Preview
FILED: NEW YORK COUNTY CLERK 06/29/2022 04:59 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 590 RECEIVED NYSCEF: 06/29/2022
Exhibit I
FILED: NEW YORK COUNTY CLERK 06/29/2022 04:59 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 590 RECEIVED NYSCEF: 06/29/2022
From: Younger, Stephen P.
Sent: Sunday, June 12, 2022 12:14 PM
To: Corder, Victoria
Cc: Michele Kahn; Archer, Judith A.; Topping, Sean; Sanjay Ibrahim; Scott Parker; Ward, Luke
Subject: Re: Tekiner - 81 Tanglewylde - Board Meeting; Request to Reschedule
Given the circumstances it is quite unreasonable to insist on a meeting tomorrow and there is nothing unreasonable to
consent to the sale subject to escrowing the proceeds.
Sent from my iPhone
On Jun 12, 2022, at 11:21 AM, Corder, Victoria wrote:
**EXTERNAL**
________________________________
Neither you, Ms. Kahn nor Zeynep had indicated when the funeral is being held in any prior communication. There is
nothing unreasonable about holding a board meeting to sell a property that the Bremen House board has been
attempting to sell for weeks. I invite Ms. Kahn to give me a call if she would like, but will not discuss this further with
you.
Regards,
Victoria
On Jun 12, 2022, at 10:39 AM, Younger, Stephen P. wrote:
I have been led to understand that the funeral will be held tomorrow so this is patently unreasonable
Sent from my iPhone
On Jun 12, 2022, at 10:01 AM, Corder, Victoria wrote:
**EXTERNAL**
________________________________
We understood that Zeynep had to travel to Turkey on Friday, which is why Bremen House made an accommodation for
her and moved the special meeting to Sunday at 10 AM. Now, half an hour before the meeting is scheduled to begin,
your clients are requesting that the rescheduled meeting be cancelled again. We understand the circumstances are
unfortunate, but Zeynep has had several weeks to consent to the sale by tendering her written signature. We will make
one last accommodation and adjourn the meeting until tomorrow at 10 AM, but we must proceed with the vote
tomorrow. Bremen House needs a decision to be made as soon as possible this week or the transaction is at risk of not
being consummated. If Zeynep cannot attend tomorrow, we will hold the meeting without her, which is permitted by
the corporate records.
Victoria Corder | Partner
Norton Rose Fulbright US LLP
1
FILED: NEW YORK COUNTY CLERK 06/29/2022 04:59 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 590 RECEIVED NYSCEF: 06/29/2022
1301 Avenue of the Americas, New York, New York 10019‐6022, United States
Tel +1 212 408 5457 | Fax +1 212 318 3400 | Cell +1 917 566 3179
victoria.corder@nortonrosefulbright.com
NORTON ROSE FULBRIGHT
Law around the world
nortonrosefulbright.com
From: Michele Kahn
Sent: Sunday, June 12, 2022 9:43 AM
To: 'Younger, Stephen P.' ; Archer, Judith A.
Cc: Topping, Sean ; 'Sanjay Ibrahim' ; 'Scott
Parker' ; Corder, Victoria ; Ward, Luke
Subject: RE: Tekiner ‐ 81 Tanglewylde ‐ Board Meeting; Request to Reschedule
Judi, I just logged on and saw the sad news about Zeyep’s ex‐husband. Thank you Steve for being on line earlier than me
and letting Judi know.
Zeynep is travelling with her daughters within Turkey and funeral arrangements are still being made. I will be in touch
when I know more.
Michele Kahn, Esq.
Kahn & Goldberg, LLP
555 Fifth Avenue, 14th Floor
New York, NY 10017
Tel. (212) 687‐5066
Fax (212) 918‐0662
mk@kahngoldberg.com
www.kahngoldberg.com>
From: Younger, Stephen P. [mailto:spyounger@foleyhoag.com]
Sent: Sunday, June 12, 2022 9:22 AM
To: Archer, Judith A. >
Cc: Michele Kahn >; Topping, Sean
>; Sanjay Ibrahim
>; Scott Parker
>; Corder, Victoria
>; Ward, Luke
>
Subject: Re: Tekiner ‐ 81 Tanglewylde ‐ Board Meeting; Request to Reschedule
2
FILED: NEW YORK COUNTY CLERK 06/29/2022 04:59 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 590 RECEIVED NYSCEF: 06/29/2022
We just learned that Zeynep’s ex‐husband passed away ‐ she is en route to Istanbul with her children and obviously is
unable to participate in a board meeting this morning. She asked us to convey her request for an adjournment of the
meeting.
Sent from my iPad
On Jun 9, 2022, at 5:56 PM, Archer, Judith A.
> wrote:
**EXTERNAL**
________________________________
Thank you Michele.
From: Michele Kahn >
Sent: Thursday, June 9, 2022 5:54 PM
To: Archer, Judith A. >;
Topping, Sean >; 'Sanjay
Ibrahim' >; 'Scott Parker'
>; 'Younger, Stephen P.'
>
Cc: Corder, Victoria >;
Ward, Luke >
Subject: RE: Tekiner ‐ 81 Tanglewylde ‐ Board Meeting; Request to Reschedule
Judi. Zeynep can participate in the phone special meeting on Sunday at 10 am. Please do whatever you think appropriate
regarding a new or updated notice, and please either send new dial‐in information or confirm that Zeynep should use
the dial‐in information in your June 7th letter.
Thank you, Michele
Michele Kahn, Esq.
Kahn & Goldberg, LLP
555 Fifth Avenue, 14th Floor
New York, NY 10017
Tel. (212) 687‐5066
Fax (212) 918‐0662
mk@kahngoldberg.com>
www.kahngoldberg.com>>
From: Archer, Judith A. [mailto:judith.archer@nortonrosefulbright.com]
Sent: Thursday, June 09, 2022 5:24 PM
To: Michele Kahn
>>; Topping, Sean
>>; 'Sanjay Ibrahim'
>>; 'Scott Parker'
>>; 'Younger, Stephen P.'
>>
Cc: Corder, Victoria
>>; Ward, Luke
>>
Subject: RE: Tekiner ‐ 81 Tanglewylde ‐ Board Meeting; Request to Reschedule
Michele – In light of Zeynep’s family emergency, our clients are willing to adjourn the meeting. We are concerned that
delaying until Monday may increase the risk of losing the buyers for the house in light of the delay in hearing from your
client and Yasemin. Would it be possible to hold meeting on Sunday, June 12, 2022 at 10am ET? If not, we will hold it on
Monday at the same time. Our clients reserve all of their rights in connection with this issue. Sincerely, Judi
From: Michele Kahn
>>
Sent: Thursday, June 9, 2022 4:09 PM
To: Topping, Sean
>>; 'Sanjay Ibrahim'
>>; 'Scott Parker'
>>; 'Younger, Stephen P.'
>>
Cc: Archer, Judith A.
>>; Corder, Victoria
>>; Ward, Luke
>>
Subject: RE: Tekiner ‐ 81 Tanglewylde ‐ Board Meeting; Request to Reschedule
Importance: High
Ms. Archer. I refer to your June 7, 2022 letter and notice scheduling a telephonic special meeting of the Bremen House
board of directors for tomorrow, June 10, 2022 at 10 am.
My client, Zeynep Tekiner, just advised me that she has to fly to Turkey tomorrow morning to deal with a pressing family
emergency. Therefore, we request that the meeting be adjourned for one business day – to Monday, June 13, 2022 at
10 am.
Please advise.
Thank you, Michele Kahn
Michele Kahn, Esq.
Kahn & Goldberg, LLP
555 Fifth Avenue, 14th Floor
New York, NY 10017
Tel. (212) 687‐5066
Fax (212) 918‐0662
mk@kahngoldberg.com>
www.kahngoldberg.com>>
From: Topping, Sean [mailto:sean.topping@nortonrosefulbright.com]
Sent: Tuesday, June 07, 2022 6:01 PM
To: 'Sanjay Ibrahim'
>>; 'Scott Parker'
>>; 'Younger, Stephen P.'
5
FILED: NEW YORK COUNTY CLERK 06/29/2022 04:59 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 590 RECEIVED NYSCEF: 06/29/2022
>>; Michele Kahn
>>
Cc: Archer, Judith A.
>>; Corder, Victoria
>>; Ward, Luke
>>
Subject: Tekiner ‐ 81 Tanglewylde
All,
Please see correspondence attached. Documents previously sent concerning the property may be accessed below:
Go to https://fjftp.fulbright.com
Enter the following User ID: site2010
Password: 0ICHP6pEd3yJeNVIz96G
Regards,
Sean Topping | Senior Associate
Norton Rose Fulbright US LLP
1301 Avenue of the Americas, New York, New York 10019‐6022, United States
Tel +1 212 318 3361 | Fax +1 212 318 3400
sean.topping@nortonrosefulbright.com>
NORTON ROSE FULBRIGHT
Law around the world
nortonrosefulbright.com
CONFIDENTIALITY NOTICE: This email, including any attachments, is confidential and may be privileged. If you are not
6
FILED: NEW YORK COUNTY CLERK 06/29/2022 04:59 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 590 RECEIVED NYSCEF: 06/29/2022
the intended recipient please notify the sender immediately, and please delete it; you should not copy it or use it for any
purpose or disclose its contents to any other person. Norton Rose Fulbright entities reserve the right to monitor all email
communications through their networks.
Norton Rose Fulbright Australia, Norton Rose Fulbright LLP, Norton Rose Fulbright Canada LLP, Norton Rose Fulbright
South Africa Inc and Norton Rose Fulbright US LLP are separate legal entities and all of them are members of Norton
Rose Fulbright Verein, a Swiss verein. Norton Rose Fulbright Verein helps coordinate the activities of the members but
does not itself provide legal services to clients. Details of each entity, with certain regulatory information, are available
at nortonrosefulbright.com.
Any tax advice included in this document and its attachments was not intended or written to be used, and it cannot be
used, for the purpose of avoiding penalties under the Internal Revenue Code.
This email message and any attachments are confidential and may be privileged. If you are not the intended recipient,
please notify Foley Hoag LLP immediately ‐‐ by replying to this message or by sending an email to
postmaster@foleyhoag.com ‐‐ and destroy all copies of this message and any
attachments without reading or disclosing their contents. Thank you.
For more information about Foley Hoag LLP, please visit us at
www.foleyhoag.com>>.
7
Preview
FILED: NEW YORK COUNTY CLERK 06/29/2022 04:59 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 590 RECEIVED NYSCEF: 06/29/2022 Exhibit I FILED: NEW YORK COUNTY CLERK 06/29/2022 04:59 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 590 RECEIVED NYSCEF: 06/29/2022 From: Younger, Stephen P. Sent: Sunday, June 12, 2022 12:14 PM To: Corder, Victoria Cc: Michele Kahn; Archer, Judith A.; Topping, Sean; Sanjay Ibrahim; Scott Parker; Ward, Luke Subject: Re: Tekiner - 81 Tanglewylde - Board Meeting; Request to Reschedule Given the circumstances it is quite unreasonable to insist on a meeting tomorrow and there is nothing unreasonable to consent to the sale subject to escrowing the proceeds. Sent from my iPhone On Jun 12, 2022, at 11:21 AM, Corder, Victoria wrote: **EXTERNAL** ________________________________ Neither you, Ms. Kahn nor Zeynep had indicated when the funeral is being held in any prior communication. There is nothing unreasonable about holding a board meeting to sell a property that the Bremen House board has been attempting to sell for weeks. I invite Ms. Kahn to give me a call if she would like, but will not discuss this further with you. Regards, Victoria On Jun 12, 2022, at 10:39 AM, Younger, Stephen P. wrote: I have been led to understand that the funeral will be held tomorrow so this is patently unreasonable Sent from my iPhone On Jun 12, 2022, at 10:01 AM, Corder, Victoria wrote: **EXTERNAL** ________________________________ We understood that Zeynep had to travel to Turkey on Friday, which is why Bremen House made an accommodation for her and moved the special meeting to Sunday at 10 AM. Now, half an hour before the meeting is scheduled to begin, your clients are requesting that the rescheduled meeting be cancelled again. We understand the circumstances are unfortunate, but Zeynep has had several weeks to consent to the sale by tendering her written signature. We will make one last accommodation and adjourn the meeting until tomorrow at 10 AM, but we must proceed with the vote tomorrow. Bremen House needs a decision to be made as soon as possible this week or the transaction is at risk of not being consummated. If Zeynep cannot attend tomorrow, we will hold the meeting without her, which is permitted by the corporate records. Victoria Corder | Partner Norton Rose Fulbright US LLP 1 FILED: NEW YORK COUNTY CLERK 06/29/2022 04:59 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 590 RECEIVED NYSCEF: 06/29/2022 1301 Avenue of the Americas, New York, New York 10019‐6022, United States Tel +1 212 408 5457 | Fax +1 212 318 3400 | Cell +1 917 566 3179 victoria.corder@nortonrosefulbright.com NORTON ROSE FULBRIGHT Law around the world nortonrosefulbright.com From: Michele Kahn Sent: Sunday, June 12, 2022 9:43 AM To: 'Younger, Stephen P.' ; Archer, Judith A. Cc: Topping, Sean ; 'Sanjay Ibrahim' ; 'Scott Parker' ; Corder, Victoria ; Ward, Luke Subject: RE: Tekiner ‐ 81 Tanglewylde ‐ Board Meeting; Request to Reschedule Judi, I just logged on and saw the sad news about Zeyep’s ex‐husband. Thank you Steve for being on line earlier than me and letting Judi know. Zeynep is travelling with her daughters within Turkey and funeral arrangements are still being made. I will be in touch when I know more. Michele Kahn, Esq. Kahn & Goldberg, LLP 555 Fifth Avenue, 14th Floor New York, NY 10017 Tel. (212) 687‐5066 Fax (212) 918‐0662 mk@kahngoldberg.com www.kahngoldberg.com> From: Younger, Stephen P. [mailto:spyounger@foleyhoag.com] Sent: Sunday, June 12, 2022 9:22 AM To: Archer, Judith A. > Cc: Michele Kahn >; Topping, Sean >; Sanjay Ibrahim >; Scott Parker >; Corder, Victoria >; Ward, Luke > Subject: Re: Tekiner ‐ 81 Tanglewylde ‐ Board Meeting; Request to Reschedule 2 FILED: NEW YORK COUNTY CLERK 06/29/2022 04:59 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 590 RECEIVED NYSCEF: 06/29/2022 We just learned that Zeynep’s ex‐husband passed away ‐ she is en route to Istanbul with her children and obviously is unable to participate in a board meeting this morning. She asked us to convey her request for an adjournment of the meeting. Sent from my iPad On Jun 9, 2022, at 5:56 PM, Archer, Judith A. > wrote: **EXTERNAL** ________________________________ Thank you Michele. From: Michele Kahn > Sent: Thursday, June 9, 2022 5:54 PM To: Archer, Judith A. >; Topping, Sean >; 'Sanjay Ibrahim' >; 'Scott Parker' >; 'Younger, Stephen P.' > Cc: Corder, Victoria >; Ward, Luke > Subject: RE: Tekiner ‐ 81 Tanglewylde ‐ Board Meeting; Request to Reschedule Judi. Zeynep can participate in the phone special meeting on Sunday at 10 am. Please do whatever you think appropriate regarding a new or updated notice, and please either send new dial‐in information or confirm that Zeynep should use the dial‐in information in your June 7th letter. Thank you, Michele Michele Kahn, Esq. Kahn & Goldberg, LLP 555 Fifth Avenue, 14th Floor New York, NY 10017 Tel. (212) 687‐5066 Fax (212) 918‐0662 mk@kahngoldberg.com> www.kahngoldberg.com>> From: Archer, Judith A. [mailto:judith.archer@nortonrosefulbright.com] Sent: Thursday, June 09, 2022 5:24 PM To: Michele Kahn >>; Topping, Sean >>; 'Sanjay Ibrahim' >>; 'Scott Parker' >>; 'Younger, Stephen P.' >> Cc: Corder, Victoria >>; Ward, Luke >> Subject: RE: Tekiner ‐ 81 Tanglewylde ‐ Board Meeting; Request to Reschedule Michele – In light of Zeynep’s family emergency, our clients are willing to adjourn the meeting. We are concerned that delaying until Monday may increase the risk of losing the buyers for the house in light of the delay in hearing from your client and Yasemin. Would it be possible to hold meeting on Sunday, June 12, 2022 at 10am ET? If not, we will hold it on Monday at the same time. Our clients reserve all of their rights in connection with this issue. Sincerely, Judi From: Michele Kahn >> Sent: Thursday, June 9, 2022 4:09 PM To: Topping, Sean >>; 'Sanjay Ibrahim' >>; 'Scott Parker' >>; 'Younger, Stephen P.' >> Cc: Archer, Judith A. >>; Corder, Victoria >>; Ward, Luke >> Subject: RE: Tekiner ‐ 81 Tanglewylde ‐ Board Meeting; Request to Reschedule Importance: High Ms. Archer. I refer to your June 7, 2022 letter and notice scheduling a telephonic special meeting of the Bremen House board of directors for tomorrow, June 10, 2022 at 10 am. My client, Zeynep Tekiner, just advised me that she has to fly to Turkey tomorrow morning to deal with a pressing family emergency. Therefore, we request that the meeting be adjourned for one business day – to Monday, June 13, 2022 at 10 am. Please advise. Thank you, Michele Kahn Michele Kahn, Esq. Kahn & Goldberg, LLP 555 Fifth Avenue, 14th Floor New York, NY 10017 Tel. (212) 687‐5066 Fax (212) 918‐0662 mk@kahngoldberg.com> www.kahngoldberg.com>> From: Topping, Sean [mailto:sean.topping@nortonrosefulbright.com] Sent: Tuesday, June 07, 2022 6:01 PM To: 'Sanjay Ibrahim' >>; 'Scott Parker' >>; 'Younger, Stephen P.' 5 FILED: NEW YORK COUNTY CLERK 06/29/2022 04:59 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 590 RECEIVED NYSCEF: 06/29/2022 >>; Michele Kahn >> Cc: Archer, Judith A. >>; Corder, Victoria >>; Ward, Luke >> Subject: Tekiner ‐ 81 Tanglewylde All, Please see correspondence attached. Documents previously sent concerning the property may be accessed below: Go to https://fjftp.fulbright.com Enter the following User ID: site2010 Password: 0ICHP6pEd3yJeNVIz96G Regards, Sean Topping | Senior Associate Norton Rose Fulbright US LLP 1301 Avenue of the Americas, New York, New York 10019‐6022, United States Tel +1 212 318 3361 | Fax +1 212 318 3400 sean.topping@nortonrosefulbright.com> NORTON ROSE FULBRIGHT Law around the world nortonrosefulbright.com CONFIDENTIALITY NOTICE: This email, including any attachments, is confidential and may be privileged. If you are not 6 FILED: NEW YORK COUNTY CLERK 06/29/2022 04:59 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 590 RECEIVED NYSCEF: 06/29/2022 the intended recipient please notify the sender immediately, and please delete it; you should not copy it or use it for any purpose or disclose its contents to any other person. Norton Rose Fulbright entities reserve the right to monitor all email communications through their networks. Norton Rose Fulbright Australia, Norton Rose Fulbright LLP, Norton Rose Fulbright Canada LLP, Norton Rose Fulbright South Africa Inc and Norton Rose Fulbright US LLP are separate legal entities and all of them are members of Norton Rose Fulbright Verein, a Swiss verein. Norton Rose Fulbright Verein helps coordinate the activities of the members but does not itself provide legal services to clients. Details of each entity, with certain regulatory information, are available at nortonrosefulbright.com. Any tax advice included in this document and its attachments was not intended or written to be used, and it cannot be used, for the purpose of avoiding penalties under the Internal Revenue Code. This email message and any attachments are confidential and may be privileged. If you are not the intended recipient, please notify Foley Hoag LLP immediately ‐‐ by replying to this message or by sending an email to postmaster@foleyhoag.com ‐‐ and destroy all copies of this message and any attachments without reading or disclosing their contents. Thank you. For more information about Foley Hoag LLP, please visit us at www.foleyhoag.com>>. 7