Exhibit,Appendix: 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 v. Bremen House Inc., German News Company, Inc., Berrin Tekiner, Gonca Tekiner, Billur Akipek in her capacity as a Trustee of the Yasemin Tekiner 2011 Descendants Trust, Zeynep Tekiner (Intervenor Plaintiff)

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                                FILED:         NEW     YORK       COUNTY        CLERK        12/14/2022             06:01        PM                 INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   908                                                                                RECEIVED      NYSCEF:     12/14/2022




                                                     EXHIBIT                                  E
   FILED:         NEW     YORK       COUNTY        CLERK        12/14/2022             06:01        PM                 INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   908                                                                                RECEIVED      NYSCEF:     12/14/2022




                                                                                                                             Meghan E. Hill
                                                                                                                         Direct Tel: 212-326-0808
                                                                                                                        Direct Fax: 212-326-0806
                                                                                                                  MHill@PRYORCASHMAN.com


                                                                             November 1, 2022

                  VIA EMAIL


                  Michele Kahn, Esq.
                  Kahn & Goldberg, LLP
                  555 Fifth Avenue, 14th Floor
                  New York, NY 10017
                  mk@kahngoldberg.com

                           Re:      Tekiner v. Bremen House Inc. et al., Index No. 657193/2020

                  Dear Michele:

                           During the deposition of Zeynep Tekiner (“Zeynep”), we made several requests for the
                  production of documents, which you agreed to “take under advisement.”                    We have not heard
                  back from you regarding these requests.

                           Therefore, we renew our demand for the production of the following documents, based
                  on your client’s deposition testimony:

                          Bank statements in Zeynep’s possession from the time period Zeynep was living in
                           Turkey showing that Berrin was regularly sending money to Zeynep and at some point
                           cut the amount of money she was sending “in half.”              Zeynep was not sure of the amount.
                           She suggested it was between $10,000 and $5,000 per month.                 (Z. Tekiner Tr. 218:2-14.)

                          Documents in Zeynep’s possession showing that Extell at one time made an expression
                           of interest at “either [$]70 or $80 million” for the Extell properties.           (Z. Tekiner Tr.
                           358:10-359:5.)

                          Documents in Zeynep’s possession that would identify the properties she was referring to
                           when she alleged, at ¶ 82 of her First Amended Verified Complaint in Intervention (Dkt.
                           371), that “comparable properties in the nearby neighborhood have recently sold for
                           much higher prices [than the Extell properties did].”           (Z. Tekiner Tr. 359: 7-360:8.)
   FILED:         NEW     YORK       COUNTY        CLERK        12/14/2022             06:01        PM                 INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   908                                                                                RECEIVED      NYSCEF:     12/14/2022




                  Michele Kahn, Esq.
                  November 1, 2022
                  Page 2

                           We demand that Zeynep either produce the documents described above or state in writing
                  that no such documents exist by this Friday, November 4, 2022.

                           We also note that you have provided no response to the letter we sent on October 24,
                  2022 to you and your co-counsel, Scott Parker, specifically regarding the production of text
                  messages that were discussed during Zeynep’s deposition.               We request the courtesy of a response
                  to that letter.  Defendants reserve all rights and remedies, none of which are hereby waived.

                                                                                          Very truly yours,




                                                                                           Meghan E. Hill
                  cc:      All Counsel of Record (via email)