On December 21, 2020 a
Exhibit,Appendix
was filed
involving a dispute between
Yasemin Tekiner,
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,
and
254-258 W. 35Th St. Llc,
Berrin Tekiner,
Billur Akipek
In Her Capacity As A Trustee Of The Yasemin Tekiner 2011 Descendants Trust,
Bremen House Inc.,
Bremen House Texas, Inc.,
German News Company, Inc.,
German News Texas, Inc.,
Gonca Tekiner,
Zeynep Tekiner,
for Commercial Division
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 04/03/2023 11:45 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1521 RECEIVED NYSCEF: 04/03/2023
EXHIBIT G
FILED: NEW YORK COUNTY CLERK 04/03/2023 11:45 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1521 RECEIVED NYSCEF: 04/03/2023
March 31, 2023
Yng Email
Ms. Berrin Tekiner, Chairman of the Board of Directors
Bremen House, Inc.
85'
200 East Street (lB)
New York, NY 10028
RE: Our February 15. 2-023_QgmandAr jSpecial-B_aanUHeeEng
Dear Berrin,
We write in response to your March 30, 2023 correspondence, in which you responded to
our March 30, 2023 correspondence
advising you that your proposal to hold a Special Meeting at
Pryor Cashman's office was inappropriate, inconsistent with the By-Laws of Bremen House, Inc.
(the "Company"), and part of your longstanding pattern of improperly involving your and the
Company's litigation counsel in the everyday affairs of Company business.
Unfortunately, your March 30 correspondence ignores all of these legitimate concems
You do not even commit to precluding Pryor Cashman from participating in the meeting: rather
all you say is that you d9not "intend" for them to participate. Nor does your suggestion that our
counsel are "welcome" to attend the meeting cure the underlying problem: you are still
unwilling to conduct Company business separate fmm the litigation, despite Judge Cohen's
specific directives to the contrary. Indeed, it is telling that your response to our stating that we
need accurate information regarding how the Company is spending its money is to point right
back to limited documents and deposition testimony from the litigation itself
Under these entirely improper and unethical circumstances, we will not be attendmg the
Special Meeting on April 3-as you have made quite clear that it will be nothmg more than a
sham meeting orchestrated by your and the Company's outside litigation counsel. As fiarther
evidence that this is intended only as a sham meeting, we also note that the Company
bookkeeper-Sadan Gurbuzturk-just testified earlier today that she was not aware of any
meeting scheduled for April 3 and had not been asked to provide any financial report3ng or
information in connection with such meeting. To the extent that you nonetheless choose to
proceed, we reserve the right to challenge any and all actions that may be taken at that time.
Sin ly,
Ya in Tekmer Zeynep Tekiner
Document Filed Date
April 03, 2023
Case Filing Date
December 21, 2020
Category
Commercial Division
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