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)

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.

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FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1173 RECEIVED NYSCEF: 01/31/2023

EXHIBIT 41
FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1173 RECEIVED NYSCEF: 01/31/2023
1301 Avenue of the Americas
25th Floor
New York, NY 10019

212.812.0400 main
212.812.0399 fax

Stephen P. Younger
212-812-0365 direct
spyounger@foleyhoag.com

December 5, 2022

Via E-mail
Jennifer Borst
Specialist, Small Business & Consumer Operations
Court Ordered Processing
Santander Bank, N.A.
jborst@santander.us

Re: Tekiner v. Bremen House Inc., et al; New York Supreme Court, New York
County, Index No. 657193/2020; Subpoena Issued to Santander Bank, N.A.

Dear Ms. Borst:

I am counsel for Plaintiff Yasemin Tekiner (“Plaintiff”) in the above proceeding. I
write in response to your letter dated November 8, 2022 and the documents Santander Bank,
N.A. (“Santander”) produced in response to Plaintiff’s subpoena dated August 9, 2022 and the
Court’s October 25, 2022 Order. First, thank you for your production to date. As discussed in
detail below, however, Santander’s production is incomplete for a variety of reasons.

Request No. 2

In response to Request No, 2, Santander produced check images and Transaction
Inquiry screenshots rather than the bank statement of accounts held by Berrin Tekiner and/or
Gonca H. Hartmann, with Account Nos. ending 3922 and 2579, from December 22, 2014 to
January 21, 2015. Please produce these complete statements or confirm that Santander no
longer has these statements in its possession.

Further, the contents of the Posted Transactions field in the Transaction Inquiry
screenshots is incomplete because the scroll bars appear to not have been moved left to right
and up and down. In addition, it appears that only content from the Posted Transactions Tab
was provided, but not from the Memo Transactions Tab. Please supplement your production
to include the complete set of fields and tabs so that all the data is visible.

ATTORNEYS AT LAW BOSTON | NEW YORK |PARIS | WASHINGTON |FOLEYHOAG.COM
FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1173 RECEIVED NYSCEF: 01/31/2023
Jennifer Borst
Page 2

Request No. 4

The following documents are missing for the account held by Residuary Trust of
Sami S. Tekiner Berrin Tekiner Trustee, with an Account No. ending in 9285:
 Complete bank statements for 2015, 2016, 2017, 2019, 2020 (except for
March), 2021, and 2022;
 Copies of all checks written in 2015, 2016, 2017, June 2018 through December
2018, 2019, 2020 (except for March), 2021, and 2022;
 Copies of all deposits in 2015, 2016, 2017, 2019, 2020 (except for March),
2021, and 2022; and
 All wire records for 2015, 2016, 2017, 2019, 2020, 2021, and 2022.