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 03/22/2022 08:20 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 219 RECEIVED NYSCEF: 03/22/2022
Beth L. Kaufman
646.723.1039 direct
bkaufman@schoeman.com
September 28, 2021
Via E-Mail
Ms. Zeynep Tekiner
31 White Plains Road
Bronxville, NY 10708
tekiner.zeynep77@gmail.com
Dear Zeynep:
The purpose of this letter is to confirm that you have retained our firm
to represent you as a non-party deposition witness in Yasemin Tekiner v. Bremen
House, Inc., et al.
We agree to undertake this representation. I will have primary
responsibility for this matter. Our services will include gathering and reviewing
information about the matter that will help us prepare you for the deposition and
defending you for the deposition itself. As part of the preparation, we may have
another lawyer in our office role play with you, as if they were plaintiff’s counsel.
It is the policy of our office to keep records of the time expended in any
given case by our legal staff. Attorneys’ time is charged at an hourly rate. My rate
is $675 per hour. Should it become necessary to have other lawyers (including
partners) or paralegals work on the matter, their billing rates, respectively, range
from $600 to $175 per hour. These rates may change from time to time. Any such
changes in rates or fees shall be in writing, amending this agreement, which you
must sign before such rate or fee changes become effective.
We have been advised that Bremen House will pay us for our
statements for services to you. Should that change, you will be responsible for
payment of costs and expenses we incur on your behalf, which may include but are
not limited to long distance telephone calls; messengers, postage and overnight mail
services (such as Federal Express); facsimile; printing, duplicating, and binding;
computerized legal research and other database charges. We will send you
monthly bills to review and approve, and then send Bremen House’s attorneys a
NEW YORK ï‚¢ 551 Fifth Avenue | New York, NY 10176 | 212.661.5030
NEW JERSEY ï‚¢ 155 Willowbrook Blvd, Ste. 300 | Wayne, NJ 07470 | 973.256.9000
www.schoeman.com
FILED: NEW YORK COUNTY CLERK 03/22/2022 08:20 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 219 RECEIVED NYSCEF: 03/22/2022
Ms. Zeynep Tekiner
September 28, 2021
Page 2
more general statement that does not disclose attorney-client confidential
information, noting for them that you have approved the statement.
Please note that if a dispute arises between us relating to our fees, you
may have the right to arbitration of the dispute pursuant to Rule 137 of the Rules of
the Chief Administrator of the Courts, a copy of which will be provided to you upon
your request.
You have the right to cancel this agreement, thereby terminating our
services, at any time.
If you understand and agree with this letter, please date and sign it
and return a copy to us. The letter will constitute not only our retainer agreement
but also our authorization to act on your behalf as your counsel in New York.
SCHOEMAN UPDIKE KAUFMAN & GERBER LLP
By:
Beth L. Kaufman
The foregoing is hereby
accepted and agreed to:
By: ____________________________________
Zeynep Tekiner
Date:____________________
NEW YORK ï‚¢ 551 Fifth Avenue | New York, NY 10176 | 212.661.5030
NEW JERSEY ï‚¢ 155 Willowbrook Blvd, Ste. 300 | Wayne, NJ 07470 | 973.256.9000
www.schoeman.com
Document Filed Date
March 22, 2022
Case Filing Date
December 21, 2020
Category
Commercial Division
For full print and download access, please subscribe at https://www.trellis.law/.
Preview
FILED: NEW YORK COUNTY CLERK 03/22/2022 08:20 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 219 RECEIVED NYSCEF: 03/22/2022 Beth L. Kaufman 646.723.1039 direct bkaufman@schoeman.com September 28, 2021 Via E-Mail Ms. Zeynep Tekiner 31 White Plains Road Bronxville, NY 10708 tekiner.zeynep77@gmail.com Dear Zeynep: The purpose of this letter is to confirm that you have retained our firm to represent you as a non-party deposition witness in Yasemin Tekiner v. Bremen House, Inc., et al. We agree to undertake this representation. I will have primary responsibility for this matter. Our services will include gathering and reviewing information about the matter that will help us prepare you for the deposition and defending you for the deposition itself. As part of the preparation, we may have another lawyer in our office role play with you, as if they were plaintiff’s counsel. It is the policy of our office to keep records of the time expended in any given case by our legal staff. Attorneys’ time is charged at an hourly rate. My rate is $675 per hour. Should it become necessary to have other lawyers (including partners) or paralegals work on the matter, their billing rates, respectively, range from $600 to $175 per hour. These rates may change from time to time. Any such changes in rates or fees shall be in writing, amending this agreement, which you must sign before such rate or fee changes become effective. We have been advised that Bremen House will pay us for our statements for services to you. Should that change, you will be responsible for payment of costs and expenses we incur on your behalf, which may include but are not limited to long distance telephone calls; messengers, postage and overnight mail services (such as Federal Express); facsimile; printing, duplicating, and binding; computerized legal research and other database charges. We will send you monthly bills to review and approve, and then send Bremen House’s attorneys a NEW YORK  551 Fifth Avenue | New York, NY 10176 | 212.661.5030 NEW JERSEY  155 Willowbrook Blvd, Ste. 300 | Wayne, NJ 07470 | 973.256.9000 www.schoeman.com FILED: NEW YORK COUNTY CLERK 03/22/2022 08:20 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 219 RECEIVED NYSCEF: 03/22/2022 Ms. Zeynep Tekiner September 28, 2021 Page 2 more general statement that does not disclose attorney-client confidential information, noting for them that you have approved the statement. Please note that if a dispute arises between us relating to our fees, you may have the right to arbitration of the dispute pursuant to Rule 137 of the Rules of the Chief Administrator of the Courts, a copy of which will be provided to you upon your request. You have the right to cancel this agreement, thereby terminating our services, at any time. If you understand and agree with this letter, please date and sign it and return a copy to us. The letter will constitute not only our retainer agreement but also our authorization to act on your behalf as your counsel in New York. SCHOEMAN UPDIKE KAUFMAN & GERBER LLP By: Beth L. Kaufman The foregoing is hereby accepted and agreed to: By: ____________________________________ Zeynep Tekiner Date:____________________ NEW YORK  551 Fifth Avenue | New York, NY 10176 | 212.661.5030 NEW JERSEY  155 Willowbrook Blvd, Ste. 300 | Wayne, NJ 07470 | 973.256.9000 www.schoeman.com