On December 21, 2020 a
Exhibit,Appendix
was filed
involving a dispute between
Yasemin Tekiner,
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,
and
254-258 W. 35Th St. Llc,
Berrin Tekiner,
Billur Akipek
In Her Capacity As A Trustee Of The Yasemin Tekiner 2011 Descendants Trust,
Bremen House Inc.,
Bremen House Texas, Inc.,
German News Company, Inc.,
German News Texas, Inc.,
Gonca Tekiner,
Zeynep Tekiner,
for Commercial Division
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 823 RECEIVED NYSCEF: 10/25/2022
EXHIBIT 8
FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 823 RECEIVED NYSCEF: 10/25/2022
Meghan E. Hill
Direct Tel: 212-326-0808
Direct Fax: 212-326-0806
MHill@PRYORCASHMAN.com
October 20, 2022
VIA EMAIL
Scott W. Parker, Esq.
Parker Ibrahim & Berg LLP
5 Penn Plaza, Suite 2371
New York, New York 10001
Re: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020
Dear Scott:
We write in response to your letter of today concerning a subset of documents in
Defendants’ production labeled “Technical Issue.” Your misleading letter is a further example of
Plaintiff’s groundless, eleventh hour effort to justify an extension of the fact discovery
deadline. Of the 4,360 documents you reference, only 193 of those documents have been produced
since Pryor Cashman LLP appeared as counsel in July 2022. The remaining documents – 96% of
the total – were produced and have been in your possession for many months without objection.
While we will ask our vendor to investigate whether there is any issue – to be clear, the
documents on our end appear exactly as they appear to you – any claim that this represents a
violation of Defendants’ discovery obligations or necessitates an extension of the discovery
schedule is not only absurd, but has long since been waived.
Very truly yours,
Meghan E. Hill
cc: Counsel of Record (via email)
Document Filed Date
October 25, 2022
Case Filing Date
December 21, 2020
Category
Commercial Division
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FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 823 RECEIVED NYSCEF: 10/25/2022 EXHIBIT 8 FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 823 RECEIVED NYSCEF: 10/25/2022 Meghan E. Hill Direct Tel: 212-326-0808 Direct Fax: 212-326-0806 MHill@PRYORCASHMAN.com October 20, 2022 VIA EMAIL Scott W. Parker, Esq. Parker Ibrahim & Berg LLP 5 Penn Plaza, Suite 2371 New York, New York 10001 Re: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020 Dear Scott: We write in response to your letter of today concerning a subset of documents in Defendants’ production labeled “Technical Issue.” Your misleading letter is a further example of Plaintiff’s groundless, eleventh hour effort to justify an extension of the fact discovery deadline. Of the 4,360 documents you reference, only 193 of those documents have been produced since Pryor Cashman LLP appeared as counsel in July 2022. The remaining documents – 96% of the total – were produced and have been in your possession for many months without objection. While we will ask our vendor to investigate whether there is any issue – to be clear, the documents on our end appear exactly as they appear to you – any claim that this represents a violation of Defendants’ discovery obligations or necessitates an extension of the discovery schedule is not only absurd, but has long since been waived. Very truly yours, Meghan E. Hill cc: Counsel of Record (via email)