Exhibit,Appendix: 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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                                FILED:         NEW     YORK       COUNTY        CLERK        10/05/2022             11:46        AM                 INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   736                                                                                RECEIVED      NYSCEF:     10/05/2022




                                              EXHIBIT                                               8
   FILED:         NEW     YORK       COUNTY        CLERK        10/05/2022             11:46        AM                 INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   736                                                                                RECEIVED      NYSCEF:     10/05/2022




                  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: [EXTERNAL] 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.
   FILED:         NEW     YORK       COUNTY        CLERK        10/05/2022             11:46        AM                 INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   736                                                                                RECEIVED      NYSCEF:     10/05/2022




                  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.

                  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
   FILED:         NEW     YORK       COUNTY        CLERK        10/05/2022             11:46        AM                 INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   736                                                                                RECEIVED      NYSCEF:     10/05/2022




                  _______________________________________
                  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