Preview
FILED: NEW YORK COUNTY CLERK 10/19/2022 12:10 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 788 RECEIVED NYSCEF: 10/19/2022
EXHIBIT F
FILED: NEW YORK COUNTY CLERK 10/19/2022 12:10 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 788 RECEIVED NYSCEF: 10/19/2022
From: Hill, Meghan E.
Sent: Wednesday, August 10, 2022 10:34:11 AM
To: Scott Parker
Cc: Soloway, Todd E. Tilton, Clare P. Sanjay Ibrahim Younger, Stephen P. mk Mohler, Bryan T.
Subject: RE: Tekiner v. Bremen House - August 4 production & scheduling of depositions [PIB-LEGAL_DMS.FID449713]
Importance: Normal
Sensitivity: None
Scott,
As you know, you and your client have made a series of voluminous, repetitive, and overbroad requests for materials –
including, as you now concede, requests seeking information already in your possession. We are working diligently to make
accessible certain Company records as we committed, and anticipate making a further production this week (to be followed
by additional rolling productions as necessary). This is entirely consistent with the spirit and letter of our agreement, and any
duplication you identify is singularly the result of the untargeted and unspecific nature of your client’s requests.
Regarding deposition scheduling, your feigned indignation is not credible and not in good faith. When we conferred
regarding you and your client’s information requests, we specifically and expressly discussed that addressing your and your
client’s requests would be time-intensive, and you repeatedly stated that you understood. That you immediately followed
up those discussions by pressing for deposition dates – even though the fact discovery deadline has now been extended and
is more than two months away – smacks of unnecessary gamesmanship. In any event, we are generally available next
Tuesday and Wednesday to confer regarding scheduling (we have a court appearance on Monday, as you will recall).
Last, please promptly provide an unsealed/unredacted copy of NYSCEF Dkt. No. 550. We do not have it, as it is our
understanding that it was never provided to predecessor counsel.
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: Tuesday, August 9, 2022 9:04 AM
To: Hill, Meghan E.
Cc: Soloway, Todd E. ; Tilton, Clare P. ; Sanjay Ibrahim
; Younger, Stephen P. ; mk
Subject: Tekiner v. Bremen House - August 4 production & scheduling of depositions [PIB-LEGAL_DMS.FID449713]
Meghan, we have reviewed your production of seven documents on August 4, in furtherance of your commitment that your
clients would begin to produce or make accessible the Company’s books and records by that date. Out of 866 pages that you
produced to us, however, only 11 pages of that production (i.e., 0.013%) were new: BREM00357123-BREM00357128, which is a
lease abstract relating to 1929 E. Garrison Blvd. in Gastonia, North Carolina. The remaining pages have all previously produced
by your clients:
FILED: NEW YORK COUNTY CLERK 10/19/2022 12:10 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 788 RECEIVED NYSCEF: 10/19/2022
· Closing Documents, Bremen House La Porte LLC (Purchaser) from The Market at Spencer, LLC (Seller), Closing Date
March 23, 2021, Volume 1 of 2
August 4th Bates Range: BREM00357246-BREM00357405
Prior Bates Range: BREM00324334-BREM00324493
· Closing Documents, Bremen House La Porte LLC (Purchaser) from The Market at Spencer, LLC (Seller), Closing Date
March 23, 2021, Volume 2 of 2
August 4th Bates Range (produced twice in 8/4/22 production): BREM00357006-BREM00357122 and BREM00357129-
BREM007245
Prior Bates Range: BREM00325988-BREM00326104
· List of Properties with Lease and Mortgage Information
August 4th Bates Range: BREM00357406-BREM00357407
Prior Bates Range: Page 1 (Brem00325161); Page 2 (Not Previously Produced)
· Lease Abstract, 9002 Spencer Highway, La Porte, Texas 77571
August 4th Bates Range: BREM00357408-BREM00357411
Prior Bates Range: Not Previously Produced
· Closing Documents re 7-Eleven, 1929 E. Garrison Blvd, Gastonia, North Carolina
August 4th Bates Range: BREM00357412-BREM00357869
Prior Bates Range: BREM00324494-BREM00324953
Your nearly entirely duplicative production is, to say the least, disappointing and inconsistent with the spirit of our
agreement, which we negotiated with you in good faith. Please advise right away exactly when you anticipate producing the
bulk of the balance of the documents, beyond the 11 new pages that you have produced thus far. As you know, a special
meeting is scheduled to be held in less than three weeks, and our written questions to your clients are due to you by August
15 – i.e., six days away.
Additionally, it has now been 14 days since we asked you to address the potential deposition dates for Jasmin, Gonca, and
Berrin. We have written to you multiple times about this issue, we have asked for your availability for a call, and we have
tried to called you – and every single one of our outreaches has gone unanswered by you. Frankly, behavior like this is
reminiscent of your predecessor counsel. Once again, we ask you to let us know when you are available for a call to discuss.
If you continue to ignore our requests to schedule these depositions, we reserve the right to seek appropriate relief from the
Court.
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
FILED: NEW YORK COUNTY CLERK 10/19/2022 12:10 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 788 RECEIVED NYSCEF: 10/19/2022
Confi denti a l i ty:
Thi s ema i l mes s a ge i s for the s ol e us e of the i ntended reci pi ent(s ) a nd ma y conta i n confi denti a l a nd pri vi l eged i nforma ti on. Any
una uthori zed revi ew, us e, di s cl os ure or di s tri buti on i s s tri ctl y prohi bi ted. If you a re not the i ntended reci pi ent, conta ct the s ender vi a repl y
ema i l a nd des troy a l l copi es of the ori gi na l mes s a ge.
From: Scott Parker
Sent: Thursday, August 4, 2022 9:49 AM
To: Hill, Meghan E.
Cc: Soloway, Todd E. ; Tilton, Clare P. ; Sanjay Ibrahim
; Younger, Stephen P. ; mk
Subject: RE: Tekiner v. Bremen House - Dates for Proposed Order [PIB-LEGAL_DMS.FID449713]
Meghan, we have still not heard back from you. Are you free to talk to me and Jay today or tomorrow? Best, Scott
Scott Parker
Office 908.333.6220 | Mobile 973.309.3156
Ext. 101
From: Scott Parker
Sent: Monday, August 1, 2022 1:59 PM
To: Hill, Meghan E.
Cc: Soloway, Todd E. ; Tilton, Clare P. ; Sanjay Ibrahim
; Younger, Stephen P. ; mk
Subject: RE: Tekiner v. Bremen House - Dates for Proposed Order [PIB-LEGAL_DMS.FID449713]
Meghan, hope all is well and that you had a good weekend. We wanted to touch base on the anticipated production of the
books and records documents – while we had agreed that your clients would begin to produce or make accessible those
documents by August 4, you had indicated that you would make every effort to begin that production in advance of that date,
so we just wanted to get a sense of where things stood.
Also, we are circling back on our correspondence below regarding depositions, and in particular, the need to lock down dates
as soon as possible for Jasmin, Gonca and Berrin. We would like to schedule those depositions around the end of August /
beginning of September. Would you please let us know.
Best,
Scott
Scott Parker
Office 908.333.6220 | Mobile 973.309.3156
Ext. 101
From: Scott Parker
Sent: Tuesday, July 26, 2022 8:51 AM
To: Hill, Meghan E.
Cc: Soloway, Todd E. ; Tilton, Clare P. ; Sanjay Ibrahim
; Younger, Stephen P. ; mk
Subject: RE: Tekiner v. Bremen House - Dates for Proposed Order [PIB-LEGAL_DMS.FID449713]
Meghan, we are just circling back on the proposed stipulations. Also, we need to begin rescheduling the depositions, which
we would like to move forward with shortly after oral argument on August 15, considering the volume of depositions that we
need to get through and the likely close of fact discovery at the end of September. At minimum, we would like to lock down
FILED: NEW YORK COUNTY CLERK 10/19/2022 12:10 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 788 RECEIVED NYSCEF: 10/19/2022
dates as soon as possible for Jasmin, Gonca and Berrin (who were previously tentatively scheduled for late July and early
August).
Best,
Scott
Scott Parker
Office 908.333.6220 | Mobile 973.309.3156
Ext. 101
From: Scott Parker
Sent: Friday, July 22, 2022 1:35 PM
To: Hill, Meghan E.
Cc: Soloway, Todd E. ; Tilton, Clare P. ; Sanjay Ibrahim
; Younger, Stephen P. ; mk
Subject: RE: Tekiner v. Bremen House - Dates for Proposed Order [PIB-LEGAL_DMS.FID449713]
Meghan, a slightly revised version of the proposed stipulation is attached – we added to paragraph 5 the fact that oral
argument on Yasemin’s motion to remove Billur as trustee (Mot. Seq. No. 24) is also to be held on August 15 at 9:30 am. Best,
Scott
From: Scott Parker
Sent: Friday, July 22, 2022 1:27 PM
To: Hill, Meghan E.
Cc: Soloway, Todd E. ; Tilton, Clare P. ; Sanjay Ibrahim
; Younger, Stephen P. ; mk
Subject: RE: Tekiner v. Bremen House - Dates for Proposed Order [PIB-LEGAL_DMS.FID449713]
Meghan, here is the proposed stipulation regarding your clients’ deadline to respond to the Second Amended Complaint, the
remaining briefing schedule on Zeynep’s motion to remove Billur as trustee, the remaining briefing schedule on Yasemin’s
motion for contempt, and the oral argument date for motions 21, 22, 23, and 32 (which has already been set by the Court, but
which we include here as a matter of completeness).
Best,
Scott
From: Scott Parker
Sent: Friday, July 22, 2022 9:41 AM
To: Hill, Meghan E.
Cc: Soloway, Todd E. ; Tilton, Clare P. ; Sanjay Ibrahim
; Younger, Stephen P. ; mk
Subject: RE: Tekiner v. Bremen House - Dates for Proposed Order [PIB-LEGAL_DMS.FID449713]
Hi Meghan – I don’t think we can strike that provision. We certainly understand the concern you raised about jamming expert
witness discovery. But we still need to have an end date for all discovery, and we think the judge will be expecting it. That
being said, I think that we can accomplish the same objective by leaving that provision in, but changing the discovery end
date to December 27, 2022. Let me know what you think.
I’ll send you the other stipulation regarding motion deadlines tomorrow morning.
Best,
Scott
FILED: NEW YORK COUNTY CLERK 10/19/2022 12:10 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 788 RECEIVED NYSCEF: 10/19/2022
Scott Parker
Office 908.333.6220 | Mobile 973.309.3156
Ext. 101
From: Hill, Meghan E.
Sent: Wednesday, July 20, 2022 5:16 PM
To: Scott Parker
Cc: Soloway, Todd E. ; Tilton, Clare P. ; Sanjay Ibrahim
; Younger, Stephen P. ; mk
Subject: [EXTERNAL] RE: Tekiner v. Bremen House - Dates for Proposed Order [PIB-LEGAL_DMS.FID449713]
Scott – after we spoke about the discovery deadlines yesterday, you asked me to send you any revisions to your stip. We
propose eliminating one date, as discussed:
NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by the undersigned attorneys for the parties
that:
1. The deadline to complete fact discovery shall be October 17, 2022;
2. The deadline for CPLR 3101(d) expert disclosure shall be November 15, 2022;
3. The end date for all discovery shall be December 15, 2022;
4. The deadline to file the note of issue shall be December 28, 2022;
5. The deadline for filing dispositive motions shall be January 27, 2023; and
We think this change addresses the concerns about jamming up expert witness discovery. Let us know if you are in
agreement so we can get the discovery stip finalized.
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: Monday, July 18, 2022 4:29 PM
To: Hill, Meghan E. ; Younger, Stephen P. ; mk
Cc: Soloway, Todd E. ; Tilton, Clare P. ; Sanjay Ibrahim
Subject: RE: Tekiner v. Bremen House - Dates for Proposed Order [PIB-LEGAL_DMS.FID449713]
Meghan, we took the liberty of preparing the proposed stipulation as to discovery/NOI/dispositive motion deadlines. It is
attached, and it follows the prior form of stipulation that Judge Cohen previously approved. (And you are correct, the
deadline for the NOI is in fact 12/28/22.) If acceptable, would you please execute, and we will gladly arrange to have it filed
with the court.
We have also prepared a stipulation addressing motion briefing deadlines (and the August 5 deadline for Defendants to
respond to the Second Amended Complaint), but we will hold off on circulating that until after we’ve sorted out the issues
FILED: NEW YORK COUNTY CLERK 10/19/2022 12:10 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 788 RECEIVED NYSCEF: 10/19/2022
relating to the contempt motion.
Thanks,
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
Confi denti a l i ty:
Thi s ema i l mes s a ge i s for the s ol e us e of the i ntended reci pi ent(s ) a nd ma y conta i n confi denti a l a nd pri vi l eged i nforma ti on. Any
una uthori zed revi ew, us e, di s cl os ure or di s tri buti on i s s tri ctl y prohi bi ted. If you a re not the i ntended reci pi ent, conta ct the s ender vi a repl y
ema i l a nd des troy a l l copi es of the ori gi na l mes s a ge.
From: Hill, Meghan E.
Sent: Friday, July 15, 2022 4:12 PM
To: Younger, Stephen P. ; mk ; Scott Parker
Cc: Soloway, Todd E. ; Tilton, Clare P.
Subject: [EXTERNAL] Tekiner v. Bremen House - Dates for Proposed Order
Counsel:
Below is my record of all the deadlines and argument dates that were discussed during the conference. If your understanding
is the same, we will circulate a proposed order for your review.
Let me know.
Pleadings
1. Defendants’ Answer to Yasemin’s second complaint: 8/5/22
Motions
2. Mot. Seq. 021 (contempt):
a. Opposition: Monday 7/18/22
b. Reply: 7/19/22
c. Oral Argument: 7/22/22 at 9:15 am
3. Mot. Seq. 022 and 023 (discovery motions)
a. Fully briefed
b. Oral argument: 8/15/22 at 9:30 am
4. Mot. Seq. 032 (Zeynep motion for removal of trustee):
a. Opposition: 8/5 (or 1-2 days after)
b. Reply: 8/10/22 (or 1-2 days after)
c. Oral argument: 8/15/22 at 9:30 am
5. Mot. Seq. 024 (Yasemin motion for removal of trustee):
a. Fully briefed
FILED: NEW YORK COUNTY CLERK 10/19/2022 12:10 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 788 RECEIVED NYSCEF: 10/19/2022
b. Oral argument: 8/15/22 at 9:30 am
Discovery
6. Deadline to complete fact discovery: 10/17/2022
7. Deadline for 3101(d) expert disclosure: 11/28/2022
8. Deadline to file NOI: 12/16/2022 (This may have been 12/28/2022, I can’t remember Steve’s suggestion to the Judge on
this.)
9. Deadline to make dispositive motions: 1/27/2023
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
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FILED: NEW YORK COUNTY CLERK 10/19/2022 12:10 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 788 RECEIVED NYSCEF: 10/19/2022 EXHIBIT F FILED: NEW YORK COUNTY CLERK 10/19/2022 12:10 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 788 RECEIVED NYSCEF: 10/19/2022 From: Hill, Meghan E. Sent: Wednesday, August 10, 2022 10:34:11 AM To: Scott Parker Cc: Soloway, Todd E. Tilton, Clare P. Sanjay Ibrahim Younger, Stephen P. mk Mohler, Bryan T. Subject: RE: Tekiner v. Bremen House - August 4 production & scheduling of depositions [PIB-LEGAL_DMS.FID449713] Importance: Normal Sensitivity: None Scott, As you know, you and your client have made a series of voluminous, repetitive, and overbroad requests for materials – including, as you now concede, requests seeking information already in your possession. We are working diligently to make accessible certain Company records as we committed, and anticipate making a further production this week (to be followed by additional rolling productions as necessary). This is entirely consistent with the spirit and letter of our agreement, and any duplication you identify is singularly the result of the untargeted and unspecific nature of your client’s requests. Regarding deposition scheduling, your feigned indignation is not credible and not in good faith. When we conferred regarding you and your client’s information requests, we specifically and expressly discussed that addressing your and your client’s requests would be time-intensive, and you repeatedly stated that you understood. That you immediately followed up those discussions by pressing for deposition dates – even though the fact discovery deadline has now been extended and is more than two months away – smacks of unnecessary gamesmanship. In any event, we are generally available next Tuesday and Wednesday to confer regarding scheduling (we have a court appearance on Monday, as you will recall). Last, please promptly provide an unsealed/unredacted copy of NYSCEF Dkt. No. 550. We do not have it, as it is our understanding that it was never provided to predecessor counsel. 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: Tuesday, August 9, 2022 9:04 AM To: Hill, Meghan E. Cc: Soloway, Todd E. ; Tilton, Clare P. ; Sanjay Ibrahim ; Younger, Stephen P. ; mk Subject: Tekiner v. Bremen House - August 4 production & scheduling of depositions [PIB-LEGAL_DMS.FID449713] Meghan, we have reviewed your production of seven documents on August 4, in furtherance of your commitment that your clients would begin to produce or make accessible the Company’s books and records by that date. Out of 866 pages that you produced to us, however, only 11 pages of that production (i.e., 0.013%) were new: BREM00357123-BREM00357128, which is a lease abstract relating to 1929 E. Garrison Blvd. in Gastonia, North Carolina. The remaining pages have all previously produced by your clients: FILED: NEW YORK COUNTY CLERK 10/19/2022 12:10 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 788 RECEIVED NYSCEF: 10/19/2022 · Closing Documents, Bremen House La Porte LLC (Purchaser) from The Market at Spencer, LLC (Seller), Closing Date March 23, 2021, Volume 1 of 2 August 4th Bates Range: BREM00357246-BREM00357405 Prior Bates Range: BREM00324334-BREM00324493 · Closing Documents, Bremen House La Porte LLC (Purchaser) from The Market at Spencer, LLC (Seller), Closing Date March 23, 2021, Volume 2 of 2 August 4th Bates Range (produced twice in 8/4/22 production): BREM00357006-BREM00357122 and BREM00357129- BREM007245 Prior Bates Range: BREM00325988-BREM00326104 · List of Properties with Lease and Mortgage Information August 4th Bates Range: BREM00357406-BREM00357407 Prior Bates Range: Page 1 (Brem00325161); Page 2 (Not Previously Produced) · Lease Abstract, 9002 Spencer Highway, La Porte, Texas 77571 August 4th Bates Range: BREM00357408-BREM00357411 Prior Bates Range: Not Previously Produced · Closing Documents re 7-Eleven, 1929 E. Garrison Blvd, Gastonia, North Carolina August 4th Bates Range: BREM00357412-BREM00357869 Prior Bates Range: BREM00324494-BREM00324953 Your nearly entirely duplicative production is, to say the least, disappointing and inconsistent with the spirit of our agreement, which we negotiated with you in good faith. Please advise right away exactly when you anticipate producing the bulk of the balance of the documents, beyond the 11 new pages that you have produced thus far. As you know, a special meeting is scheduled to be held in less than three weeks, and our written questions to your clients are due to you by August 15 – i.e., six days away. Additionally, it has now been 14 days since we asked you to address the potential deposition dates for Jasmin, Gonca, and Berrin. We have written to you multiple times about this issue, we have asked for your availability for a call, and we have tried to called you – and every single one of our outreaches has gone unanswered by you. Frankly, behavior like this is reminiscent of your predecessor counsel. Once again, we ask you to let us know when you are available for a call to discuss. If you continue to ignore our requests to schedule these depositions, we reserve the right to seek appropriate relief from the Court. 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 FILED: NEW YORK COUNTY CLERK 10/19/2022 12:10 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 788 RECEIVED NYSCEF: 10/19/2022 Confi denti a l i ty: Thi s ema i l mes s a ge i s for the s ol e us e of the i ntended reci pi ent(s ) a nd ma y conta i n confi denti a l a nd pri vi l eged i nforma ti on. Any una uthori zed revi ew, us e, di s cl os ure or di s tri buti on i s s tri ctl y prohi bi ted. If you a re not the i ntended reci pi ent, conta ct the s ender vi a repl y ema i l a nd des troy a l l copi es of the ori gi na l mes s a ge. From: Scott Parker Sent: Thursday, August 4, 2022 9:49 AM To: Hill, Meghan E. Cc: Soloway, Todd E. ; Tilton, Clare P. ; Sanjay Ibrahim ; Younger, Stephen P. ; mk Subject: RE: Tekiner v. Bremen House - Dates for Proposed Order [PIB-LEGAL_DMS.FID449713] Meghan, we have still not heard back from you. Are you free to talk to me and Jay today or tomorrow? Best, Scott Scott Parker Office 908.333.6220 | Mobile 973.309.3156 Ext. 101 From: Scott Parker Sent: Monday, August 1, 2022 1:59 PM To: Hill, Meghan E. Cc: Soloway, Todd E. ; Tilton, Clare P. ; Sanjay Ibrahim ; Younger, Stephen P. ; mk Subject: RE: Tekiner v. Bremen House - Dates for Proposed Order [PIB-LEGAL_DMS.FID449713] Meghan, hope all is well and that you had a good weekend. We wanted to touch base on the anticipated production of the books and records documents – while we had agreed that your clients would begin to produce or make accessible those documents by August 4, you had indicated that you would make every effort to begin that production in advance of that date, so we just wanted to get a sense of where things stood. Also, we are circling back on our correspondence below regarding depositions, and in particular, the need to lock down dates as soon as possible for Jasmin, Gonca and Berrin. We would like to schedule those depositions around the end of August / beginning of September. Would you please let us know. Best, Scott Scott Parker Office 908.333.6220 | Mobile 973.309.3156 Ext. 101 From: Scott Parker Sent: Tuesday, July 26, 2022 8:51 AM To: Hill, Meghan E. Cc: Soloway, Todd E. ; Tilton, Clare P. ; Sanjay Ibrahim ; Younger, Stephen P. ; mk Subject: RE: Tekiner v. Bremen House - Dates for Proposed Order [PIB-LEGAL_DMS.FID449713] Meghan, we are just circling back on the proposed stipulations. Also, we need to begin rescheduling the depositions, which we would like to move forward with shortly after oral argument on August 15, considering the volume of depositions that we need to get through and the likely close of fact discovery at the end of September. At minimum, we would like to lock down FILED: NEW YORK COUNTY CLERK 10/19/2022 12:10 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 788 RECEIVED NYSCEF: 10/19/2022 dates as soon as possible for Jasmin, Gonca and Berrin (who were previously tentatively scheduled for late July and early August). Best, Scott Scott Parker Office 908.333.6220 | Mobile 973.309.3156 Ext. 101 From: Scott Parker Sent: Friday, July 22, 2022 1:35 PM To: Hill, Meghan E. Cc: Soloway, Todd E. ; Tilton, Clare P. ; Sanjay Ibrahim ; Younger, Stephen P. ; mk Subject: RE: Tekiner v. Bremen House - Dates for Proposed Order [PIB-LEGAL_DMS.FID449713] Meghan, a slightly revised version of the proposed stipulation is attached – we added to paragraph 5 the fact that oral argument on Yasemin’s motion to remove Billur as trustee (Mot. Seq. No. 24) is also to be held on August 15 at 9:30 am. Best, Scott From: Scott Parker Sent: Friday, July 22, 2022 1:27 PM To: Hill, Meghan E. Cc: Soloway, Todd E. ; Tilton, Clare P. ; Sanjay Ibrahim ; Younger, Stephen P. ; mk Subject: RE: Tekiner v. Bremen House - Dates for Proposed Order [PIB-LEGAL_DMS.FID449713] Meghan, here is the proposed stipulation regarding your clients’ deadline to respond to the Second Amended Complaint, the remaining briefing schedule on Zeynep’s motion to remove Billur as trustee, the remaining briefing schedule on Yasemin’s motion for contempt, and the oral argument date for motions 21, 22, 23, and 32 (which has already been set by the Court, but which we include here as a matter of completeness). Best, Scott From: Scott Parker Sent: Friday, July 22, 2022 9:41 AM To: Hill, Meghan E. Cc: Soloway, Todd E. ; Tilton, Clare P. ; Sanjay Ibrahim ; Younger, Stephen P. ; mk Subject: RE: Tekiner v. Bremen House - Dates for Proposed Order [PIB-LEGAL_DMS.FID449713] Hi Meghan – I don’t think we can strike that provision. We certainly understand the concern you raised about jamming expert witness discovery. But we still need to have an end date for all discovery, and we think the judge will be expecting it. That being said, I think that we can accomplish the same objective by leaving that provision in, but changing the discovery end date to December 27, 2022. Let me know what you think. I’ll send you the other stipulation regarding motion deadlines tomorrow morning. Best, Scott FILED: NEW YORK COUNTY CLERK 10/19/2022 12:10 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 788 RECEIVED NYSCEF: 10/19/2022 Scott Parker Office 908.333.6220 | Mobile 973.309.3156 Ext. 101 From: Hill, Meghan E. Sent: Wednesday, July 20, 2022 5:16 PM To: Scott Parker Cc: Soloway, Todd E. ; Tilton, Clare P. ; Sanjay Ibrahim ; Younger, Stephen P. ; mk Subject: [EXTERNAL] RE: Tekiner v. Bremen House - Dates for Proposed Order [PIB-LEGAL_DMS.FID449713] Scott – after we spoke about the discovery deadlines yesterday, you asked me to send you any revisions to your stip. We propose eliminating one date, as discussed: NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by the undersigned attorneys for the parties that: 1. The deadline to complete fact discovery shall be October 17, 2022; 2. The deadline for CPLR 3101(d) expert disclosure shall be November 15, 2022; 3. The end date for all discovery shall be December 15, 2022; 4. The deadline to file the note of issue shall be December 28, 2022; 5. The deadline for filing dispositive motions shall be January 27, 2023; and We think this change addresses the concerns about jamming up expert witness discovery. Let us know if you are in agreement so we can get the discovery stip finalized. 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: Monday, July 18, 2022 4:29 PM To: Hill, Meghan E. ; Younger, Stephen P. ; mk Cc: Soloway, Todd E. ; Tilton, Clare P. ; Sanjay Ibrahim Subject: RE: Tekiner v. Bremen House - Dates for Proposed Order [PIB-LEGAL_DMS.FID449713] Meghan, we took the liberty of preparing the proposed stipulation as to discovery/NOI/dispositive motion deadlines. It is attached, and it follows the prior form of stipulation that Judge Cohen previously approved. (And you are correct, the deadline for the NOI is in fact 12/28/22.) If acceptable, would you please execute, and we will gladly arrange to have it filed with the court. We have also prepared a stipulation addressing motion briefing deadlines (and the August 5 deadline for Defendants to respond to the Second Amended Complaint), but we will hold off on circulating that until after we’ve sorted out the issues FILED: NEW YORK COUNTY CLERK 10/19/2022 12:10 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 788 RECEIVED NYSCEF: 10/19/2022 relating to the contempt motion. Thanks, 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 Confi denti a l i ty: Thi s ema i l mes s a ge i s for the s ol e us e of the i ntended reci pi ent(s ) a nd ma y conta i n confi denti a l a nd pri vi l eged i nforma ti on. Any una uthori zed revi ew, us e, di s cl os ure or di s tri buti on i s s tri ctl y prohi bi ted. If you a re not the i ntended reci pi ent, conta ct the s ender vi a repl y ema i l a nd des troy a l l copi es of the ori gi na l mes s a ge. From: Hill, Meghan E. Sent: Friday, July 15, 2022 4:12 PM To: Younger, Stephen P. ; mk ; Scott Parker Cc: Soloway, Todd E. ; Tilton, Clare P. Subject: [EXTERNAL] Tekiner v. Bremen House - Dates for Proposed Order Counsel: Below is my record of all the deadlines and argument dates that were discussed during the conference. If your understanding is the same, we will circulate a proposed order for your review. Let me know. Pleadings 1. Defendants’ Answer to Yasemin’s second complaint: 8/5/22 Motions 2. Mot. Seq. 021 (contempt): a. Opposition: Monday 7/18/22 b. Reply: 7/19/22 c. Oral Argument: 7/22/22 at 9:15 am 3. Mot. Seq. 022 and 023 (discovery motions) a. Fully briefed b. Oral argument: 8/15/22 at 9:30 am 4. Mot. Seq. 032 (Zeynep motion for removal of trustee): a. Opposition: 8/5 (or 1-2 days after) b. Reply: 8/10/22 (or 1-2 days after) c. Oral argument: 8/15/22 at 9:30 am 5. Mot. Seq. 024 (Yasemin motion for removal of trustee): a. Fully briefed FILED: NEW YORK COUNTY CLERK 10/19/2022 12:10 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 788 RECEIVED NYSCEF: 10/19/2022 b. Oral argument: 8/15/22 at 9:30 am Discovery 6. Deadline to complete fact discovery: 10/17/2022 7. Deadline for 3101(d) expert disclosure: 11/28/2022 8. Deadline to file NOI: 12/16/2022 (This may have been 12/28/2022, I can’t remember Steve’s suggestion to the Judge on this.) 9. Deadline to make dispositive motions: 1/27/2023 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. 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