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)

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.

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK

GONCA TEKINER CHELSEA, and BREMEN Index No:
HOUSE, INC.,
SUMMONS
Plaintiffs,

- against -

YASEMIN TEKINER and ZEYNEP TEKINER,

Defendants.

To the Above-Named Defendants:

You are hereby summoned to answer the verified complaint in this action and to serve a
copy of your answer on the Plaintiffs’ attorneys within 20 days after the service of this summons
(or within 30 days after the service is complete if this summons is not personally delivered to you
within the State of New York); and in case of your failure to appear or answer, judgment will be
taken against you by default for the relief demanded in the complaint.

Plaintiffs designate New York County as the place of trial. The basis of venue is that a
substantial part of the events giving rise to the claims asserted herein occurred in the County of
New York.

Dated: New York, New York PRYOR CASHMAN LLP
May 9, 2023

By:_____________________________
Todd E. Soloway
Bryan T. Mohler
Clare P. Tilton
Lawrence P. Keating
7 Times Square
New York, New York 10036
Attorneys for Plaintiffs

TO: Yasemin Tekiner
10819 Vicenza Way
Los Angeles, California

Zeynep Tekiner
31 White Plains Road
Bronxville, New York

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SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK

GONCA TEKINER CHELSEA, and BREMEN Index No:
HOUSE, INC.,
VERIFIED COMPLAINT
Plaintiffs,

- against -

YASEMIN TEKINER and ZEYNEP TEKINER,

Defendants.

Plaintiffs Gonca Tekiner Chelsea and Bremen House, Inc., by their attorneys, Pryor

Cashman LLP, for their Verified Complaint as against the above-named defendants, respectfully

allege as follows:

NATURE OF ACTION

1. In 1999, non-party Berrin Tekiner (“Berrin”) created a trust for the maintenance of

a life insurance policy payable upon her death, for the benefit and protection of her family (the

“Life Insurance Trust”).

2. The beneficiaries under both the Life Insurance Trust and the insurance policy (the

“Policy”) are Berrin’s three daughters, Gonca Tekiner Chelsea (“Gonca”), Yasemin Tekiner

(“Yasemin”), and Zeynep Tekiner (“Zeynep”, together with Berrin, Gonca, and Yasemin, the

“Tekiners”). The Life Insurance Trust’s only asset is the Policy.

3. The Life Insurance Trust is responsible for paying the Policy premiums. To

facilitate payment of the premiums, in January 2000, the Life Insurance Trust’s sole trustee

(hereinafter, the trustee of the Life Insurance Trust shall be referred to as the “Trustee”), acting on

behalf of the Life Insurance Trust, entered into a Split-Dollar Life Insurance Collateral Assignment

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Agreement (the “Split-Dollar Agreement”), dated January 19, 2000, with plaintiff Bremen House,

Inc. (“Bremen House”), a company owned and managed by the Tekiners.

4. Under this agreement, Bremen House pays the insurance premiums necessary to

maintain the Policy and is entitled to recoup all sums paid from the Policy proceeds upon Berrin’s

death or upon surrender of the Policy.

5. Yasemin was appointed Trustee in 2014 and has served as sole Trustee ever since.

6. In December 2020, Yasemin initiated a derivative lawsuit against Bremen House,

Berrin and Gonca (the “Lawsuit”).

7. In April 2022, Zeynep joined the action as an intervenor-plaintiff.

8. In early 2022, Yasemin and Zeynep (“Defendants”) decided to pursue litigation

financing to fund the Lawsuit.

9. Defendants entered into a series of agreements to secure such financing, including

a litigation funding agreement with the Statera Capital, LLC (“Statera”). Statera describes itself

as “the leading commercial litigation financing source for midsize investments.”

10. Defendants also entered into a payment agreement, dated May 11, 2022, between

Defendants and their respective counsel in the Lawsuit (the “Payment Agreement”).

11. In February 2023, Yasemin publicly filed a heavily redacted copy of the Payment

Agreement. That document showed, to Plaintiffs’ surprise, that the Life Insurance Trust is a party

to the Payment Agreement (for which Yasemin signed as Trustee).

12. Gonca repeatedly demanded that Yasemin explain why the Life Insurance Trust is

a party to the Payment Agreement.

13. Gonca also demanded that Yasemin explain whether she has pledged or otherwise

encumbered the Life Insurance Trust to secure funding for the Lawsuit against Plaintiffs (among

others).

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14. Yasemin has refused to explain why the Life Insurance Trust executed the Payment

Agreement.

15. There is no legitimate explanation for why the Life Insurance Trust would have

executed the Payment Agreement or why Yasemin refuses to tell a beneficiary why she did so on

behalf of the Life Insurance Trust.

16. Yasemin has acted in contravention of the Life Insurance Trust.

17. The terms of the Berrin Isguden Tekiner Irrevocable Trust, dated

December 23, 1999 (the “Trust Agreement”) created the Life Insurance Trust, defined the duties

of the Trustee, and specified the Trustee’s obligations with respect to maintenance of the Policy.

18. The Trust Agreement’s terms demonstrate that the Life Insurance Trust exists for

the purpose of holding and maintaining the Policy.

19. The Trust Agreement patently does not contemplate or empower the Trustee to use

her position as Trustee to fund unrelated litigation or to use the Life Insurance Trust as an asset or

collateral in doing so.

20. Yasemin’s encumbrance of the Life Insurance Trust was also a violation of the

Split-Dollar Agreement by which Bremen House agreed to pay premiums on the Policy.

21. Pursuant to the Split-Dollar Agreement, the Trustee specifically agreed “not [to]

take any action which, directly or indirectly, would impair or impede [Bremen House’s] right” to

repayment of the premiums it paid on the Policy.

22. Bremen House’s rights under the Split-Dollar Agreement include “the unqualified

right to receive a portion of [Berrin Tekiner’s] death benefit equal to the lesser of the total amount

of the premiums paid by it hereunder or the then cash surrender value of the Policy.” (Split-Dollar

Agreement § 9(b).)

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23. As a result of Yasemin’s unauthorized acts on behalf of the Life Insurance Trust

and breaches of her fiduciary duties to Gonca, and Zeynep’s encouragement and participation,

Gonca has been forced to defend herself – including by retaining counsel – in the Lawsuit.

24. Yasemin’s unauthorized acts on behalf of the Life Insurance Trust are a breach of

the Split-Dollar Agreement, pursuant to which Bremen House has paid over $2 million in

premiums.

PARTIES

25. Plaintiff Gonca Tekiner Chelsea is an individual who resides at 19 Keyser Road

Westport, CT 06880. She is a beneficiary of the Life Insurance Trust.

26. Plaintiff Bremen House is a New York corporation with its principal place of

business located at 200 East 85th Street, New York, NY 10028.

27. Defendant Yasemin Tekiner is a resident of California. Yasemin has been Trustee

of the Life Insurance Trust since June 2014 and is a beneficiary of the Life Insurance Trust.

28. Defendant Zeynep Tekiner is a resident of New York. She is also a beneficiary of

the Life Insurance Trust.

JURISDICTION

29. This Court has jurisdiction over this action pursuant to CPLR §§ 301 and 302

because (1) Yasemin serves as Trustee of the Life Insurance Trust, which is located in and

governed by New York law, and she encumbered the Life Insurance Trust by entering into a New

York contract; and (2) Zeynep is domiciled in New York.

30. Venue is proper pursuant to CPLR § 503(a) because a substantial part of the events

giving rise to the claims asserted herein occurred in the County of New York.

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FACTS

A. The Trust Agreement Establishes the Life Insurance Trust and Defines Its Purpose

31. Berrin Tekiner (“Berrin”) is the mother of three adult daughters: Gonca, Yasemin

and Zeynep.

32. On December 23, 1999, when Berrin was 55, she established the Life Insurance

Trust.

33. One month later, on January 19, 2000, Berrin obtained a life insurance policy (the

“Policy”) from The United States Life Insurance Company in the City of New York. A true and

correct copy of the agreement that created the Life Insurance Trust (the “Trust Agreement”) is

attached hereto as Exhibit A.

34. The Policy is, and has always been, the Life Insurance Trust’s only asset.

35. During Berrin’s life, the purpose of the Life Insurance Trust is to maintain the

Policy, which Berrin obtained for the benefit and protection of her family.

36. Pursuant to the Trust Agreement, the beneficiaries of the Life Insurance Trust are

Berrin’s children—Gonca, Yasemin and Zeynep. (Ex. A ¶ 4(a).)

37. The Trust Agreement contemplates that the Life Insurance Trust will hold one or

more policies of insurance on Berrin’s life.

38. Section 9(a) of the Life Insurance Trust identifies the affirmative duties of the

Trustee.

39. During Berrin’s life, the duties of the Trustee with respect to the Policy:

“shall consist solely of the following: (i) [t]o hold and safeguard [the Policy]; (ii) [t]o pay
premiums due on any such policies when, and only when, cash sums are held by or
deposited with my Trustee sufficient to pay the same . . . (iii) [t]o receive any sum or sums
which may be paid to my Trustee by the insurance carrier . . . and to hold the same subject
to provisions of this agreement”. (Id. § 9(a).)

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40. When Berrin created the Life Insurance Trust in 1999, Aydin S. Caginalp

(“Caginalp”) accepted appointment as Trustee. Caginalp remained trustee until 2014.

B. The Trustee and Bremen House Enter Into the Split-Dollar Agreement

41. On January 19, 2000, Bremen House entered into the Split-Dollar Agreement with

Berrin and Caginalp in his capacity as Trustee. A true and correct copy of the Split-Dollar

Agreement is attached hereto as Exhibit B.

42. The Split-Dollar Agreement is “subject to, governed by and [to be] construed under

the laws of the State of New York.” (Ex. B § 15.)

43. Pursuant to the Split Dollar Agreement, Bremen House agreed to “make each

premium payment . . . on the Policy less the amount, if any, that the Trustee, in his sole and absolute

discretion, shall determine to pay, directly to the insurance company.” (Ex. B § 3.)

44. Bremen House has fulfilled its obligations under the Split-Dollar Agreement and

paid premiums on the Policy for the last 23 years.

45. Under the Split-Dollar Agreement, Bremen House’s obligation to make payment

of the premiums due on the Policy is subject to its right to recover the amount of its premium

payments.

46. The parties to the Split-Dollar Agreement – Berrin, the Trustee, and Bremen House

– agreed that such repayments would be made from either the cash surrender value of the Policy

(in the event the Trustee surrenders or cancels the Policy) or from the death proceeds of the Policy

(in the event Berrin dies while the Policy remains in force). (Id. § 6.)

47. To secure Bremen House’s right to repayment, the Trustee collaterally assigned to

Bremen House an interest in the Policy, by an agreement titled the “Split-Dollar Collateral

Assignment” (the “Collateral Assignment”), which is annexed to the Split-Dollar Agreement. (Id.

at 8-10.)

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48. The Collateral Assignment specifies that Bremen House is entitled to repayment of

the premiums paid on the Policy “decreased by any indebtedness under the policy.” (Id. at 9.)

49. The Split-Dollar Agreement limits the Trustee’s rights to use the Life Insurance

Trust. It requires that “[t]he Trustee shall not take any action which, directly or indirectly, would

impair or impede Bremen’s right under this Agreement and/or under the collateral assignment to

be repaid any premium payment it has made with respect to the Policy.” (Id. §7(a).)

C. Yasemin Assumes the Obligations of Trustee

50. On June 26, 2014, Yasemin succeeded Caginalp as Trustee. A true and correct

copy of the document by which Yasemin accepted her appointment as successor Trustee is attached

hereto as Exhibit C.

51. In assuming the role of successor Trustee, Yasemin assumed the obligations and

responsibilities that her predecessor, Caginalp, had undertaken in his capacity as Trustee.

52. Those include (but are not limited to) all obligations Caginalp assumed as a

signatory to the Trust Agreement and to the Split-Dollar Agreement.

53. Yasemin is a fiduciary with respect to all beneficiaries of the Life Insurance Trust,

including Gonca.

D. Yasemin Brings a Lawsuit, and Gonca and Bremen House Discover that Yasemin
Used the Life Insurance Trust to Fund Her Litigation

54. On December 21, 2020, Yasemin brought a lawsuit against, inter alia, Bremen

House, Berrin, and Gonca related to their management of Bremen House and its affiliates and

alleged conduct with respect to certain unrelated trusts.

55. Gonca and Yasemin’s sister, Zeynep, intervened in the Lawsuit in May 2022,

asserting essentially the same claims as Yasemin, and is now a co-plaintiff in the action.

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56. In February and March 2023, attorneys representing Yasemin and Zeynep in the

Lawsuit moved to withdraw from the dispute.

57. In opposition to her counsel’s motion to withdraw, Yasemin filed documents that

revealed she had violated both her fiduciary duties to Gonca and the terms of the Trust Agreement.

58. Most significantly, Yasemin filed a May 11, 2022 Payment Agreement between

Yasemin, Zeynep, representatives of law firms representing them, and the Life Insurance Trust,

which Yasemin signed as Trustee.

59. Yasemin heavily redacted the Payment Agreement before filing it, but the salient

facts are clear: (a) Yasemin and Zeynep entered into the Payment Agreement to modify existing

retainer agreements with their attorneys; (b) the Payment Agreement was conditioned on Yasemin

and Zeynep’s execution of a separate funding agreement, which (it appears) refers to a litigation

funding agreement with Statera; and (c) the Life Insurance Trust is a party to the Payment

Agreement. The redacted Payment Agreement is attached hereto as Exhibit D.

E. Despite Repeated Demand, Yasemin Refuses to Explain or Justify In Any Way the
Life Insurance Trust’s Role As a Signatory to the Payment Agreement

60. On April 5, 2023, Gonca wrote to Yasemin through counsel to demand, among

other things, (1) an unredacted copy of the Payment Agreement and any related documents,

including but not limited to any amendments and (2) an explanation for the Life Insurance Trust’s

inclusion as a signatory to the Payment Agreement, including but not limited to, whether any trust

assets had been distributed, pledged, or otherwise impaired by Yasemin. A true and correct copy

of Gonca’s April 5, 2023 letter is attached hereto as Exhibit E.

61. Yasemin wrote to Gonca by email on April 10, 2023. In that email, she said only

that that there had been no withdrawals from the Life Insurance Trust since 2018. She also took

the opportunity to make irrelevant, unsupported allegations against non-party Berrin, while

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evading Gonca’s questions about Yasemin’s misuse of her power as Trustee. A true and correct

copy of Yasemin’s April 10, 2023 email is attached hereto as Exhibit F.

62. Following Yasemin’s April 10 email, Gonca asked again why the Life Insurance

Trust is a signatory to the Payment Agreement. A true and correct copy of Gonca’s April 17, 2023

letter is attached hereto as Exhibit G.

63. On April 19, 2023, Yasemin emailed Gonca, once again refusing to explain the Life

Insurance Trust’s involvement as a party to the Payment and this time saying that she would need

time to respond to Gonca’s straightforward questions. A true and correct copy of Yasemin’s April

19, 2023 email to Gonca is attached hereto as Exhibit H.

64. On April 28, 2023, Gonca once again asked Yasemin what she had done as Trustee

to involve the Life Insurance Trust in Yasemin and Zeynep’s litigation funding arrangement. A

true and correct copy of Gonca’s April 28, 2023 letter to Yasemin is attached hereto as Exhibit I.

65. Yasemin has not responded to Gonca’s most recent letter.

66. Yasemin has refused to provide to Gonca an unredacted copy of the Payment

Agreement.

67. Gonca and Bremen House can only conclude that Yasemin has pledged or

otherwise encumbered the Life Insurance Trust or its assets.

68. This pledge or encumbrance was in violation of the purpose of the Life Insurance

Trust, Yasemin’s fiduciary duties to Gonca, and Yasemin’s contractual obligation pursuant to the

Split-Dollar Agreement not to impede or impair Bremen House’s right to recover its payment of

premiums on the Policy.

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FIRST CAUSE OF ACTION
(Breach of Fiduciary Duty by Gonca Against Yasemin)

69. Gonca incorporates by reference the allegations set forth in Paragraphs 1

through 68 as if fully set forth herein.

70. As sole Trustee of the Life Insurance Trust, Yasemin owes fiduciary duties to its

beneficiaries, including Gonca.

71. In pledging or otherwise encumbering the Life Insurance Trust to finance her

litigation against Gonca, Bremen House and others, Yasemin violated her fiduciary duties of

loyalty and good faith, in that she has engaged in self-dealing and used her role as Trustee to

Gonca’s detriment.

72. In addition, in pledging or otherwise encumbering the Life Insurance Trust to

finance her lawsuit, Yasemin has violated her duty of care to Gonca by negligently managing the

assets of the Life Insurance Trust.

73. By virtue of Yasemin’s breaches, she and Zeynep obtained funding for the Lawsuit

against Gonca and others. As a direct result, Gonca was forced to expend significant funds

defending the Lawsuit.

74. By reason of the foregoing, Gonca is entitled to monetary damages in an amount to

be determined at trial, but in no event less than $1 million, plus attorneys’ fees, interest, and

punitive damages.

SECOND CAUSE OF ACTION
(Aiding and Abetting Breaches of Fiduciary Duty by Gonca Against Zeynep)

75. Gonca incorporates by reference the allegations set forth in Paragraphs 1 through

74 as if fully set forth herein.

76. As fully alleged in the preceding paragraphs, Yasemin breached her fiduciary duty

to Gonca by pledging or otherwise encumbering the Life Insurance Trust.

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77. Zeynep, who is also a beneficiary of the Life Insurance Trust, knew that the purpose

of the Life Insurance Trust was to maintain the Policy and allow Berrin to provide life insurance

for the benefit and protection of her family.

78. Zeynep also knew that Yasemin was Trustee of the Life Insurance Trust and that

she therefore owed fiduciary duties to the beneficiaries, including Gonca.

79. Zeynep is a signatory to the Payment Agreement and benefitted from the Payment

Agreement insofar as she obtained a restructuring of her obligations to counsel representing her in

the Lawsuit.

80. Upon information and belief, Zeynep therefore knowingly participated in

Yasemin’s breach of her fiduciary duties by encouraging her to pledge or otherwise encumber the

Life Insurance Trust and by executing the Payment Agreement as a signatory.

81. By virtue of Zeynep’s aiding and abetting of Yasemin’s breaches of fiduciary duty,

Defendants obtained funding for the Lawsuit against Gonca and others. As a direct result, Gonca

was forced to expend significant funds defending the Lawsuit.

82. By reason of the foregoing, Gonca is entitled to monetary damages in an amount to

be determined at trial, but in no event less than $1 million, plus attorneys’ fees, interest, and

punitive damages.

THIRD CAUSE OF ACTION
(Breach of Contract by Bremen House Against Yasemin)

83. Bremen House incorporates by reference the allegations set forth in Paragraphs 1

through 82 as if fully set forth herein.

84. Bremen House entered into the Split-Dollar Agreement, between itself, Berrin, and

Aydin Caginalp in his capacity as Trustee on January 19, 2000.

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85. Pursuant to the Split-Dollar Agreement, Bremen House has paid premiums on the

Policy from 2000 until the present.

86. Pursuant to the Split-Dollar Agreement, Bremen House has paid over $2 million in

premiums on the Policy.

87. Pursuant to the Split-Dollar Agreement, Bremen House agreed to pay such

premiums subject to its right to recover the amount of its premium payments.

88. Pursuant to the Split-Dollar Agreement, the Trustee is prohibited from taking “any

action which, directly or indirectly, would impair or impede [Bremen House’s] right” to repayment

of its premium payments.

89. In pledging or otherwise encumbering the Life Insurance Trust, Yasemin has

impaired and/or impeded Bremen House’s right to repayment of its premium payments, in

violation of Yasemin’s contractual obligations as Trustee.

90. By reason of the foregoing, Bremen House is entitled to monetary damages in an

amount to be determined at trial, but believed to be no less than $1 million, plus attorneys’ fees

and interest.

FOURTH CAUSE OF ACTION
(Breach of Trust Under EPTL § 7-2.4 by Gonca Against Yasemin)

91. Gonca incorporates by reference the allegations set forth in Paragraphs 1 through

90 as if fully set forth herein.

92. Having accepted appointment Trustee on June 26, 2014, Yasemin became Trustee

of the Life Insurance Trust. She is the successor to Aydin S. Caginalp, who was Trustee from

December 23, 1999 until June 26, 2014.

93. The purpose of the Life Insurance Trust is expressed in the Trust Agreement by,

among other provisions, § 9(a), which specifies the duties of the Trustee.

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94. On or around May 11, 2023, Yasemin pledged or otherwise encumbered the Life

Insurance Trust by entering into the Payment Agreement on its behalf. This encumbrance was for

the purpose of financing the Lawsuit and not for any valid purpose under the Trust Agreement.

95. Yasemin therefore encumbered the Life Insurance Trust in contravention of the

Life Insurance Trust and the Trust Agreement.

96. By reason of the foregoing, Gonca seeks a declaration that Yasemin’s encumbrance

of the Life Insurance Trust was an act in contravention of the Life Insurance Trust, and that the

Payment Agreement is therefore void.

FIFTH CAUSE OF ACTION
(Removal of Yasemin as Trustee Pursuant to EPTL § 7-2.6(c) by Gonca Against Yasemin)

97. Gonca incorporates by reference the allegations set forth in Paragraphs 1 through

96 as if fully set forth herein.

98. Pursuant to EPTL § 7-2.6(a)(2), this Court may “[o]n the application of any person

interested in [a trust] . . . suspend or remove a trustee who has violated or threatens to violate his

trust . . . or who for any reason is a person unsuitable to execute the trust.”

99. As fully alleged above, Yasemin has violated the Life Insurance Trust and violated

the fiduciary duties she owes to Gonca as a beneficiary of the Life Insurance Trust. She has abused

her position as Trustee in order to finance her own litigation against, Gonca, a trust beneficiary.

100. As a result, Yasemin has violated the Life Insurance Trust and is a person unsuitable

to hold the position of trustee.

101. Furthermore, this Court may also remove a trustee upon a finding that such a

conflict of interest exists between a trustee and a beneficiary that the conflict thwarts proper

administration of the trust.

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102. Given Yasemin’s pledge or other encumbrance of the Life Insurance Trust to

finance her litigation against Gonca, such a conflict of interest exists, and Yasemin should be

removed.

103. By reason of the foregoing, Gonca seeks Yasemin’s removal as Trustee of the Life

Insurance Trust.

WHEREFORE, Plaintiffs demand judgment as follows:

a. on the first cause of action, Gonca is entitled to monetary damages in an amount to

be determined at trial, but in no event less than $1 million, plus attorneys’ fees, interest, and

punitive damages;

b. on the second cause of action, Gonca is entitled to monetary damages in an amount

to be determined at trial, but in no event less than $1 million, plus attorneys’ fees, interest, and

punitive damages;

c. on the third cause of action, Bremen House is entitled to monetary damages in an

amount to be determined at trial, but believed to be no less than $1 million, plus attorneys’ fees

and interest;

d. on the fourth cause of action, Gonca is entitled to a declaration that Yasemin’s

encumbrance of the Life Insurance Trust was an act in contravention of the Life Insurance Trust,

and that the Payment Agreement is therefore void;

e. on the fifth cause of action, Gonca is entitled to Yasemin’s removal as Trustee of

the Life Insurance Trust; and

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PM INDEX NO. 657193/2020
154224/2023
NYSCEF DOC. NO. 1630
1 RECEIVED NYSCEF: 05/19/2023
05/09/2023

f. granting Plaintiffs such other and further relief as is just and proper.

Dated: New York, New York PRYOR CASHMAN LLP
May 9, 2023

By:_____________________________
Todd E. Soloway
Bryan T. Mohler
Clare P. Tilton
Lawrence P. Keating
7 Times Square
New York, New York 10036
Attorneys for Plaintiffs

16 of 18
FILED: NEW YORK COUNTY CLERK 05/19/2023
05/09/2023 12:03
04:52 AM
PM INDEX NO. 657193/2020
154224/2023
NYSCEF DOC. NO. 1630
1 RECEIVED NYSCEF: 05/19/2023
05/09/2023

17 of 18
FILED: NEW YORK COUNTY CLERK 05/19/2023
05/09/2023 12:03
04:52 AM
PM INDEX NO. 657193/2020
154224/2023
NYSCEF DOC. NO. 1630
1 RECEIVED NYSCEF: 05/19/2023
05/09/2023

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Case Info

Judge

Joel M. Cohen Track Judge’s New Case

Case No.

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Document Filed Date

May 19, 2023

Case Filing Date

December 21, 2020

County

Parties

254-258 W. 35th St. LLC Defendant
Berrin Tekiner Defendant
Billur Akipek in her capacity as a Trustee of the Yasemin Tekiner 2011 Descendants Trust Defendant
Bremen House Inc. Defendant
Bremen House Texas, Inc. Defendant
CONKLIN, DONALD DAVID Attorney for the Plaintiff
DE SANTIS, JOSEPH VINCENT Attorney
Foley Hoag LLP Non Party
German News Company, Inc. Defendant
German News Texas, Inc. Defendant
GOLDBERG, ERIC A Attorney
GOLDBERG, ERIC ADAM Attorney for the Defendant
Gonca Tekiner Defendant
HARWOOD, ANTHONY J Attorney for the Plaintiff
HILL, MEGHAN ELIZABETH Attorney for the Defendant
IBRAHIM, SANJAY P Attorney for the Plaintiff
KAHN, MICHELE E. Attorney
KAHN, MICHELE E. Attorney for the Defendant
KEATING, LAWRENCE POLK Attorney for the Defendant
MANDEL, EVAN MORGEN Attorney for the Plaintiff
MANDELSBERG, STEVEN J. Attorney
Michele Kahn ESQ. Attorney for Proposed Intervenor-Plaintiff Non Party
MILLER, MATTHEW EDWARD Attorneys for Plaintiffs
MOHLER, BRYAN T. Attorney for the Defendant
Parker Ibrahim & Berg LLP Non Party
PARKER, SCOTT WESLEY Attorney for the Plaintiff
SCHLEIFSTEIN, DANIEL AARON Attorney for the Plaintiff
SHAW, RACHEL ELIZABETH Attorney for the Defendant
SOLOWAY, TODD E Attorney for the Defendant
TILTON, CLARE PRIMIANO Attorney for the Defendant
WEISSMAN, BENJAMIN HEALEY Attorney for the Plaintiff
WEISS, ZANDER ALOYSIUS Attorney for the Defendant
Yasemin Tekiner Plaintiff
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 Plaintiff
YOUNGER, STEPHEN PETERS Attorney for the Plaintiff
Zeynep Tekiner (Intervenor Plaintiff) Defendant
JUDITH ARCHER Attorneys for Defendants
Philip Michaels Attorney
MATTHEW KASINDORF Attorney
Steven Young Attorney
GARY TANNENBAUM Attorney
VICTORIA CORDER Attorneys for Defendants
SEAN TOPPING Attorney
MARGARET O'NEAL Attorney
ESTHER YU Attorney
Victoria Corder Attorney
JAY SIMENS Attorney
SETH MOTT Attorney
JEFFREY GOLDMAN Attorney
BETH KAUFMAN Attorney
JEREMY KAYE Attorney
PHILIP JAWORSKYJ Attorney
TIFFANY KO Attorneys for Plaintiffs
JANET DORE Attorney
DAVID SCHWARTZ Attorneys for Defendants
LISA SCHAPIRA Attorneys for Defendants
STEPHEN PAZAN Attorney
JOHN MCDONOUGH Attorneys for Plaintiffs
ROBERT HANEY Attorneys for Plaintiffs
MICHAEL KALAN Attorney
MITCHELL KAHN Attorneys for Defendants
GARY FREIDMAN Attorneys for Plaintiffs
PHILIP MICHAELS Attorney
DAVID EISENBERG Attorney
HERBERT WEISSMAN Attorney
ANTHONY CARUSO Attorneys for Defendants
WILLIAM PARKER Attorney
DANIEL HOWARD Attorney
MARTIN MURPHY Attorneys for Plaintiffs
Matt Hanley Attorney
BENJAMIN WEISMAN Attorneys for Plaintiffs

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