen House Inc., with an Account No. ending in 3639. 10. All documents that show or tend to show movement of funds, including, but not limited to, monthly, quarterly, or other periodic account statements, check images, cancelled checks, deposit slips, and/or wire transfers associated with an account held by Bremen House Texas Inc., with an Account No. ending in 0889, including, but not limited to, the following unredacted and complete Santander Bank statement: Statement Period of March 1, 2020 to March 31, 2020, attached as Exhibit 19. 11. All documents that show or tend to show movement of funds, including, but not limited to, monthly, quarterly, or other periodic account statements, check images, cancelled checks, deposit slips, and/or wire transfers associated with an account held by Bremen House Inc., with an Account No. ending in 7909, including, but not limited to, the following unredacted and complete Santander Bank Statements: Statement Period of March 1, 2020 to March 31, 2020, attached as Exhibit 20, and; Statement Period of April 1, 2018 to April 30, 2018. 12. All documents that show or tend to show movement of funds, including, but not limited to, monthly, quarterly, or other periodic account statements, check images, cancelled checks, deposit slips, and/or wire transfers associated with an account held by Bremen House Inc., with an Account No. ending in 0978, including but not limited to, the following unredacted and 10 FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023 complete Santander Bank statement: Statement Period of March 1, 2020 to March 31, 2020, attached as Exhibit 21. 13. All documents that show or tend to show movement of funds, including, but not limited to, monthly, quarterly, or other periodic account statements, check images, cancelled checks, deposit slips, and/or wire transfers associated with an account held by German News Inc., with an Account No. ending in 5360, including, but not limited to, the following unredacted and complete Santander Bank statement: Statement Period of March 1, 2020 to March 31, 2020, attached as Exhibit 22. 14. All documents that show or tend to show movement of funds, including, but not limited to, monthly, quarterly, or other periodic account statements, check images, cancelled checks, deposit slips, and/or wire transfers associated with an account held by Bremen House Texas Inc., with an Account No. ending in 3589, including, but not limited to, the following unredacted and complete Santander Bank statement: Statement Period of March 1, 2020 to March 31, 2020 attached as Exhibit 23. 15. All documents that show or tend to show movement of funds, including, but not limited to, monthly, quarterly, or other periodic account statements, check images, cancelled checks, deposit slips, and/or wire transfers associated with a Santander small business account held by Berrin Tekiner and/or Gonca H. Hartmann with an Account No. ending in 5142. 16. All documents that show or tend to show movement of funds, including, but not limited to, monthly, quarterly, or other periodic account statements, check images, cancelled checks, deposit slips, and/or wire transfers associated with a Santander small business account held by Berrin Tekiner, Gonca H. Hartmann, and/or Billur Akipek with an Account No. ending in 5088. 11 FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023 17. All documents that show or tend to show movement of funds, including, but not limited to, monthly, quarterly, or other periodic account statements, check images, cancelled checks, deposit slips, and/or wire transfers associated with a Santander small business account held by Berrin Tekiner and Gonca H. Hartmann, with an Account No. ending in 5142. 18. All documents that show or tend to show movement of funds, including, but not limited to, monthly, quarterly, or other periodic account statements, check images, cancelled checks, deposit slips, and/or wire transfers associated with a Santander small business account held by Billur Akipek, with an Account No. ending in 9900. 19. All documents that show or tend to show movement of funds, including, but not limited to, monthly, quarterly, or other periodic account statements, check images, cancelled checks, deposit slips, and/or wire transfers associated with a Santander small business account held by Billur Akipek, with an Account No. ending in 0891. 20. All signature cards for the accounts identified in Request Nos. 1-19. 12 FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023 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 shareholder or a Index No. 657193/2020 member of the Company Defendants, Commercial Division Part 3 Plaintiff, Hon. Joel M. Cohen -against- BREMEN HOUSE INC., BREMEN HOUSE TEXAS, INC., GERMAN NEWS COMPANY, INC., AFFIRMATION OF SERVICE 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. I, Stephen P. Younger, Esq., hereby affirm under penalty of perjury as follows: 1. I am an attorney-at-law admitted to practice in the State of New York, and am a partner of the law firm of Foley Hoag LLP, co-counsel for Plaintiff 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 in the above-captioned action. 2. On August 9, 2022, I caused to be served a Subpoena Duces Tecum and this Affirmation of Service, as follows: VIA PERSONAL SERVICE Santander Bank, N.A. 222 Broadway New York, New York 10038 VIA FEDEX Meghan E. Hill, Esq. Pryor Cashman LLP 7 Times Square New York, New York 10036-6569 Attorneys for Defendants Michele Kahn, Esq. Kahn & Goldberg, LLP 555 5th Avenue, 14th Floor New York, New York 10017 Attorneys for Intervenor-Plaintiff 3. I hereby affirm that the foregoing statements made by me are true. I am aware that if any of the foregoing statements made by me are willfully false I may be subject to punishment. 1 Index No. 657193/2020 FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023 Dated: New York, New York August 9, 2022 FOLEY HOAG LLP Co-Counsel for Plaintiff, 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 /s/ Stephen P. Younger Stephen P. Younger, Esq. 1301 Avenue of the Americas, 25th Floor New York, New York 10019 Telephone: (212) 812-0365 spyounger@foleyhoag.com 2 Index No. 657193/2020 FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023 EXHIBIT 1 FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 d NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023 Santanc er Statement Period 11/16/1570 12/15/15 SANTANDER PREMlER CHECKING our Customer For your convenience ContactCenter 7 am- 8 pm EST, 7 days a week is available from Call us at 1-877-768-1143. (TTY/TTD). may call 1-800-428-9121 Hearing impaired www.santanderbank.com BERRIN TEKINER 40 E 787H ST # 4H 0000 NEW YORK NY 19075-18310 7 0 15 PROSPERIT n S HIR PSION PROGRESS T FRIENDS TOGETHERNESS OY n other words Seasorts Greetmgs from Santander ACCEPTANCE GRACE RESOLUTIONS PASSION BB LNR AO AERNE1EKINE Account Identi.. Personally 4arned thisyeriod $190 E)ast Yea dDd * The iriterest eamed and the nterest paid may differ depend n on when inteestis Bredited to your account . SantanderNA.isaMember 3arik, PDid andawheny owned ofBanco subsidiary SA.02015 Santander, Santander . Bank A. Allrights reserved. Santander Santander, theRame Bank, LogoandExtra 20(forchecking account D Ge 1of 5 -a arereaistered semces) andExtra trademarks, 20(forsavings account isaservice servicesí mark ofBanco Santander, CONFIDENTIAL Brem00249870 FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 d NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023 Santancer Checks Posted Check # Date Paid Amount Reference Check # Date Paid Amount Reference . . . mma-weawamm---mm-mamwmawamamummemum 112* 12/08 $239.27 0985333570 167* 12/07 $30,000.00 0984864105 4 Check(s) Posted=$40,349.27 An asterisk (*) indicates a skip in sequential check numbers. Account Activity Date Description Additions Subtractions Balance 11-16Beginninq Balance $441,867.53 11 27 RUFLED FEAT ER914 725 6880 /NY US CARD Pi RCHA (22 73 $484 650 90 12-03 BRANCH MIXED DEPOSITAT UPPEREASTSIDE $140.25 $483,612.29 TPAN5FERFROV ACCOUNT *3922 $ G 25 12 04 GERMAN NEWS CD ! DiRECT DEM Si204 50024248656E $5 904 27 $ 496 738.02 12 07 AMEX EPayment AC A PVT 15 204 v3150 519 999 85 $46b /38.16 12-08 CHECK 000000000112 $239.27 $436,498.89 12-15 JOSHUAS RESTAURWOODSTOCK /NY US CARD PURCHASE $89.13 439,656.76 12- 5 EndingBalance $439,546.76 Dane 2 of5 'ersmallyIdentifiah. CONFIDENTIAL Brem00249871 FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023 PREMIER MONEY MARKET SAVINGS Statement Period 12/16/15 - 01/15/16 . .. BERRIN TEKINER Account # 695 Balances Beginn ng Ba!anS 11,76$ 31 tunent Balance $1,76575 Deposits!Credits +$0 44 Average Dai y Balance $ 1,765 75 Wdhdrawals/Debas -$0 00 Interest Paid this Penod * 10 44 Annual PerentageYeld Eamed 0 29% Earned (nis Period 10 44 Paid last Year 53 53 Paid Year-To-Date $0 00 * Tno interest eamed and the interest paid :nterest is creciited to your account may dif fer depending on when Account Activity Date Description Additions Subtractions Balance 12-16Beginning Balance $;765.31 01-15 EndingBalance $1,76575 pace 2 of 4 CONFIDENTIAL Brem00249872 FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023 EXHIBIT 2 FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1170 RECEIVED NYSCEF: 01/31/2023 Statement Period12/22/14T001/21/15 PREMlER MONEY MARKET- PROMO For your convenienceour Customer ContactCenter 7arn- is available from 8pm EST, 7 daysa week Call usat1-877-768-1143. MSBG11AFO20122105204-00001217-o03--1000 may call 1-800-428-9121 Hearing impaired