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  • 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)Commercial Division document preview
  • 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)Commercial Division document preview
  • 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)Commercial Division document preview
  • 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)Commercial Division document preview
  • 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)Commercial Division document preview
  • 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)Commercial Division document preview
						
                                

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FILED: NEW YORK COUNTY CLERK 03/27/2023 11:28 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1473 RECEIVED NYSCEF: 03/27/2023 EXHIBIT 14 FILED: NEW YORK COUNTY CLERK 03/27/2023 11:28 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1473 RECEIVED NYSCEF: 03/27/2023 Writer’s Direct Contact: 908.333.6220 (Tel.) PARKER IBRAHIM & BERG LLP 212.596.7036 (Fax) scott.parker@piblaw.com www.piblaw.com October 6, 2022 VIA E-MAIL Meghan E. Hill 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: We write with respect to Zeynep’s visit today to the Company’s office. In sum, your firm made sure the visit would be nothing more than an unacceptable sham that was run exclusively by your firm (in violation of ethical rules), and with no assistance from the Company’s bookkeeper, despite Yasemin’s request. By way of background, on September 29, 2022, Yasemin wrote to Shadan Gurbuzturk to inquire as to the possibility of coming to the office the following week, in order to review the Company ledger. Defendants agreed to allow that office access on October 6, 2022 at 11 am. On October 4, 2022, Yasemin wrote to Shadan and Billur Akipek, asking that they ensure that Shadan was actually going to attend the October 6 meeting, given her role as the Company bookkeeper: “Now that Billur confirmed our meeting for this Thursday at 11am, I’d like to make sure we have at least a few hours to be able to go over the ledger. Shadan, I will need your assistance in running some basic financial reports via the quickbook/accounting system of expenditures, income, profit/loss, breakdowns of the disbursements from all sales from Dec 2020 to present, etc. Please confirm that you will be there for this. Will anyone else be in attendance for the meeting?” (emphasis added) On October 5, 2022, at 3:03 pm, Billur responded that Defendants were gathering the requested bank statements and would provide them when they were ready. Further, Billur said that: (1) between 11 am and 5 pm, Yasemin and Zeynep would be “able to access and review the Quickbooks ledger”, (2) an unidentified “paralegal” would be there with the log-in credentials, and (3) “no one else will be there during that time” (including Shadan, despite Yasemin’s request). New York Office: 5 Penn Plaza, Suite 2371 – New York, New York 10001 – 212.596.7037 New Jersey Office: 270 Davidson Avenue – Somerset, New Jersey 08873 – 908.725.9700 BOSTON – NEW JERSEY – NEW YORK – ORANGE COUNTY – PHILADELPHIA FILED: NEW YORK COUNTY CLERK 03/27/2023 11:28 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1473 RECEIVED NYSCEF: 03/27/2023 On October 5, 2022, at 4:47 pm, Yasemin responded to Billur, noting among other things that Billur’s proposed arrangement impeded Yasemin’s ability to perform as a director and officer. Yasemin also questions the need for a paralegal to oversee the books and records of the Company, given that the Company already has a full time bookkeeper on the payroll. Billur did not respond to Yasemin. On October 6, 2022, at 11 am, Zeynep arrived at the Company’s office, with Yasemin also attending the meeting telephonically. Zeynep was met by an individual who only identified himself as “Robert”, and who we (eventually) learned was an employee of Pryor Cashman. He advised that he was there only to “monitor” Zeynep and would not otherwise help in granting Zeynep access to QuickBooks – which is exactly why Shadan’s presence during this meeting was necessary. He also said that, to the extent Yasemin and Zeynep actually wanted any files, they were required to request those reports through you and the attorneys at your firm. Zeynep gathered whatever information she could, but the visit ended up being largely meaningless thanks to Shadan’s absence (or anyone else that could actually assist). It is evident that this visit was simply part of Defendants’ orchestrated plan to create the appearance of granting Yasemin and Zeynep Company access, while in fact failing to provide any meaningful access. Further, the visit (and the idea that Yasemin and Zeynep need to first go to you to obtain any reports through you) is directly contrary to Justice Cohen’s comments at the July 1, 2022 hearing that, as a director, Yasemin does not need to go through litigation discovery in order to obtain information about the company. Frankly, you should not be involved at all in the generation of Company reports. Finally, your paralegal speaking directly to Zeynep violated Rule 4.2 of the Rules of Professional Conduct, given that Zeynep is represented by counsel. The fact that it was a paralegal, as opposed to an attorney, is irrelevant: pursuant to Rule 8.4, a lawyer or law firm shall not “violate or attempt to violate the Rules of Professional Conduct, knowingly assist or induce another to do so, or do so through the acts of another.” And, we note that you did not even disclose to us before today’s meeting that a paralegal from your office was going to be there – and all Billur said was that “a” paralegal would attend. Very truly yours, Scott W. Parker cc: Stephen P. Younger, Esq. Michele Kahn, Esq. 2