Preview
FILED: NEW YORK COUNTY CLERK 09/16/2022 11:06 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 692 RECEIVED NYSCEF: 09/16/2022
EXHIBIT B
FILED: NEW YORK COUNTY CLERK 09/16/2022 11:06 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 692 RECEIVED NYSCEF: 09/16/2022
Keating, Lawrence P.
From: Hill, Meghan E.
Sent: Wednesday, September 7, 2022 3:39 PM
To: Scott Parker
Cc: Sanjay Ibrahim; Mohler, Bryan T.; Younger, Stephen P.; Michele Kahn; Soloway, Todd E.
Subject: RE: Tekiner v. Bremen House Inc. [PIB-LEGAL_DMS.FID449713]
Scott –
We write to memorialize the discussions between counsel during meet and confer held yesterday
afternoon. Immediately advise if you disagree with any of the following.
Santander Subpoena
First, you agreed to get back to me as soon as possible about extending the return date of the subpoena to allow the
parties a good faith opportunity to meet and confer and, if disputes remain, follow the pre-motion procedure mandated
by Commercial Division Rule 14 and Justice Cohen’s Individual Practices and Procedures, VII.B. Our proposal was to set
the return date for two weeks after the Rule 14 conference. Please note that, if we do not hear from you about this
issue by 10 am tomorrow (Thursday), we intend to call the Court to discuss.
Defendants raised the following global defects with the subpoena:
1. The subpoena is facially defective for lack of a description of the reason why Santander’s documents are
material and necessary. I asked if Plaintiff would consider withdrawing the subpoena and re-serving a new one,
and you said you would get back to me.
2. To the extent the requests seek non-redacted copies of documents redacted for PII, Plaintiff indicated
willingness to amend those requests as Defendants could see no reasonable basis for such a request.
3. To the extent the requests seek information outside any applicable statute of limitations of Plaintiff’s causes of
action, Plaintiff will advise as to her willingness to revise the time periods at issue.
The parties stated their position as to the following categories as follows:
4. Bank account statements of the Residuary Trust of Sami Tekiner are irrelevant and requests pertaining to those
documents are not proper.
5. You did not provide a basis for seeking documents pertaining to dismissed parties in the case other than
“transfers into and out of accounts” held by such parties are relevant to show “management or mismanagement
of the companies.” You declined to identify to which causes of action those reasons apply.
6. You gave the same basis as to why Plaintiff seeks documents from the bank accounts belonging to the individual
defendants.
7. You agreed to provide Plaintiff’s basis for requesting the signature cards in request 20.
8. Defendants stated that they do not concede the relevance of any documents previously produced.
9. As to Requests 8, 9, 15-19, Defendants’ position is that they are currently so overbroad as to be impossible to
respond to. Plaintiff agreed to reconsider the lack of a time period in those requests.
Medical Records
Plaintiff will serve an updated list of document demands, and we will review and respond to them.
Privilege Log
Defendants’ re-review of the privilege log is underway. We agreed to take under advisement your request to produce
documents on a rolling basis, and will get back to you as to that issue. We will also confirm with prior counsel whether
the Zeynep privilege log is a subset of the larger privilege log.
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FILED: NEW YORK COUNTY CLERK 09/16/2022 11:06 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 692 RECEIVED NYSCEF: 09/16/2022
Depositions
An update regarding the availability of Defendants for depositions is forthcoming. You advised that Plaintiff also intends
to seek the non-party depositions of Steve Levine and John Stewart based on previously served subpoenas. We will
reach out to both to indicate our representation of Defendants and discuss dates. You said you would get back to me as
to any other third-party depositions Plaintiff intends to seek.
Special Meeting
Plaintiffs take the position that Defendants have no discretion per the Bylaws to refuse to hold the Special Meeting.
Defendants’ position remains that it is ready to hold a Special Meeting, but inasmuch as the Special Meeting is part of an
ongoing strategy of harassment with no valid business purpose, Defendants have no obligation to hold such a
meeting. We explained that our previous understanding based on the May 19 notice and conversations with you and
Michelle was that the purposes of the meeting were as follows: 1) to advise Yasemin on events that occurred while she
was not a director or officer; 2) to give her a global financial update with the aid of up-to-date financial reporting of the
Company, which reporting Defendants have now produced; and 3) to advise Yasemin as to the planned future sales of
company property. We are amenable to such a meeting, and have produced documents in response to her books and
records demands as to those three topics. As to the third topic, we reiterated that, other than 81 Tanglewylde, no other
properties are planned to be sold or marketed for sale.
Plaintiff agreed to provide us with an updated list of questions. We are in receipt of your updated list of topics, and we
will review. Subject to Defendants’ review of the revised list of questions and the availability of the parties, and while
reserving all of Defendants’ rights, we noted our unavailability for 9/13, but proposed the latter part of next week as a
possibility.
Tanglewylde Proceeds
Plaintiff takes the position that Defendants’ responses regarding the use of Tanglewylde proceeds are too vague. We
noted that the 2020 and 2021 profit and loss statements provide guidance for which categories of expenses the
Company considers to be “ordinary course business expenses.”
This email is sent pursuant to 22 NYCRR §§ 202.7(c), 202.20-f and Rule 14 of the Commercial Division. Defendants
hereby reserve all rights, none of which are waived.
Sincerely,
Meghan
_______________________________________
MEGHAN E. HILL
PRYOR CASHMAN LLP
7 Times Square, New York, NY 10036-6569
mhill@pryorcashman.com
Direct Tel:212-326-0808 (also reachable remotely at this number)
www.pryorcashman.com
A member of Interlaw, an International Association of Independent Law Firms
From: Scott Parker
Sent: Wednesday, September 7, 2022 11:11 AM
To: Hill, Meghan E.
Cc: Sanjay Ibrahim ; Mohler, Bryan T. ; Younger,
Stephen P. ; Michele Kahn ; Soloway, Todd E.
Subject: RE: Tekiner v. Bremen House Inc. [PIB-LEGAL_DMS.FID449713]
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FILED: NEW YORK COUNTY CLERK 09/16/2022 11:06 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 692 RECEIVED NYSCEF: 09/16/2022
Meghan, per your request, here is a list of revised questions/topics for the Special Meeting. Would you please confirm if
you are going to arrange for the meeting to occur on September 15 or 16, subject to defendants’ availability? If there
are any questions that you believe have already been fully addressed through document production, please identify the
Bates ranges for those documents. Or, if there are any questions that your clients can answer in advance of the meeting
to streamline the issues, please provide those answers under separate cover. Thanks, Scott
Questions/Topics:
We would like to discuss the profit and loss of the company in 2021 (see Brem00357456-488), including: (1) the
distribution of the net income of $19,263,177.30 (see Brem00357457); and (2) the exact breakdown of the gross
payroll (85120) of $1,272,356.68 from the 2021 Profit and Loss for Bremen House Inc. (see Brem00357457,
Brem00357487, Brem00357497).
What is the profit and loss of the company so far in 2022? What is the market outlook for the company?
o What were the company’s financial projections for 2021, and were they met? How about for 2022 so
far? If not met, why not?
o Are any of the company’s properties not currently profitable? If so, which ones and why not? What is
the main driver of the company’s profitability?
o How much debt is the company currently carrying? Which properties have mortgages, and for how
much?
o Does the company currently have a line of credit? If so, how much and what has been used?
How much cash does the company currently have on hand? How does that compare to the end of 2021, 2020,
and 2019?
What is the status of the company’s tax returns (federal and state) for 2020 and 2021?
Which properties have existing code violations, and for how much?
How were the sale proceeds distributed from 1320 Madison?
Regarding the sale of the Tanglewylde property, your September 5 th letter indicated that the sale proceeds
would be used for “ordinary-course business expenses”, including the “payment of additional property taxes
among other things.” On our call today, you said that the reference to “ordinary-course business expenses” in
your letter was intended to be used the same way as that term is used on the 2021 Profit & Loss
statement. Please provide more specific information as to exactly which expenses the proceeds are going to be
applied to, and also which property taxes the Company intends to cover with these proceeds.
o Further, please identify the purchaser of the Tanglewylde property.
Other than Tanglewylde, is the company currently considering purchasing or selling any other properties? What
properties were purchased and/or sold in 2021 and 2022?
What is the percentage of vacant units (both residential and commercial) for the company’s properties,
including 35th Street?
Questions regarding 35th Street:
o What was the profit and loss for 35th Street for 2021 and 2022, including to whom are management fees
paid, how much and for what services?
o What is the status of the listing and sales effort for 35th Street? Is there a price? Have any offers been
made?
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FILED: NEW YORK COUNTY CLERK 09/16/2022 11:06 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 692 RECEIVED NYSCEF: 09/16/2022
o Why does company management want to sell 35th Street?
o What is the Bremen House log-in for Marcus Millichap?
What is the status of the company’s bookkeeper?
What accounting system is the company using post-Raish?
Since December 2020, please identify which company employees have been hired and/or fired.
o Please also provide a list of current employment agreements in effect for the company and its
employees.
Are all of the company’s corporate filings up to date? Are there any delinquent filings?
o Have the deficiencies identified in Jasmin’s May 23 rd letter (including but not limited to the Texas
companies) been cured? If not, why not?
What is the status of the German News entities?
What is the status of the certificate of occupancy for the company’s office?
Is there any other pending or threatened litigation involving any of the companies or its board members or
employees?
o Is the lawsuit regarding the office units takeover, involving rent stabilized tenants, still active?
Why is the company paying for the maintenance on the Marion Lane property, if the company is no longer
paying maintenance on personal homes?
Why does Jasmin’s home have an automobile expense listed in the Profit and Loss?
Scott Parker
NJ Office: 270 Davidson Avenue, Somerset, NJ 08873
NY Office: 5 Penn Plaza, Suite 2371, New York, NY 10001
Direct: +1 908.333.6220 | Main: +1 212.596.7037
www.piblaw.com
Confidentiality:
This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized
review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, contact the sender via reply email and destroy all
copies of the original message.
From: Hill, Meghan E.
Sent: Monday, September 5, 2022 9:57 PM
To: Scott Parker
Cc: Sanjay Ibrahim ; Mohler, Bryan T. ; Younger,
Stephen P. ; Michele Kahn ; Soloway, Todd E.
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FILED: NEW YORK COUNTY CLERK 09/16/2022 11:06 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 692 RECEIVED NYSCEF: 09/16/2022
Subject: [EXTERNAL] RE: Tekiner v. Bremen House Inc. [PIB-LEGAL_DMS.FID449713]
Scott:
See attached letter. We will circulate a dial-in for the meet and confer tomorrow in a separate email.
Meghan
_______________________________________
MEGHAN E. HILL
PRYOR CASHMAN LLP
7 Times Square, New York, NY 10036-6569
mhill@pryorcashman.com
Direct Tel:212-326-0808 (also reachable remotely at this number)
www.pryorcashman.com
A member of Interlaw, an International Association of Independent Law Firms
From: Scott Parker
Sent: Saturday, September 3, 2022 5:35 PM
To: Hill, Meghan E.
Cc: Sanjay Ibrahim ; Mohler, Bryan T. ; Younger,
Stephen P. ; Michele Kahn
Subject: RE: Tekiner v. Bremen House Inc. [PIB-LEGAL_DMS.FID449713]
Meghan, please see attached. We are available to meet and confer on all of these topics, plus the Santander subpoena,
on Tuesday until 2 pm.
Regards,
Scott
Scott Parker
NJ Office: 270 Davidson Avenue, Somerset, NJ 08873
NY Office: 5 Penn Plaza, Suite 2371, New York, NY 10001
Direct: +1 908.333.6220 | Main: +1 212.596.7037
www.piblaw.com
Confidentiality:
This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized
review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, contact the sender via reply email and destroy all
copies of the original message.
From: Hill, Meghan E.
Sent: Wednesday, August 31, 2022 3:18 PM
To: Scott Parker
Cc: Sanjay Ibrahim ; Mohler, Bryan T. ; Younger,
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FILED: NEW YORK COUNTY CLERK 09/16/2022 11:06 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 692 RECEIVED NYSCEF: 09/16/2022
Stephen P.
Subject: [EXTERNAL] RE: Tekiner v. Bremen House Inc. [PIB-LEGAL_DMS.FID449713]
Scott – See attached correspondence in response to your August 24, 2022 email. Defendants’ next production of
documents will be transmitted under separate cover.
Please confirm by no later than 9:00 am tomorrow that the return date of the Santander Bank subpoena will be
extended to September 15, 2022 in order for the parties to meet and confer regarding the scope of the documents
requested.
Meghan
_______________________________________
MEGHAN E. HILL
PRYOR CASHMAN LLP
7 Times Square, New York, NY 10036-6569
mhill@pryorcashman.com
Direct Tel:212-326-0808 (also reachable remotely at this number)
www.pryorcashman.com
A member of Interlaw, an International Association of Independent Law Firms
From: Scott Parker
Sent: Tuesday, August 30, 2022 10:26 AM
To: Hill, Meghan E.
Cc: Sanjay Ibrahim ; Mohler, Bryan T. ; Younger,
Stephen P.
Subject: RE: Tekiner v. Bremen House Inc. [PIB-LEGAL_DMS.FID449713]
Meghan, we would be happy to meet and confer about the scope of the Santander subpoena. But we also must address
the multiple other topics that we have written to you about that you continue to ignore (see attached).
For example – when is the Special Meeting going to be held? Back on July 22 (i.e., five weeks ago), you agreed that it
would be held during the week of August 29, and you expressed a preference for the meeting to be held early that
week, to which we agreed. It is now August 30th, yet you have still not even confirmed the date of the meeting, let alone
scheduled it.
Regards,
Scott
Scott Parker
NJ Office: 270 Davidson Avenue, Somerset, NJ 08873
NY Office: 5 Penn Plaza, Suite 2371, New York, NY 10001
Direct: +1 908.333.6220 | Main: +1 212.596.7037
www.piblaw.com
Confidentiality:
6
FILED: NEW YORK COUNTY CLERK 09/16/2022 11:06 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 692 RECEIVED NYSCEF: 09/16/2022
This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized
review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, contact the sender via reply email and destroy all
copies of the original message.
From: Hill, Meghan E.
Sent: Monday, August 29, 2022 9:36 PM
To: Scott Parker
Cc: Sanjay Ibrahim ; Mohler, Bryan T.
Subject: [EXTERNAL] Tekiner v. Bremen House Inc.
Scott –
I left you a voicemail earlier this evening. We would like to meet and confer about the scope of the Santander subpoena.
Please give me a call to discuss.
Thanks,
Meghan
_______________________________________
MEGHAN E. HILL
PRYOR CASHMAN LLP
7 Times Square, New York, NY 10036-6569
mhill@pryorcashman.com
Direct Tel:212-326-0808 (also reachable remotely at this number)
www.pryorcashman.com
A member of Interlaw, an International Association of Independent Law Firms
***CONFIDENTIALITY NOTICE***
This email contains confidential information which may also be legally privileged and which is intended only for the use of
the recipient(s) named above. If you are not the intended recipient, you are hereby notified that forwarding or copying of
this email, or the taking of any action in reliance on its contents, may be strictly prohibited. If you have received this email
in error, please notify us immediately by reply email and delete this message from your inbox.
***CONFIDENTIALITY NOTICE***
This email contains confidential information which may also be legally privileged and which is intended only for the use of
the recipient(s) named above. If you are not the intended recipient, you are hereby notified that forwarding or copying of
this email, or the taking of any action in reliance on its contents, may be strictly prohibited. If you have received this email
in error, please notify us immediately by reply email and delete this message from your inbox.
***CONFIDENTIALITY NOTICE***
This email contains confidential information which may also be legally privileged and which is intended only for the use of
the recipient(s) named above. If you are not the intended recipient, you are hereby notified that forwarding or copying of
this email, or the taking of any action in reliance on its contents, may be strictly prohibited. If you have received this email
in error, please notify us immediately by reply email and delete this message from your inbox.
7
Preview
FILED: NEW YORK COUNTY CLERK 09/16/2022 11:06 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 692 RECEIVED NYSCEF: 09/16/2022 EXHIBIT B FILED: NEW YORK COUNTY CLERK 09/16/2022 11:06 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 692 RECEIVED NYSCEF: 09/16/2022 Keating, Lawrence P. From: Hill, Meghan E. Sent: Wednesday, September 7, 2022 3:39 PM To: Scott Parker Cc: Sanjay Ibrahim; Mohler, Bryan T.; Younger, Stephen P.; Michele Kahn; Soloway, Todd E. Subject: RE: Tekiner v. Bremen House Inc. [PIB-LEGAL_DMS.FID449713] Scott – We write to memorialize the discussions between counsel during meet and confer held yesterday afternoon. Immediately advise if you disagree with any of the following. Santander Subpoena First, you agreed to get back to me as soon as possible about extending the return date of the subpoena to allow the parties a good faith opportunity to meet and confer and, if disputes remain, follow the pre-motion procedure mandated by Commercial Division Rule 14 and Justice Cohen’s Individual Practices and Procedures, VII.B. Our proposal was to set the return date for two weeks after the Rule 14 conference. Please note that, if we do not hear from you about this issue by 10 am tomorrow (Thursday), we intend to call the Court to discuss. Defendants raised the following global defects with the subpoena: 1. The subpoena is facially defective for lack of a description of the reason why Santander’s documents are material and necessary. I asked if Plaintiff would consider withdrawing the subpoena and re-serving a new one, and you said you would get back to me. 2. To the extent the requests seek non-redacted copies of documents redacted for PII, Plaintiff indicated willingness to amend those requests as Defendants could see no reasonable basis for such a request. 3. To the extent the requests seek information outside any applicable statute of limitations of Plaintiff’s causes of action, Plaintiff will advise as to her willingness to revise the time periods at issue. The parties stated their position as to the following categories as follows: 4. Bank account statements of the Residuary Trust of Sami Tekiner are irrelevant and requests pertaining to those documents are not proper. 5. You did not provide a basis for seeking documents pertaining to dismissed parties in the case other than “transfers into and out of accounts” held by such parties are relevant to show “management or mismanagement of the companies.” You declined to identify to which causes of action those reasons apply. 6. You gave the same basis as to why Plaintiff seeks documents from the bank accounts belonging to the individual defendants. 7. You agreed to provide Plaintiff’s basis for requesting the signature cards in request 20. 8. Defendants stated that they do not concede the relevance of any documents previously produced. 9. As to Requests 8, 9, 15-19, Defendants’ position is that they are currently so overbroad as to be impossible to respond to. Plaintiff agreed to reconsider the lack of a time period in those requests. Medical Records Plaintiff will serve an updated list of document demands, and we will review and respond to them. Privilege Log Defendants’ re-review of the privilege log is underway. We agreed to take under advisement your request to produce documents on a rolling basis, and will get back to you as to that issue. We will also confirm with prior counsel whether the Zeynep privilege log is a subset of the larger privilege log. 1 FILED: NEW YORK COUNTY CLERK 09/16/2022 11:06 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 692 RECEIVED NYSCEF: 09/16/2022 Depositions An update regarding the availability of Defendants for depositions is forthcoming. You advised that Plaintiff also intends to seek the non-party depositions of Steve Levine and John Stewart based on previously served subpoenas. We will reach out to both to indicate our representation of Defendants and discuss dates. You said you would get back to me as to any other third-party depositions Plaintiff intends to seek. Special Meeting Plaintiffs take the position that Defendants have no discretion per the Bylaws to refuse to hold the Special Meeting. Defendants’ position remains that it is ready to hold a Special Meeting, but inasmuch as the Special Meeting is part of an ongoing strategy of harassment with no valid business purpose, Defendants have no obligation to hold such a meeting. We explained that our previous understanding based on the May 19 notice and conversations with you and Michelle was that the purposes of the meeting were as follows: 1) to advise Yasemin on events that occurred while she was not a director or officer; 2) to give her a global financial update with the aid of up-to-date financial reporting of the Company, which reporting Defendants have now produced; and 3) to advise Yasemin as to the planned future sales of company property. We are amenable to such a meeting, and have produced documents in response to her books and records demands as to those three topics. As to the third topic, we reiterated that, other than 81 Tanglewylde, no other properties are planned to be sold or marketed for sale. Plaintiff agreed to provide us with an updated list of questions. We are in receipt of your updated list of topics, and we will review. Subject to Defendants’ review of the revised list of questions and the availability of the parties, and while reserving all of Defendants’ rights, we noted our unavailability for 9/13, but proposed the latter part of next week as a possibility. Tanglewylde Proceeds Plaintiff takes the position that Defendants’ responses regarding the use of Tanglewylde proceeds are too vague. We noted that the 2020 and 2021 profit and loss statements provide guidance for which categories of expenses the Company considers to be “ordinary course business expenses.” This email is sent pursuant to 22 NYCRR §§ 202.7(c), 202.20-f and Rule 14 of the Commercial Division. Defendants hereby reserve all rights, none of which are waived. Sincerely, Meghan _______________________________________ MEGHAN E. HILL PRYOR CASHMAN LLP 7 Times Square, New York, NY 10036-6569 mhill@pryorcashman.com Direct Tel:212-326-0808 (also reachable remotely at this number) www.pryorcashman.com A member of Interlaw, an International Association of Independent Law Firms From: Scott Parker Sent: Wednesday, September 7, 2022 11:11 AM To: Hill, Meghan E. Cc: Sanjay Ibrahim ; Mohler, Bryan T. ; Younger, Stephen P. ; Michele Kahn ; Soloway, Todd E. Subject: RE: Tekiner v. Bremen House Inc. [PIB-LEGAL_DMS.FID449713] 2 FILED: NEW YORK COUNTY CLERK 09/16/2022 11:06 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 692 RECEIVED NYSCEF: 09/16/2022 Meghan, per your request, here is a list of revised questions/topics for the Special Meeting. Would you please confirm if you are going to arrange for the meeting to occur on September 15 or 16, subject to defendants’ availability? If there are any questions that you believe have already been fully addressed through document production, please identify the Bates ranges for those documents. Or, if there are any questions that your clients can answer in advance of the meeting to streamline the issues, please provide those answers under separate cover. Thanks, Scott Questions/Topics: We would like to discuss the profit and loss of the company in 2021 (see Brem00357456-488), including: (1) the distribution of the net income of $19,263,177.30 (see Brem00357457); and (2) the exact breakdown of the gross payroll (85120) of $1,272,356.68 from the 2021 Profit and Loss for Bremen House Inc. (see Brem00357457, Brem00357487, Brem00357497). What is the profit and loss of the company so far in 2022? What is the market outlook for the company? o What were the company’s financial projections for 2021, and were they met? How about for 2022 so far? If not met, why not? o Are any of the company’s properties not currently profitable? If so, which ones and why not? What is the main driver of the company’s profitability? o How much debt is the company currently carrying? Which properties have mortgages, and for how much? o Does the company currently have a line of credit? If so, how much and what has been used? How much cash does the company currently have on hand? How does that compare to the end of 2021, 2020, and 2019? What is the status of the company’s tax returns (federal and state) for 2020 and 2021? Which properties have existing code violations, and for how much? How were the sale proceeds distributed from 1320 Madison? Regarding the sale of the Tanglewylde property, your September 5 th letter indicated that the sale proceeds would be used for “ordinary-course business expenses”, including the “payment of additional property taxes among other things.” On our call today, you said that the reference to “ordinary-course business expenses” in your letter was intended to be used the same way as that term is used on the 2021 Profit & Loss statement. Please provide more specific information as to exactly which expenses the proceeds are going to be applied to, and also which property taxes the Company intends to cover with these proceeds. o Further, please identify the purchaser of the Tanglewylde property. Other than Tanglewylde, is the company currently considering purchasing or selling any other properties? What properties were purchased and/or sold in 2021 and 2022? What is the percentage of vacant units (both residential and commercial) for the company’s properties, including 35th Street? Questions regarding 35th Street: o What was the profit and loss for 35th Street for 2021 and 2022, including to whom are management fees paid, how much and for what services? o What is the status of the listing and sales effort for 35th Street? Is there a price? Have any offers been made? 3 FILED: NEW YORK COUNTY CLERK 09/16/2022 11:06 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 692 RECEIVED NYSCEF: 09/16/2022 o Why does company management want to sell 35th Street? o What is the Bremen House log-in for Marcus Millichap? What is the status of the company’s bookkeeper? What accounting system is the company using post-Raish? Since December 2020, please identify which company employees have been hired and/or fired. o Please also provide a list of current employment agreements in effect for the company and its employees. Are all of the company’s corporate filings up to date? Are there any delinquent filings? o Have the deficiencies identified in Jasmin’s May 23 rd letter (including but not limited to the Texas companies) been cured? If not, why not? What is the status of the German News entities? What is the status of the certificate of occupancy for the company’s office? Is there any other pending or threatened litigation involving any of the companies or its board members or employees? o Is the lawsuit regarding the office units takeover, involving rent stabilized tenants, still active? Why is the company paying for the maintenance on the Marion Lane property, if the company is no longer paying maintenance on personal homes? Why does Jasmin’s home have an automobile expense listed in the Profit and Loss? Scott Parker NJ Office: 270 Davidson Avenue, Somerset, NJ 08873 NY Office: 5 Penn Plaza, Suite 2371, New York, NY 10001 Direct: +1 908.333.6220 | Main: +1 212.596.7037 www.piblaw.com Confidentiality: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, contact the sender via reply email and destroy all copies of the original message. From: Hill, Meghan E. Sent: Monday, September 5, 2022 9:57 PM To: Scott Parker Cc: Sanjay Ibrahim ; Mohler, Bryan T. ; Younger, Stephen P. ; Michele Kahn ; Soloway, Todd E. 4 FILED: NEW YORK COUNTY CLERK 09/16/2022 11:06 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 692 RECEIVED NYSCEF: 09/16/2022 Subject: [EXTERNAL] RE: Tekiner v. Bremen House Inc. [PIB-LEGAL_DMS.FID449713] Scott: See attached letter. We will circulate a dial-in for the meet and confer tomorrow in a separate email. Meghan _______________________________________ MEGHAN E. HILL PRYOR CASHMAN LLP 7 Times Square, New York, NY 10036-6569 mhill@pryorcashman.com Direct Tel:212-326-0808 (also reachable remotely at this number) www.pryorcashman.com A member of Interlaw, an International Association of Independent Law Firms From: Scott Parker Sent: Saturday, September 3, 2022 5:35 PM To: Hill, Meghan E. Cc: Sanjay Ibrahim ; Mohler, Bryan T. ; Younger, Stephen P. ; Michele Kahn Subject: RE: Tekiner v. Bremen House Inc. [PIB-LEGAL_DMS.FID449713] Meghan, please see attached. We are available to meet and confer on all of these topics, plus the Santander subpoena, on Tuesday until 2 pm. Regards, Scott Scott Parker NJ Office: 270 Davidson Avenue, Somerset, NJ 08873 NY Office: 5 Penn Plaza, Suite 2371, New York, NY 10001 Direct: +1 908.333.6220 | Main: +1 212.596.7037 www.piblaw.com Confidentiality: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, contact the sender via reply email and destroy all copies of the original message. From: Hill, Meghan E. Sent: Wednesday, August 31, 2022 3:18 PM To: Scott Parker Cc: Sanjay Ibrahim ; Mohler, Bryan T. ; Younger, 5 FILED: NEW YORK COUNTY CLERK 09/16/2022 11:06 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 692 RECEIVED NYSCEF: 09/16/2022 Stephen P. Subject: [EXTERNAL] RE: Tekiner v. Bremen House Inc. [PIB-LEGAL_DMS.FID449713] Scott – See attached correspondence in response to your August 24, 2022 email. Defendants’ next production of documents will be transmitted under separate cover. Please confirm by no later than 9:00 am tomorrow that the return date of the Santander Bank subpoena will be extended to September 15, 2022 in order for the parties to meet and confer regarding the scope of the documents requested. Meghan _______________________________________ MEGHAN E. HILL PRYOR CASHMAN LLP 7 Times Square, New York, NY 10036-6569 mhill@pryorcashman.com Direct Tel:212-326-0808 (also reachable remotely at this number) www.pryorcashman.com A member of Interlaw, an International Association of Independent Law Firms From: Scott Parker Sent: Tuesday, August 30, 2022 10:26 AM To: Hill, Meghan E. Cc: Sanjay Ibrahim ; Mohler, Bryan T. ; Younger, Stephen P. Subject: RE: Tekiner v. Bremen House Inc. [PIB-LEGAL_DMS.FID449713] Meghan, we would be happy to meet and confer about the scope of the Santander subpoena. But we also must address the multiple other topics that we have written to you about that you continue to ignore (see attached). For example – when is the Special Meeting going to be held? Back on July 22 (i.e., five weeks ago), you agreed that it would be held during the week of August 29, and you expressed a preference for the meeting to be held early that week, to which we agreed. It is now August 30th, yet you have still not even confirmed the date of the meeting, let alone scheduled it. Regards, Scott Scott Parker NJ Office: 270 Davidson Avenue, Somerset, NJ 08873 NY Office: 5 Penn Plaza, Suite 2371, New York, NY 10001 Direct: +1 908.333.6220 | Main: +1 212.596.7037 www.piblaw.com Confidentiality: 6 FILED: NEW YORK COUNTY CLERK 09/16/2022 11:06 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 692 RECEIVED NYSCEF: 09/16/2022 This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, contact the sender via reply email and destroy all copies of the original message. From: Hill, Meghan E. Sent: Monday, August 29, 2022 9:36 PM To: Scott Parker Cc: Sanjay Ibrahim ; Mohler, Bryan T. Subject: [EXTERNAL] Tekiner v. Bremen House Inc. Scott – I left you a voicemail earlier this evening. We would like to meet and confer about the scope of the Santander subpoena. Please give me a call to discuss. Thanks, Meghan _______________________________________ MEGHAN E. HILL PRYOR CASHMAN LLP 7 Times Square, New York, NY 10036-6569 mhill@pryorcashman.com Direct Tel:212-326-0808 (also reachable remotely at this number) www.pryorcashman.com A member of Interlaw, an International Association of Independent Law Firms ***CONFIDENTIALITY NOTICE*** This email contains confidential information which may also be legally privileged and which is intended only for the use of the recipient(s) named above. If you are not the intended recipient, you are hereby notified that forwarding or copying of this email, or the taking of any action in reliance on its contents, may be strictly prohibited. If you have received this email in error, please notify us immediately by reply email and delete this message from your inbox. ***CONFIDENTIALITY NOTICE*** This email contains confidential information which may also be legally privileged and which is intended only for the use of the recipient(s) named above. If you are not the intended recipient, you are hereby notified that forwarding or copying of this email, or the taking of any action in reliance on its contents, may be strictly prohibited. If you have received this email in error, please notify us immediately by reply email and delete this message from your inbox. ***CONFIDENTIALITY NOTICE*** This email contains confidential information which may also be legally privileged and which is intended only for the use of the recipient(s) named above. If you are not the intended recipient, you are hereby notified that forwarding or copying of this email, or the taking of any action in reliance on its contents, may be strictly prohibited. If you have received this email in error, please notify us immediately by reply email and delete this message from your inbox. 7