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)

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                                FILED:         NEW     YORK       COUNTY        CLERK        01/31/2023             04:02        AM                 INDEX    NO.   657193/2020
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   FILED:         NEW     YORK       COUNTY        CLERK        01/31/2023             04:02        AM                 INDEX    NO.   657193/2020
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         From:                                 Topping, Sean
         Sent:                                 Tuesday, November 23, 2021 11:22 AM
         To:                                   Evan Mandel; Leah Vickers
         Cc:                                   Shomik Ghosh; Younger, Stephen P.; McDonough, Joanna; Archer, Judith A.; Corder,
                                               Victoria; Ward, Luke
         Subject:                              Tekiner v. Bremen House - Aykal Documents & Deposition


         Evan and Leah,

         I wanted to follow up with you concerning issues raised at last week’s meet and confer concerning Gurer and the NRF
         subpoena.

         As it concerns the subpoena to NRF, we informed you that the Defendants already collected and produced certain final
         corporate and trust files in the possession of NRF that were not privileged.        We also reiterated our objections to the
         subpoena to NRF as overly broad and unduly burdensome in that it seeks documents that are predominately privileged
         and, to the extent they are not, are likely to be in our clients’ possession and already produced to the extent
         responsive.   We did, however, agree to get a better sense of the scope of the universe of communications in NRF’s
         possession that exist between NRF and Third Parties and that pre-date the litigation.          That is underway and we
         anticipate having a response regarding what production NRF will make, if any, next week.

         As it concerns the subpoena duces tecum to Gurer Akyal, we reiterated that Mr. Akyal is not relevant to this dispute by
         virtue of the fact that he has nothing to do with the management of the Companies or Yasemin’s Trust, and that we
         have declined to search his documents for the reasons stated in our objections and responses to the subpoena.                We
         again noted that his communications with Berrin will be subject to the spousal privilege.           We agreed on the call that the
         parties appear to be an impasse on his documents; however, in an effort to resolve this dispute without court
         intervention, we agree to search for and produce any documents, to the extent they exist, reflecting any benefit Mr.
         Aykal received from the Companies.

         As it concerns Mr. Aykal’s deposition, we reiterated what we told you previously – that we will produce Mr. Aykal for a
         deposition concerning the topic of whether he received any benefits from the companies, but we object to your asking
         him questions about irrelevant and personal topics, including the health and mental conditions of individual
         defendants.    When we raised this objection with you at a prior meet and confer concerning Mr. Aykal, you had seemed
         to understand our position.     However on last week’s call, you attempted to argue that such an objection was
         improper.   It is not improper and we reiterate our objection in writing and our intent to instruct him not to answer such
         questions.   We will not permit Mr. Aykal to testify about irrelevant, private, highly sensitive mat ters concerning Berrin or
         Gonca’s alleged health and mental states.

         Of further concerning note, you made a representation on the call concerning Mr. Akyal that is false and we must
         correct your misunderstanding.      The Companies have not purchased or rented a house in Turkey for Mr. Aykal, as you
         claimed they have.

         Best,
         Sean

         Sean Topping | Associate
         Pronouns: he / him / his
         Norton Rose Fulbright US LLP
         1301 Avenue of the Americas, New York, New York            10019-6022, United States
         Tel +1 212 318 3361 | Fax +1 212 318 3400
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   FILED:         NEW     YORK       COUNTY        CLERK        01/31/2023             04:02        AM                 INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   1190                                                                               RECEIVED      NYSCEF:     01/31/2023
         sean.topping@nortonrosefulbright.com

         NORTON ROSE FULBRIGHT

         Law around the world
         nortonrosefulbright.com




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