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 12/14/2022 06:01 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 906 RECEIVED NYSCEF: 12/14/2022
EXHIBIT C
FILED: NEW YORK COUNTY CLERK 12/14/2022 06:01 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 906 RECEIVED NYSCEF: 12/14/2022
Tilton, Clare P.
From: Scott Parker
Sent: Sunday, October 16, 2022 10:04 PM
To: Tilton, Clare P.; Sanjay Ibrahim
Cc: Soloway, Todd E.; Hill, Meghan E.; Michele Kahn; spyounger@foleyhoag.com
Subject: RE: Production of Text Messages [PIB-LEGAL_DMS.FID449713]
Clare, the texts are protected by attorney work product. We are not going to produce them to you. 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: Tilton, Clare P.
Sent: Friday, October 14, 2022 11:22 AM
To: Scott Parker ; Sanjay Ibrahim
Cc: Soloway, Todd E. ; Hill, Meghan E. ; Michele
Kahn ; spyounger@foleyhoag.com
Subject: [EXTERNAL] Production of Text Messages
Scott,
At Yasemin’s deposition yesterday, Yasemin testified that she and Zeynep exchanged text messages during the
deposition of Gonca Chelsea on October 12, 2022. We demanded the production of those text messages on the record
during Yasemin’s deposition. We ask that you complete the production no later than Wednesday, October 19.
Best,
Clare
_______________________________________
CLARE P. TILTON
Associate
PRYOR CASHMAN LLP
7 Times Square, New York, NY 10036-6569
ctilton@pryorcashman.com
Direct Tel: 212-326-0898
1
FILED: NEW YORK COUNTY CLERK 12/14/2022 06:01 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 906 RECEIVED NYSCEF: 12/14/2022
Direct Fax: 212-326-0806
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.
2
Document Filed Date
December 14, 2022
Case Filing Date
December 21, 2020
Category
Commercial Division
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FILED: NEW YORK COUNTY CLERK 12/14/2022 06:01 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 906 RECEIVED NYSCEF: 12/14/2022 EXHIBIT C FILED: NEW YORK COUNTY CLERK 12/14/2022 06:01 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 906 RECEIVED NYSCEF: 12/14/2022 Tilton, Clare P. From: Scott Parker Sent: Sunday, October 16, 2022 10:04 PM To: Tilton, Clare P.; Sanjay Ibrahim Cc: Soloway, Todd E.; Hill, Meghan E.; Michele Kahn; spyounger@foleyhoag.com Subject: RE: Production of Text Messages [PIB-LEGAL_DMS.FID449713] Clare, the texts are protected by attorney work product. We are not going to produce them to you. 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: Tilton, Clare P. Sent: Friday, October 14, 2022 11:22 AM To: Scott Parker ; Sanjay Ibrahim Cc: Soloway, Todd E. ; Hill, Meghan E. ; Michele Kahn ; spyounger@foleyhoag.com Subject: [EXTERNAL] Production of Text Messages Scott, At Yasemin’s deposition yesterday, Yasemin testified that she and Zeynep exchanged text messages during the deposition of Gonca Chelsea on October 12, 2022. We demanded the production of those text messages on the record during Yasemin’s deposition. We ask that you complete the production no later than Wednesday, October 19. Best, Clare _______________________________________ CLARE P. TILTON Associate PRYOR CASHMAN LLP 7 Times Square, New York, NY 10036-6569 ctilton@pryorcashman.com Direct Tel: 212-326-0898 1 FILED: NEW YORK COUNTY CLERK 12/14/2022 06:01 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 906 RECEIVED NYSCEF: 12/14/2022 Direct Fax: 212-326-0806 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. 2