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.   738                                                                                RECEIVED      NYSCEF:     10/05/2022




                                           EXHIBIT                                               10
   FILED:         NEW     YORK       COUNTY        CLERK        10/05/2022             11:46        AM                 INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   738                                                                                RECEIVED      NYSCEF:     10/05/2022
                                                                                                                        Writer’s Direct Contact:
                                                                                                                            908.333.6220 (Tel.)
         PARKER                    IBRAHIM                     &      BERG               LLP                                 212.596.7036 (Fax)
                                                                                                                       scott.parker@piblaw.com
                                                                                                                               www.piblaw.com

                  September 19, 2022

                  VIA E-MAIL
                  Meghan E. Hill
                  Pryor Cashman LLP
                  7 Times Square
                  New York, New York 10036-6569

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

                  Dear Meghan:

                           I write with respect to the Court’s August 17, 2022 order, which granted in part Plaintiff
                  Yasemin     Tekiner’s    motion   to  compel    “to  the  extent   that Defendants’     categorical    assertion   of
                  privilege with respect to corporate business-related documents is overly broad.”                  (NYSCEF Doc.
                  No. 680).    Although that order is now a month old, you have not yet produced any documents in
                  compliance with the Court’s order.         We raised this issue during our meet-and-confer on September
                  6, and you said that Defendants would be willing to consider producing these documents to us on
                  a rolling basis – an arrangement to which we agreed.             Defendants, however, still failed to produce
                  a single document after our meet-and-confer.

                           On September 13, 2022, we wrote to you to follow up on your failure, and asked you to
                  confirm exactly when you would: (1) begin your rolling production; and (2) complete your rolling
                  production.    Once again, you ignored us completely.

                           In light of   your  month-long,     willful disregard of    the Court’s order,     this is to advise    you
                  that, if you do not produce the entire set of responsive documents to us by Tuesday, September
                  20 at 2 pm, we will contact the Court to advise as your contempt of this order.

                                                                                                   Very truly yours,




                                                                                                   Scott W. Parker
                  cc:      Stephen P. Younger, Esq. (via e-mail)
                           Michele Kahn, Esq. (via e-mail)




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