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 02/14/2023 09:34 AM         INDEX NO. 657193/2020
NYSCEF DOC. NO. 1260                               RECEIVED NYSCEF: 02/14/2023




                       EXHIBIT R
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM                                              INDEX NO. 657193/2020
NYSCEF DOC. NO. 1260                                                                   RECEIVED NYSCEF: 02/14/2023
                                                                                              Writer’s Direct Contact:
                                                                                                   908.333.6220 (Tel.)
   PARKER IBRAHIM & BERG LLP                                                                       212.596.7036 (Fax)
                                                                                             scott.parker@piblaw.com
                                                                                                      www.piblaw.com



         October 20, 2022

         VIA E-MAIL
         Meghan E. Hill, Esq.
         Pryor Cashman LLP
         7 Times Square
         New York, New York 10036-6569

                Re:     Yasemin Tekiner, et al. v. Bremen House Inc., et al.
                        Index No.: 657193/2020

         Dear Meghan:

                Kindly allow this letter to memorialize the reiterated demand of Plaintiff Yasemin Tekiner
         (“Yasemin”) that Defendants produce Sadan Gurbuzturk (“Ms. Gurbuzturk”) for her duly noticed
         deposition without further delay.

                On September 17, 2022, Yasemin noticed Ms. Gurbuzturk’s deposition for October 14,
         2022. Defendants declined to comply. Instead, on September 27, 2022, Defendants stated that
         “[w]ith respect to Sadan Gurbuzturk, an employee of the Company Defendants, pursuant to CPLR
         3106(d), Gonca Tekiner Chelsea, President of Bremen House, Inc., will be produced in place of
         Ms. Gurbuzturk.” Defendants failed to provide any justification for this substitution.

                  At Ms. Chelsea’s deposition conducted on October 12, 2022, she testified that she “[didn’t]
         know” that “she’s here” for Sadan, and that nobody ever told as much. See Tr. 4:15-5:4. Moreover,
         Ms. Chelsea testified that “accounting stuff” was not her “area of expertise” – and, when Ms.
         Chelsea was asked if she was familiar with the bookkeeping of the Company Defendants, she
         testified: “I am familiar with what I need to do my job but I’m not the bookkeeper so this would
         be a question more for accounting or bookkeeping.” See Tr. 90:14-90:25. She identified Ms.
         Gurbuzturk as the bookkeeper who was familiar with the books and records of the Company
         Defendants, who used QuickBooks to keep the accounting (a program Ms. Chelsea testified she
         did not use), and to whom she would turn for documents printed off QuickBooks. See Tr. 91:2-
         25. Further, Ms. Chelsea testified that Ms. Gurbuzturk “tracks bills” and “tracks rents” for the
         Company Defendants, and provides information to the Company Defendants’ accountants to
         prepare their financial statements. See Tr. 101:12-102:11. As such, at the conclusion of Ms.
         Chelsea’s deposition, Yasemin reserved all of her rights – including, but not limited to, seeking
         Ms. Gurbuzturk’s deposition. See Tr. 242:14.




             New York Office: 5 Penn Plaza, Suite 2371 – New York, New York 10001 – 212.596.7037
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                    BOSTON – NEW JERSEY – NEW YORK – ORANGE COUNTY – PHILADELPHIA
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM                                              INDEX NO. 657193/2020
NYSCEF DOC. NO. 1260                                                                    RECEIVED NYSCEF: 02/14/2023




                 It is plain that Ms. Chelsea’s testimony is no substitute for Ms. Gurbuzturk’s testimony,
         which is relevant and necessary to the claims and defenses at issue in this litigation. Accordingly,
         Yasemin requests that, by no later than 4 pm on October 21, 2022, Defendants provide at least
         three dates in November 2022 that Ms. Gurbuzturk is available to be deposed in person at Foley
         Hoag LLP, 1301 Avenue of the Americas, New York, New York 10019. To the extent that
         Defendants believe a new deposition notice is required to compel Ms. Gurbuzturk’s attendance in
         person, kindly let us know on or before this date, and we will serve another notice.

                If Defendants fail to confirm that Ms. Gurbuzturk will be produced for an in-person
         deposition within the timeframe set forth in this letter, Yasemin will move to compel her
         attendance, and will seek any associated fees and costs from Defendants.
                                                                      Very truly yours,



                                                                      Scott W. Parker
         cc:    Stephen P. Younger, Esq. (via email)
                Michele Kahn, Esq. (via email)




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