Letter,Correspondence: 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)

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                                PARKER                    IBRAHIM                     &      BERG               LLP                             Writer’s Direct Contact:
                                                                                                                             908.333.6220 (Tel.)
                                                                                                                              212.596.7036 (Fax)
                                                                                                                        scott.parker@piblaw.com
                  May 20, 2022                                                                                                   www.piblaw.com

                  VIA NYSCEF
                  Hon. Joel M. Cohen, J.S.C.
                  Supreme Court of the State of New York
                  County of New York
                  60 Centre Street, Room 570
                  New York, New York 10007

                           Re:      Yasemin Tekiner, et al. v. Bremen House Inc., et al.
                                    Index No.: 657193/2020

                  Dear Justice Cohen:
                           This  firm   represents   Plaintiff  Yasemin    Tekiner    (“Plaintiff”)  as  co-counsel    in the  above-
                  referenced action.     At the last Rule 14 conference, the Court asked the parties to: (1) address their
                  Rule 14 issues in a single, omnibus motion, and (2) meet and confer as to a briefing schedule.
                           Based upon those instructions, Plaintiff and Defendants have agreed to brief the following
                  issues: (1) Plaintiff’s November 11, 2021 correspondence concerning Defendants’ privilege log;
                  (2)  Plaintiff’s   March     1,  2022    concerning     Defendants’      mental    health   and    substance    use;
                  (3)  Defendants’     June   20,  2021   correspondence      concerning     scheduling    the  deposition    of  Paul
                  Schwartzman;      and   (4)  Defendants’    September     16,  2021   correspondence      concerning     Plaintiff’s
                  privilege log entries including Lisa Rubin.           Further, Plaintiff and Defendants have agreed to the
                  following briefing schedule:
                                   Plaintiff and Defendants shall electronically file and serve a single omnibus motion
                                    addressing their respective issues on or before June 6, 2022;
                                   Plaintiff  and   Defendants      shall  electronically    file and   serve   a  single   omnibus
                                    opposition responding to the issues raised therein on or before June 15, 2022;
                                   Plaintiff and Defendants shall electronically file and serve a single omnibus reply
                                    in further support of their respective motions on or before June 21, 2022, and;
                                   Both motions shall be returnable June 22, 2022, with oral argument to be scheduled
                                    at a date and time convenient to the Court.
                           While    Plaintiff  and  Defendants     have   agreed   upon    this briefing   schedule,   we   have   not
                  reached an agreement as to the length of those submissions.              Plaintiff believes that the complexity
                  and issues that the parties must address in these omnibus motions require comprehensive briefing
                  to properly inform the Court of the applicable facts and law in reaching its determinations.                   With
                  this  in mind,   Plaintiff  respectfully   requests    that the  Court   permits   Plaintiff  and   Defendants     to
                  submit   initial motions    with   supporting    briefs  up  to 14,000    words,   oppositions    with  supporting




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                  briefs  up  to 14,000    words,   and  replies   with  supporting    briefs  up  to 8,400   words.     Defendants,
                  however, have not consented to an expansion of the standard Commercial Division word limits,
                  as  they believe   these   issues  “are  not  particularly complicated      and  believe   they could    be  argued
                  succinctly.”
                           Plaintiff  respectfully   requests   that  the  Court   so  order:  (1)  the jointly  proposed    briefing
                  schedule set forth above, and (2) Plaintiff’s proposed expanded word limit for those briefs, in light
                  of the number and complexity of issues involved.
                           We thank the Court for its consideration of this application.
                                                                                          Respectfully submitted,
                                                                                          /s/ Scott W. Parker
                                                                                          Scott W. Parker
                  cc:      All counsel of record (via NYSCEF)