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. 833 RECEIVED NYSCEF: 10/25/2022
EXHIBIT 19
FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 833 RECEIVED NYSCEF: 10/25/2022
Writer’s Direct Contact:
908.333.6220 (Tel.)
PARKER IBRAHIM & BERG LLP 212.596.7036 (Fax)
scott.parker@piblaw.com
www.piblaw.com
July 21, 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:
As you know, this firm represents the plaintiff Yasemin Tekiner (“Yasemin”) as co-counsel
in the above-referenced action. Thank you again for your time today, and this week, to discuss
Yasemin’s Order to Show Cause for Contempt (Mot. Seq. #21) (the “Contempt Motion”).
Below is a memorialization of the agreement that we have reached. If there is any aspect
of this agreement that you do not believe is correct, please let us know immediately.
Beginning tomorrow, July 22, 2022, your clients will include Jasmin and Zeynep on all
e-mails that relate to: (1) operations of the Company for any material events, and/or
(2) significant matters regarding property sales.
Your clients will begin to produce or make accessible the Company’s books and
records by no later than August 4, 2022 – and you will make every effort to begin that
production in advance of that date, hopefully as soon as next week if possible.
Your clients will hold the Special Meeting requested in Yasemin’s May 19th and July
1st letters during the week of August 29, 2022. You expressed a preference for the
meeting to be held earlier in that week, which our client has no objection to. Would
you kindly confirm the exact date of the Special Meeting as soon as you’re able? As
we understand it, the meeting will be held virtually.
Our client will submit her written questions to your clients at least two weeks in
advance of the Special Meeting, if not earlier.
Based on these representations, we agreed to request (and, in fact, have requested) that
the Court adjourn tomorrow’s oral argument on the Contempt Motion to August 15,
2022. Assuming that August 15 is the new argument date, Yasemin’s reply brief in
further support of the Contempt Motion would be due no later than August 13, 2022.
New York Office: 5 Penn Plaza, Suite 2371 – New York, New York 10001 – 212.596.7037
New Jersey Office: 270 Davidson Avenue – Somerset, New Jersey 08873 – 908.725.9700
BOSTON – NEW JERSEY – NEW YORK – ORANGE COUNTY – PHILADELPHIA
FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 833 RECEIVED NYSCEF: 10/25/2022
o We will include both of these dates in the joint stipulation we are preparing for
you that memorializes the upcoming schedule for various pending motions.
As we discussed on today’s call, our client is amenable to considering a further
adjournment of the oral argument on the Contempt Motion, depending upon the level of progress
that is achieved in the coming weeks with respect to the agreed-upon items set forth in this letter.
Very truly yours,
/s/ Scott W. Parker
Scott W. Parker
2
Document Filed Date
October 25, 2022
Case Filing Date
December 21, 2020
Category
Commercial Division
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Preview
FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 833 RECEIVED NYSCEF: 10/25/2022 EXHIBIT 19 FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 833 RECEIVED NYSCEF: 10/25/2022 Writer’s Direct Contact: 908.333.6220 (Tel.) PARKER IBRAHIM & BERG LLP 212.596.7036 (Fax) scott.parker@piblaw.com www.piblaw.com July 21, 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: As you know, this firm represents the plaintiff Yasemin Tekiner (“Yasemin”) as co-counsel in the above-referenced action. Thank you again for your time today, and this week, to discuss Yasemin’s Order to Show Cause for Contempt (Mot. Seq. #21) (the “Contempt Motion”). Below is a memorialization of the agreement that we have reached. If there is any aspect of this agreement that you do not believe is correct, please let us know immediately. Beginning tomorrow, July 22, 2022, your clients will include Jasmin and Zeynep on all e-mails that relate to: (1) operations of the Company for any material events, and/or (2) significant matters regarding property sales. Your clients will begin to produce or make accessible the Company’s books and records by no later than August 4, 2022 – and you will make every effort to begin that production in advance of that date, hopefully as soon as next week if possible. Your clients will hold the Special Meeting requested in Yasemin’s May 19th and July 1st letters during the week of August 29, 2022. You expressed a preference for the meeting to be held earlier in that week, which our client has no objection to. Would you kindly confirm the exact date of the Special Meeting as soon as you’re able? As we understand it, the meeting will be held virtually. Our client will submit her written questions to your clients at least two weeks in advance of the Special Meeting, if not earlier. Based on these representations, we agreed to request (and, in fact, have requested) that the Court adjourn tomorrow’s oral argument on the Contempt Motion to August 15, 2022. Assuming that August 15 is the new argument date, Yasemin’s reply brief in further support of the Contempt Motion would be due no later than August 13, 2022. New York Office: 5 Penn Plaza, Suite 2371 – New York, New York 10001 – 212.596.7037 New Jersey Office: 270 Davidson Avenue – Somerset, New Jersey 08873 – 908.725.9700 BOSTON – NEW JERSEY – NEW YORK – ORANGE COUNTY – PHILADELPHIA FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 833 RECEIVED NYSCEF: 10/25/2022 o We will include both of these dates in the joint stipulation we are preparing for you that memorializes the upcoming schedule for various pending motions. As we discussed on today’s call, our client is amenable to considering a further adjournment of the oral argument on the Contempt Motion, depending upon the level of progress that is achieved in the coming weeks with respect to the agreed-upon items set forth in this letter. Very truly yours, /s/ Scott W. Parker Scott W. Parker 2