Preview
FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 836 RECEIVED NYSCEF: 10/25/2022
EXHIBIT 22
FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 836 RECEIVED NYSCEF: 10/25/2022
From: Archer, Judith A.
Sent: Friday, June 10, 2022 4:29 PM
To: Scott Parker; Topping, Sean; Sanjay Ibrahim; Younger, Stephen P.; Michele Kahn
Cc: Corder, Victoria; Ward, Luke
Subject: [EXTERNAL] RE: Tekiner -- proposed revised discovery schedule [PIB-
LEGAL_DMS.FID449713]
Scott –
Thanks for your response. We can take Yasemin’s deposition on June 27. Gonca is available on July 1. Berrin is available
on July 7 and 8. Given her paralysis, she works in her wheelchair from home and is not able to sit for a 7 hour deposition
in one day. I suggest we break it up into 2 days, and if she is unable to complete in two days we can discuss another
date at that time.
As for Lisa, we subpoenaed her deposition long before Plaintiff asked for Gurer, she is obligated to appear and we have
never agreed to make her deposition contingent on his. That said, we will provide dates for Gurer’s deposition but need
Lisa’s availability.Please propose dates. We will also seek dates for Levine from his counsel.
We will see what the Court does on Schwartzman. As for remaining deponents, we find it hard to believe that you still
have not identified others that you are certain to depose. We reserve all of our rights in that regard.
Have a good weekend.
Best, Judi
From: Scott Parker
Sent: Tuesday, June 7, 2022 6:00 PM
To: Archer, Judith A. ; Topping, Sean
; Sanjay Ibrahim ; Younger, Stephen P.
; Michele Kahn
Cc: Corder, Victoria ; Ward, Luke
Subject: RE: Tekiner ‐‐ proposed revised discovery schedule [PIB‐LEGAL_DMS.FID449713]
Judi, thank you for your e‐mail. We propose the following dates for depositions:
Jasmin: June 27
Gonca: June 28
Berrin: July 6
You also indicate that you are seeking the deposition of non‐party Lisa Rubin. We propose that this deposition take
place during the week of July 11. As you have been previously advised, however, our agreeing to make Ms. Rubin
available for deposition is contingent upon your agreement to make Gurer Akyal available for deposition as well.
As you know, we are also seeking the deposition of Paul Schwartzman. If the court denies your June 6 motion, we will
take steps to schedule his deposition after that decision.
1
FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 836 RECEIVED NYSCEF: 10/25/2022
Finally, we need deposition dates for Steve Levine, as we would like to take his deposition as well.
We will circle back with you regarding any additional potential deponents. That being said, Donald Conklin previously
sent you such a list on February 25 – and explained that, as we take depositions, we will understand better which
deponents are important and which are less important, and may change the number of intended depositions. Thus, we
cannot provide you with a comprehensive list at this time, nor are we obligated to do so.
Best,
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
Confidentiality:
This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized
review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, contact the sender via reply email and destroy all
copies of the original message.
From: Archer, Judith A.
Sent: Tuesday, May 31, 2022 4:58 PM
To: Scott Parker ; Topping, Sean ; Sanjay Ibrahim
; Younger, Stephen P. ; Michele Kahn
Cc: Corder, Victoria ; Ward, Luke
Subject: [EXTERNAL] RE: Tekiner ‐‐ proposed revised discovery schedule [PIB‐LEGAL_DMS.FID449713]
Scott – We will begin to get dates from our clients, and ask you to do the same for Yasemin and Lisa. We propose a
discussion in which we set deposition dates for all. Given past difficulties and delays in getting dates for Yasemin and
Lisa, we will not provide dates for Berrin and Gonca without also pinning down Yasemin and Lisa’s. Also, please let us
know what other witnesses you intend to depose so that we can create a schedule of depositions that works for
everyone. We will review the email just received from Michele which appears to deal with discovery issues and Zeynep’s
deposition and will respond to that separately. Best, Judi
From: Scott Parker
Sent: Friday, May 27, 2022 5:18 PM
To: Topping, Sean ; Sanjay Ibrahim ; Younger,
Stephen P. ; Michele Kahn
Cc: Archer, Judith A. ; Corder, Victoria
; Ward, Luke
Subject: RE: Tekiner ‐‐ proposed revised discovery schedule [PIB‐LEGAL_DMS.FID449713]
2
FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 836 RECEIVED NYSCEF: 10/25/2022
Judi, we are following up on our April 25, 2022 telephone conference regarding depositions. During that call,
we had suggested starting party depositions in late May. You responded that you believed early June would be
more appropriate. To that end, kindly let us know Berrin’s and Gonca’s availability for depositions in early to
mid-June. Best, 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
Confidentiality:
This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized
review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, contact the sender via reply email and destroy all
copies of the original message.
From: Topping, Sean
Sent: Monday, April 25, 2022 7:05 PM
To: Scott Parker ; Sanjay Ibrahim ; Younger, Stephen P.
; Michele Kahn
Cc: Archer, Judith A. ; Corder, Victoria
; Ward, Luke
Subject: [EXTERNAL] Re: Tekiner ‐‐ proposed revised discovery schedule [PIB‐LEGAL_DMS.FID449713]
Scott,
We had two questions following on our earlier conversation re Tekiner discovery issues.
In order to set a reasonable briefing schedule for the discovery motions, can you confirm what topics raised in Plaintiff’s
Rule 14 letters you intend on briefing? Based upon our earlier conversations and email exchange, we assumed it was
going to be limited to issues raised in Plaintiff’s November 11, 2021 letter (not Plaintiff’s July 30, 2021 or February 18,
2022 letters).
As for Schwartzman’s deposition, in a final effort to avoid motion practice, can you identify the topics you will question
him on at his deposition? In our discussions and email exchanges with Plaintiff’s former counsel, we repeatedly asked
Plaintiff to identify the relevant topics for Schwartzman, but were never given straightforward answers. As you know, it
is our understanding he does not possess any relevant firsthand knowledge pertinent to this litigation.
Best,
Sean
From: Scott Parker
Sent: Monday, April 25, 2022 12:37 PM
To: Archer, Judith A. ; Corder, Victoria
; Michele Kahn
3
FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 836 RECEIVED NYSCEF: 10/25/2022
Cc: Sanjay Ibrahim ; Younger, Stephen P.
Subject: Tekiner ‐‐ proposed revised discovery schedule [PIB‐LEGAL_DMS.FID449713]
[External Email – Use Caution]
Judi, Victoria, and Michele, per the court’s April 18 order, attached is a proposed revised discovery schedule for
submission to the court. Would you please let us know if you have any comments? Best, 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
Confidentiality:
This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized
review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, contact the sender via reply email and destroy all
copies of the original message.
Sean Topping | Senior Associate
Norton Rose Fulbright US LLP
1301 Avenue of the Americas, New York, New York 10019-6022, United States
Tel +1 212 318 3361 | Fax +1 212 318 3400
sean.topping@nortonrosefulbright.com
NORTON ROSE FULBRIGHT
Law around the world
nortonrosefulbright.com
CONFIDENTIALITY NOTICE: This email, including any attachments, is confidential and may be privileged. If you are not
the intended recipient please notify the sender immediately, and please delete it; you should not copy it or use it for any
purpose or disclose its contents to any other person. Norton Rose Fulbright entities reserve the right to monitor all email
communications through their networks.
Norton Rose Fulbright Australia, Norton Rose Fulbright LLP, Norton Rose Fulbright Canada LLP, Norton Rose Fulbright
South Africa Inc and Norton Rose Fulbright US LLP are separate legal entities and all of them are members of Norton
Rose Fulbright Verein, a Swiss verein. Norton Rose Fulbright Verein helps coordinate the activities of the members but
does not itself provide legal services to clients. Details of each entity, with certain regulatory information, are available at
nortonrosefulbright.com.
4
FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 836 RECEIVED NYSCEF: 10/25/2022
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.
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.
1
FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 836 RECEIVED NYSCEF: 10/25/2022
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
_______________________________________
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: Wednesday, September 7, 2022 11:11 AM
To: Hill, Meghan E.
Cc: Sanjay Ibrahim ; Mohler, Bryan T. ; Younger,
Stephen P. ; Michele Kahn ; Soloway, Todd E.
Subject: RE: Tekiner v. Bremen House Inc. [PIB‐LEGAL_DMS.FID449713]
2
FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 836 RECEIVED NYSCEF: 10/25/2022
Meghan, per your request, here is a list of revised questions/topics for the Special Meeting. Would you please confirm if
you are going to arrange for the meeting to occur on September 15 or 16, subject to defendants’ availability? If there
are any questions that you believe have already been fully addressed through document production, please identify the
Bates ranges for those documents. Or, if there are any questions that your clients can answer in advance of the meeting
to streamline the issues, please provide those answers under separate cover. Thanks, Scott
Questions/Topics:
We would like to discuss the profit and loss of the company in 2021 (see Brem00357456‐488), including: (1) the
distribution of the net income of $19,263,177.30 (see Brem00357457); and (2) the exact breakdown of the gross
payroll (85120) of $1,272,356.68 from the 2021 Profit and Loss for Bremen House Inc. (see Brem00357457,
Brem00357487, Brem00357497).
What is the profit and loss of the company so far in 2022? What is the market outlook for the company?
o What were the company’s financial projections for 2021, and were they met? How about for 2022 so
far? If not met, why not?
o Are any of the company’s properties not currently profitable? If so, which ones and why not? What is
the main driver of the company’s profitability?
o How much debt is the company currently carrying? Which properties have mortgages, and for how
much?
o Does the company currently have a line of credit? If so, how much and what has been used?
How much cash does the company currently have on hand? How does that compare to the end of 2021, 2020,
and 2019?
What is the status of the company’s tax returns (federal and state) for 2020 and 2021?
Which properties have existing code violations, and for how much?
How were the sale proceeds distributed from 1320 Madison?
Regarding the sale of the Tanglewylde property, your September 5th letter indicated that the sale proceeds
would be used for “ordinary‐course business expenses”, including the “payment of additional property taxes
among other things.” On our call today, you said that the reference to “ordinary‐course business expenses” in
your letter was intended to be used the same way as that term is used on the 2021 Profit & Loss
statement. Please provide more specific information as to exactly which expenses the proceeds are going to be
applied to, and also which property taxes the Company intends to cover with these proceeds.
o Further, please identify the purchaser of the Tanglewylde property.
Other than Tanglewylde, is the company currently considering purchasing or selling any other properties? What
properties were purchased and/or sold in 2021 and 2022?
What is the percentage of vacant units (both residential and commercial) for the company’s properties,
including 35th Street?
Questions regarding 35th Street:
o What was the profit and loss for 35th Street for 2021 and 2022, including to whom are management fees
paid, how much and for what services?
o What is the status of the listing and sales effort for 35th Street? Is there a price? Have any offers been
made?
3
FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 836 RECEIVED NYSCEF: 10/25/2022
o Why does company management want to sell 35th Street?
o What is the Bremen House log‐in for Marcus Millichap?
What is the status of the company’s bookkeeper?
What accounting system is the company using post‐Raish?
Since December 2020, please identify which company employees have been hired and/or fired.
o Please also provide a list of current employment agreements in effect for the company and its
employees.
Are all of the company’s corporate filings up to date? Are there any delinquent filings?
o Have the deficiencies identified in Jasmin’s May 23rd letter (including but not limited to the Texas
companies) been cured? If not, why not?
What is the status of the German News entities?
What is the status of the certificate of occupancy for the company’s office?
Is there any other pending or threatened litigation involving any of the companies or its board members or
employees?
o Is the lawsuit regarding the office units takeover, involving rent stabilized tenants, still active?
Why is the company paying for the maintenance on the Marion Lane property, if the company is no longer
paying maintenance on personal homes?
Why does Jasmin’s home have an automobile expense listed in the Profit and Loss?
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
Confidentiality:
This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized
review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, contact the sender via reply email and destroy all
copies of the original message.
From: Hill, Meghan E.
Sent: Monday, September 5, 2022 9:57 PM
To: Scott Parker
Cc: Sanjay Ibrahim ; Mohler, Bryan T. ; Younger,
Stephen P. ; Michele Kahn ; Soloway, Todd E.
4
FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 836 RECEIVED NYSCEF: 10/25/2022
Subject: [EXTERNAL] RE: Tekiner v. Bremen House Inc. [PIB‐LEGAL_DMS.FID449713]
Scott:
See attached letter. We will circulate a dial‐in for the meet and confer tomorrow in a separate email.
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: Saturday, September 3, 2022 5:35 PM
To: Hill, Meghan E.
Cc: Sanjay Ibrahim ; Mohler, Bryan T. ; Younger,
Stephen P. ; Michele Kahn
Subject: RE: Tekiner v. Bremen House Inc. [PIB‐LEGAL_DMS.FID449713]
Meghan, please see attached. We are available to meet and confer on all of these topics, plus the Santander subpoena,
on Tuesday until 2 pm.
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
Confidentiality:
This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized
review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, contact the sender via reply email and destroy all
copies of the original message.
From: Hill, Meghan E.
Sent: Wednesday, August 31, 2022 3:18 PM
To: Scott Parker
Cc: Sanjay Ibrahim ; Mohler, Bryan T. ; Younger,
5
FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 836 RECEIVED NYSCEF: 10/25/2022
Stephen P.
Subject: [EXTERNAL] RE: Tekiner v. Bremen House Inc. [PIB‐LEGAL_DMS.FID449713]
Scott – See attached correspondence in response to your August 24, 2022 email. Defendants’ next production of
documents will be transmitted under separate cover.
Please confirm by no later than 9:00 am tomorrow that the return date of the Santander Bank subpoena will be
extended to September 15, 2022 in order for the parties to meet and confer regarding the scope of the documents
requested.
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 30, 2022 10:26 AM
To: Hill, Meghan E.
Cc: Sanjay Ibrahim ; Mohler, Bryan T. ; Younger,
Stephen P.
Subject: RE: Tekiner v. Bremen House Inc. [PIB‐LEGAL_DMS.FID449713]
Meghan, we would be happy to meet and confer about the scope of the Santander subpoena. But we also must address
the multiple other topics that we have written to you about that you continue to ignore (see attached).
For example – when is the Special Meeting going to be held? Back on July 22 (i.e., five weeks ago), you agreed that it
would be held during the week of August 29, and you expressed a preference for the meeting to be held early that
week, to which we agreed. It is now August 30th, yet you have still not even confirmed the date of the meeting, let alone
scheduled it.
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
Confidentiality:
6
FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 836 RECEIVED NYSCEF: 10/25/2022
This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized
review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, contact the sender via reply email and destroy all
copies of the original message.
From: Hill, Meghan E.
Sent: Monday, August 29, 2022 9:36 PM
To: Scott Parker
Cc: Sanjay Ibrahim ; Mohler, Bryan T.
Subject: [EXTERNAL] Tekiner v. Bremen House Inc.
Scott –
I left you a voicemail earlier this evening. We would like to meet and confer about the scope of the Santander subpoena.
Please give me a call to discuss.
Thanks,
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. 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. 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.
7
FILED: NEW YORK COUNTY CLERK 10/25/2022 03:01 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 836 RECEIVED NYSCEF: 10/25/2022
***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.
8