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)

• 
• 
• 
• 
• 
• 

						
                                
Preview
                                FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM         INDEX NO. 657193/2020
NYSCEF DOC. NO. 1315                               RECEIVED NYSCEF: 02/17/2023




                       EXHIBIT B
FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM                                                       INDEX NO. 657193/2020
NYSCEF DOC. NO. 1315                                                                           RECEIVED NYSCEF: 02/17/2023




    From:                             Scott Parker 
    Sent:                             Friday, August 19, 2022 2:38 PM
    To:                               Hill, Meghan E.
    Cc:                               Younger, Stephen P.; Sanjay Ibrahim
    Subject:                          Tekiner v Bremen House (Index No. 657193/2020) - books and records [PIB-
                                      LEGAL_DMS.FID449713]


    **EXTERNAL**

    Meghan, this is in furtherance to our recent conversation. We are still missing at least the following books and records:

        1. Financials for 254-258 West 35th Street LLC for 2021 and 2022.

        2. Documents reflecting a breakdown of the “gross payroll” line item of $1,272,356.68 from the 2021
           Bremen House Profit & Loss statements (i.e., Brem00357457, Brem00357487, Brem00357497).

        3. The tax returns for Yasemin’s Trust for 2020 and 2021.

                a. NOTE: Yasemin first asked for these in her e-mail to Billur on July 5, which has still gone
                   unanswered.

        4. Bremen House’s tax return for 2021.

        5. The Bremen House log-in for Marcus Millichap, along with updated sales listings for the West 35 th
           Street Property.

                a. NOTE: Yasemin had an e-mail exchange with John Stewart about this on July 14, but she has
                   received no response since.

        6. Accounting for the Companies for 2020-present (Quickbooks or ledgers), given that the funds identified
           on the profit and loss general statements that you produced cannot otherwise be tracked.

        7. All documents or other records relating to the terms of purchase and the source of the purchase price for
           the purchase for an apartment located at 124 East 79th Street.

        8. Documents reflecting the current balances in the Company’s bank accounts.

                a. NOTE: Yasemin first asked for this in her e-mail to Sadan on July 5, which has still gone
                   unanswered.

        9. Documents reflecting the distribution of the sale proceeds for 1320 Madison, the sale of which occurred
           in April 2022 for $4,075,000.00.

        10. A current listing of any mortgages or other debts of the Companies.

        11. A current listing of any outstanding property taxes owed by the Companies.

                                                                1
FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM                                                                                 INDEX NO. 657193/2020
NYSCEF DOC. NO. 1315                                                                                                   RECEIVED NYSCEF: 02/17/2023

         12. Documents reflecting the distribution of proceeds from the Extell sale (apart from the $25 million
             reinvested in the triple nets).

         13. Documents concerning the lack of good standing of Bremen House Texas, German News Texas, and
             German News Corp., and possibly Bremen House Inc.

                   a. NOTE: Yasemin first asked about this in correspondence to Berrin, Gonca, and Billur on May 23,
                      which has still gone unanswered.

         14. All board materials, including but not limited to, meeting minutes, agendas, notes decks, presentation
             material, consents and/or resolutions.

    Regards,
    Scott

    Scott Parker
    NJ Office: 270 Davidson Avenue, Somerset, NJ 08873
    NY Office: 5 Penn Plaza, Suite 2371, New York, NY 10001
    Direct: +1 908.333.6220 | Main: +1 212.596.7037
    www.piblaw.com




    Confidentiality:
    This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized
    review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, contact the sender via reply email and destroy all
    copies of the original message.




                                                                                2