Preview
FILED: NEW YORK COUNTY CLERK 09/23/2022 05:04 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 708 RECEIVED NYSCEF: 09/23/2022
EXHIBIT I
FILED: NEW YORK COUNTY CLERK 09/23/2022 05:04 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 708 RECEIVED NYSCEF: 09/23/2022
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]
Attachments: Tekiner - 9.3.22 ltr to M. Hill.pdf
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,
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
_______________________________________
1
FILED: NEW YORK COUNTY CLERK 09/23/2022 05:04 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 708 RECEIVED NYSCEF: 09/23/2022
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:
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 –
2
FILED: NEW YORK COUNTY CLERK 09/23/2022 05:04 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 708 RECEIVED NYSCEF: 09/23/2022
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.
3
FILED: NEW YORK COUNTY CLERK 09/23/2022 05:04 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 708 RECEIVED NYSCEF: 09/23/2022
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FILED: NEW YORK COUNTY CLERK 09/23/2022 05:04 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 708 RECEIVED NYSCEF: 09/23/2022 EXHIBIT I FILED: NEW YORK COUNTY CLERK 09/23/2022 05:04 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 708 RECEIVED NYSCEF: 09/23/2022 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] Attachments: Tekiner - 9.3.22 ltr to M. Hill.pdf 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, 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 _______________________________________ 1 FILED: NEW YORK COUNTY CLERK 09/23/2022 05:04 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 708 RECEIVED NYSCEF: 09/23/2022 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: 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 – 2 FILED: NEW YORK COUNTY CLERK 09/23/2022 05:04 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 708 RECEIVED NYSCEF: 09/23/2022 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. 3 FILED: NEW YORK COUNTY CLERK 09/23/2022 05:04 PM INDEX NO. 657193/2020 NYSCEF DOC. 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