Preview
FILED: NEW YORK COUNTY CLERK 01/31/2023 04:02 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1191 RECEIVED NYSCEF: 01/31/2023
EXHIBIT 59
FILED: NEW YORK COUNTY CLERK 01/31/2023 04:02 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1191 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 Index No. 657193/2020
a holder of equitable interests in a
shareholder or a member of the Company Commercial Division Part 3
Defendants,
Hon. Joel M. Cohen
Plaintiff,
-against- NOTICE OF SUBPOENA
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.
1
FILED: NEW YORK COUNTY CLERK 01/31/2023 04:02 AM INDEX NO. 657193/2020
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PLEASE TAKE NOTICE THAT, pursuant to CPLR 3120, Plaintiff Yasemin Tekiner
intends to serve non-party Philip J. Michaels of Norton Rose Fulbright US LLP with the attached
Subpoena Duces Tecum and Ad Testificandum seeking the production of documents on October
10, 2022, and deposition on October 17, 2022.
Dated: New York, New York
September 19, 2022
/s/ Scott W. Parker
Sanjay P. Ibrahim
Scott W. Parker
Daniel A. Schleifstein
PARKER IBRAHIM & BERG LLP
5 Penn Plaza, Suite 2371
New York, NY 10001
Telephone: (212) 596-7037
sanjay.ibrahim@piblaw.com
scott.parker@piblaw.com
daniel.schleifstein@piblaw.com
- and -
Stephen P. Younger
FOLEY HOAG LLP
1301 Avenue of the Americas, 25th Floor
New York, NY 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 04:02 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1191 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 Index No. 657193/2020
a holder of equitable interests in a
shareholder or a member of the Company Commercial Division Part 3
Defendants,
Hon. Joel M. Cohen
Plaintiff,
-against- SUBPOENA DUCES TECUM
AND AD TESTIFICANDUM
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.
1
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NYSCEF DOC. NO. 1191 RECEIVED NYSCEF: 01/31/2023
To: Philip J. Michaels
Norton Rose Fulbright US LLP
1301 Avenue of the Americas
New York, NY 10019-6022
WE HEREBY COMMAND YOU that, all business and excuses being laid aside, to
produce at Parker Ibrahim & Berg LLP, c/o Scott W. Parker, Esq., 270 Davidson Avenue, 5th Floor,
Somerset, NJ 08873, on or before October 10, 2022, the documents requested on Schedule A
annexed hereto.
WE ALSO COMMAND YOU to appear and testify before a Notary Public or other person
so qualified to act, at a remote deposition to be conducted by videoconference or other remote
means on October 17, 2022, at 9:00 a.m. (Prevailing Eastern Time), concerning the subject matter
set forth in Schedule B. The deposition will continue day to day until complete and will be
recorded by stenographic means and video recorded.
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 testimony is required in order to establish certain facts
in the above-captioned case relating, inter alia, to the properties owned by Bremen House, Inc.,
Bremen House Texas, Inc., German News Company, Inc., German News Texas, Inc., and/or 254
– 258 W. 35th St. LLC (the “Companies”), the management of properties owned by the
Companies, profits and losses of the Companies, and compensation of the Companies’ directors,
officers and employees.
PLEASE TAKE FURTHER NOTICE that this examination shall be recorded by
stenographic means and videotaped, pursuant to CPLR 3113 and 22 N.Y.C.R.R. § 202.15. In
accordance with 22 N.Y.C.R.R. § 202.15, please be advised that the videotape operator will be an
employee or agent of counsel for Plaintiff.
2
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NYSCEF DOC. NO. 1191 RECEIVED NYSCEF: 01/31/2023
Dated: New York, New York
September 19, 2022
/s/ Scott W. Parker
Sanjay P. Ibrahim
Scott W. Parker
Daniel A. Schleifstein
PARKER IBRAHIM & BERG LLP
5 Penn Plaza, Suite 2371
New York, NY 10001
Telephone: (212) 596-7037
sanjay.ibrahim@piblaw.com
scott.parker@piblaw.com
daniel.schleifstein@piblaw.com
- and -
Stephen P. Younger
FOLEY HOAG LLP
1301 Avenue of the Americas, 25th Floor
New York, NY 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
3
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NYSCEF DOC. NO. 1191 RECEIVED NYSCEF: 01/31/2023
SCHEDULE A
DEFINITIONS
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 “Norton Rose” shall refer to Norton Rose Fulbright US LLP and any of
its subsidiaries, affiliates, predecessors, successors, employees, contractors, agents, advisors,
professionals, directors, officers, or any other entity related thereto.
4. 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.
5. The term “Trust” shall refer to The Yasemin Tekiner 2011 Descendants Trust.
6. The term “communication” means the transmittal of information (in the form of
facts, ideas, inquiries, or otherwise), and may be written or oral.
7. 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).
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8. 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
FILED: NEW YORK COUNTY CLERK 01/31/2023 04:02 AM INDEX NO. 657193/2020
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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.
9. The terms “You” or “Your” shall be construed in its broadest sense and shall refer
to (i) you, Philip J. Michaels, and any of your predecessors, successors, affiliates, partners, agents,
employees, accountants, lawyers and/or any other person(s) acting on your behalf; and (ii) Norton
Rose and any of its parent companies, subsidiary companies, predecessors, successors, affiliates,
partners, and any or all of their stockholders, agents, employees, accountants, lawyers and/or any
other person(s) acting on their behalf.
INSTRUCTIONS FOR DOCUMENT REQUESTS
1. Unless otherwise specified, the production of documents called for in these requests
covers the period 2011 to the present. Notwithstanding, to the extent any document created before
that date pertains to the subject matter of the requested, it should be produced in response to these
requests.
2. Documents should be produced in their entirety without abbreviation or
expurgation.
3. 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;
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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. In the event that any matter called for in a request has been destroyed, that item
should be identified as follows: sender, recipient, each recipient copied or blind copied; date,
subject matter, number of pages, attachments or appendixes; all persons to whom distributed,
shown or explained; date of destruction, manner of destruction, reason for destruction, person
authorizing destruction and person destroying the document(s).
9. These requests are continuing, and require further and supplemental production if
the recipient receives or generates additional matter between the time of original production and
the time of trial.
10. If any matter covered by a request is no longer in your possession, custody or
control, describe the matter in detail and identify the present custodian.
11. Each page of a produced document shall have a legible, unique page identifier
(“Bates Number”) on the face of the image in a location that does not obliterate, conceal or interfere
with any information from the source document.
12. Electronic records and computerized information must be produced with all
metadata preserved and intact.
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REQUESTS FOR DOCUMENTS
1. All engagement letters between You and Defendants, Yasemin, or Zeynep Tekiner,
or any trust or entity created, owned or affiliated with Defendants, Yasemin, or Zeynep Tekiner.
2. Documents sufficient to identify all of Your attorneys and employees who have
provided services to or for the benefit of Defendants, Yasemin, or Zeynep Tekiner, or any trust or
entity created, owned or affiliated with Defendants, Yasemin, or Zeynep Tekiner.
3. All invoices for services that you have provided to or for the benefit of Defendants,
Yasemin, or Zeynep Tekiner, or any trust or entity created, owned or affiliated with Defendants,
Yasemin, or Zeynep Tekiner.
4. Documents sufficient to identify all payments made for services provided to or for
the benefit of Defendants, Yasemin, or Zeynep Tekiner, or any trust or entity created, owned or
affiliated with Defendants, Yasemin, or Zeynep Tekiner, including but not limited to the payor,
the payment date, and payment amount.
5. All documents concerning any trust created by Sami Tekiner.
6. All documents concerning any will of Sami Tekiner.
7. All documents concerning the estate of Sami Tekiner.
8. All communications with Defendants.
9. All communications with Yasemin.
10. All communications with Zeynep Tekiner.
11. All documents and correspondence related to the sale or contemplated sale of
properties owned by the Companies to Extell or other buyers, including but not limited to, any
final or draft contracts, correspondence related to negotiations with the prospective buyers, the
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status of any down payments for the sales, how the sales prices were set, the status of any pre-
closing conditions and the status of any closings.
12. All documents concerning any offers for or due diligence conducted by Extell or
any other potential buyers of those properties.
13. All documents and communications concerning any advice provided by Norton
regarding the Extell sale and how the Companies responded to such advice.
14. All analyses provided or prepared by real estate advisors concerning any properties
owned by the Companies.
15. All documents related to any appraisals of any properties owned by the Companies.
16. All documents and communications related to or concerning Yasemin’s removal as
a Trustee of the Trust in 2017 and 2020/2021.
17. All documents and communications related to or concerning Yasemin’s removal as
Director or Officer of the Companies in 2017 and 2020/2021.
18. All documents and communications concerning Yasemin’s potential or actual
removal, termination, or resignation from any position at the Companies or any trust.
19. All documents and communications concerning Zeynep Tekiner’s potential or
actual removal, termination, or resignation from any position at the Companies or any trust.
20. All documents and communications concerning Gonca Tekiner’s potential or actual
removal, termination, or resignation from any position at the Companies or any trust, including
but not limited to Your communications regarding Gonca’s actual termination.
21. All documents and communications concerning any loss of Yasemin’s access to the
Companies’ electronic systems, including the Companies’ servers and email system.
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22. All documents and communications related to or concerning Yasemin’s
termination as an employee of the Companies in 2021 and her performance as an employee for the
last ten years.
23. All documents, including all communications, concerning the termination of
Weitzman Associates.
24. All documents, including all communications, concerning any analyses,
recommendations or information provided by Weitzman Associates.
25. All documents concerning any bills rendered by Weitzman Associates for its
services and any payments made by the Companies of such bills.
26. All documents and communications concerning Gonca Tekiner’s employment
agreement as President and CEO of Bremen House, Inc.
27. All documents and communications concerning Gonca Tekiner’s performance as
director, officer or employee at any of the Companies, including but not limited to all reviews,
reports, performance improvement plans or recommendations concerning her performance.
28. All documents and communications concerning any contract, lease or transaction
between any of the Companies and any relative, friend, employee, or independent contractor of an
employee, officer, or director of any of the Companies.
29. All documents and communications relating to payments, benefits, things of value,
or other consideration provided by the Companies to any of their shareholders, directors, officers,
or employees, including but not limited to salaries, bonuses, expense reimbursements,
commissions, consulting fees, pension plan contributions, profit-sharing, use of the Companies’
credit cards, personal services, housing expenses, loans guaranteed by the Companies, interest,
dividends and/or gifts.
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30. All documents and communications concerning any transaction between any of the
Companies and any shareholder, employee, officer, or director of any of the Companies.
31. Any appraisals made of the value of any properties owned by the Companies.
32. All documents concerning the Companies’ solicitation or receipt of offers to
purchase any of the Companies’ assets.
33. All documents or communications concerning the re-investment, including through
what is known as a 1031 exchange, of the sales proceeds from the sale of certain Manhattan real
estate to Extell.
34. All documents or communications reflecting or relating to Defendants’ assertion
that Yasemin demanded to receive a portion of the sales proceeds from the sale of certain
Manhattan real estate to Extell.
35. All documents including all communications concerning any request by any
director or shareholder of the Companies to inspect the Companies’ books and records, including
but not limited to correspondence between Yasemin and the Companies.
36. All studies, reviews, examinations or recommendations concerning compensation
paid to the Companies’ officers, directors, employees and/or shareholders.
37. All documents including all communications concerning any actual, potential, or
apparent conflict of interest of any employee, officer, and/or director of the Companies.
38. All documents including all communications concerning any actual, potential, or
apparent conflict of interest of any trustee, protector, trustee committee member of the Trust or
any other trust that, directly or indirectly, has an interest in any of the Companies.
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39. All documents and communications regarding any consideration given by any of
the Defendants to dividing up the assets of the Companies among their shareholders, including but
not limited to the tax implications of doing so.
40. All documents concerning the formation of the Trust.
41. All documents concerning any distributions made from the Trust and any
consideration to making distributions.
42. All documents concerning the decision to pay Yasemin’s salary and bonus.
43. All documents concerning the decision not to make distributions to Yasemin from
the Trust.
44. All documents concerning a promissory note between Berrin Tekiner and the Trust
and any payments of principal or interest on such promissory note.
45. All documents concerning any promissory note(s) between Berrin Tekiner and any
trust of which Zeynep Tekiner or Gonca Tekiner is a beneficiary and any payments of principal or
interest on such promissory note(s).
46. All documents concerning the appointment of Billur Akipek as a member of the
Trust Committee of the Trust and any communications with Billur Akipkek about trust affairs.
47. All documents concerning Billur Akipek’s compensation, benefits and employment
arrangements with the companies.
48. All documents concerning any leases or other arrangements Billur Akipek or any
member of her family has in connection with arrangements to live in or stay at any properties
owned by the Companies.
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49. All documents concerning the removal of Aydin S. Caginalp as a Trustee or any
other fiduciary roles in connection with any of the Defendants or any trusts that they may have
settled or of which they may have been beneficiaries.
50. All documents concerning the purchase by the Companies or Berrin Tekiner of a
yacht or boat and any subsequent sale thereof.
51. All documents concerning the purchase by the Companies or Berrin Tekiner of a a
home in the South of France and any subsequent sale thereof.
52. All documents concerning the purchase by the Companies, Gonca Tekiner or Berrin
Tekiner of any apartments located at 30 East 85th Street and any subsequent sales thereof.
53. All documents concerning the purchase by the Companies or Berrin Tekiner of a a
home in the Hamptons area of Long Island and any subsequent sale thereof.
54. All documents concerning the purchase by the Companies or Gonca Tekiner of a
home in Bronxville, New York, including but limited to any mortgages or other financing taken
out by the Companies to pay for that purchase.
55. All documents concerning the Companies’ payment or reimbursement of expenses
of any of the Individual Defendants, including but not limited to: telephone bills; landscaping bills;
housekeeping bills; wages or expenses of a driver or housekeeper; travel expenses; and pet food.
56. All documents concerning any leases or other arrangements made to permit any
friends, relatives or staff of the Defendants to reside in, stay in, or use any of the properties owned
by the Defendants.
57. All documents or communications concerning the reasons why Yasemin moved
into and later moved out of apartments owned by the Companies located on the Bowery or at 1320
Madison Avenue in Manhattan.
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58. All documents concerning the air quality and any noxious fumes at 1320 Madison
Avenue.
59. All documents concerning the purchase by the Companies of a home at in Bel Air,
California, and the source of the funds used to pay for that home, including but not limited to the
proceeds of the sale of an apartment in Manhattan.
60. All documents and communications concerning any rent paid by Yasemin for her
lease of a home in Bel Air, California.
61. All leases entered into by Yasemin or any of the Individual Defendants in
connection with their use of any properties owned by the Companies.
62. All documents concerning the Companies’ sale of a property located on Second
Avenue in Midtown Manhattan during 2006 through 2007 and Yasemin’s role in that transaction.
63. All documents concerning the Companies’ purchase of a property located on the
Bowery in Manhattan and Yasemin’s role in that transaction.
64. All documents concerning the Companies’ consideration of purchasing properties
in Florida.
65. All documents concerning any complaints or concerns Yasemin raised about the
Companies’ operations, management or finances.
66. All documents concerning any performance reviews, evaluations or feedback given
to Yasemin in connection with her employment with the Companies.
67. All documents or communications concerning any steps taken to retaliate against
Yasemin or any other employees of the Companies.
68. All documents concerning any complaints or concerns raised about the Companies’
operations, management or finances.
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69. All documents concerning any training the Companies accounting and financial
staff have had in accounting or financial management.
70. All documents concerning the Companies’ acquisition of properties in Texas.
71. All documents concerning or reflecting the financial performance of the
Companies’ properties in Texas.
72. Any documents or communications concerning the possible loss of any of the
Companies’ Texas properties and the Companies’ need to buy those properties back at auction.
73. All documents concerning any minutes or notes of any of the Companies’ meetings
or events, including but not limited to any minutes of meetings of boards of directors.
74. All documents or communications related to, reflecting, or concerning any racist
comments made or racist actions undertaken by Gonca Tekiner.
75. All documents or communications related to, reflecting, or concerning any
homophobic comments made or homophobic actions undertaken by Gonca Tekiner.
76. All documents or communications related to travel expenses incurred by or on behalf of
Berrin Tekiner.
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SCHEDULE B
DEPOSITION TOPICS
1. Services You provided to Defendants, Yasemin, or Zeynep Tekiner, or any trust or
entity created, owned or affiliated with Defendants, Yasemin, or Zeynep Tekiner.
2. Payment for services You provided to Defendants, Yasemin, or Zeynep Tekiner, or
any trust or entity created, owned or affiliated with Defendants, Yasemin, or Zeynep Tekiner.
3. Any trust created by Sami Tekiner.
4. Any will of Sami Tekiner.
5. Sami Tekiner’s estate.
6. The Trust and any trust or entity created, owned or affiliated with Defendants,
Yasemin, or Zeynep Tekiner.
7. Your communications with Defendants, Yasemin, or Zeynep Tekiner.
8. The value of properties owned by the Companies.
9. Appraisals of any properties owned by the Companies.
10. Assets of the Companies.
11. Purchases of properties by the Companies.
12. The sale or contemplated sale of properties owned by the Companies.
13. The Companies’ solicitation or receipt of offers to purchase any of the Companies’
assets.
14. Mortgages on any of the properties owned by the Companies.
15. Distributions of revenue and/or profits relating to the Companies.
16. Expenses of the Companies.
17. Analyses of any properties owned by the Companies by real estate advisors.
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18. Contracts and transactions between the Companies and any relative, friend,
employee, or independent contractor of an employee, officer, or director of any of the Companies,
including the individual Defendants.
19. Contracts and transactions between the Companies and any shareholder, employee,
officer, or director of any of the Companies, including the individual Defendants.
20. Payments, benefits, things of value, or other consideration provided by