Preview
FILED: NEW YORK COUNTY CLERK 12/27/2022 03:59 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 985 RECEIVED NYSCEF: 12/27/2022
EXHIBIT D
FILED: NEW YORK COUNTY CLERK 12/27/2022 03:59 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 985 RECEIVED NYSCEF: 12/27/2022
From: Scott Parker
Sent: Thursday, November 3, 2022 6:13 PM
To: Paul Schwartzman
Cc: 'Hill, Meghan E.'; Younger, Stephen P.; 'mk'; Sanjay Ibrahim
Subject: RE: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P.
Schwartzman [PIB-LEGAL_DMS.FID449713]
Mr. Schwartzman, we have not heard back from you. Kindly let us know when you are available this month for your
deposition. Best, Scott
From: Scott Parker
Sent: Friday, October 14, 2022 3:35 PM
To: Paul Schwartzman
Cc: 'Hill, Meghan E.' ; 'Younger, Stephen P.' ; 'mk'
; Sanjay Ibrahim
Subject: RE: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman [PIB-
LEGAL_DMS.FID449713]
Mr. Schwartzman, we could also do October 24, 25, or 26. Best, Scott
Scott Parker
Office 908.333.6220 | Mobile 973.309.3156
Ext. 101
From: Scott Parker
Sent: Friday, October 14, 2022 2:38 PM
To: Paul Schwartzman
Cc: 'Hill, Meghan E.' ; 'Younger, Stephen P.'
; 'mk' ; Sanjay Ibrahim
Subject: RE: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman
[PIB-LEGAL_DMS.FID449713]
Paul, hope all is well. We need to move your deposition – currently scheduled for October 17 th – until later in
the week (I know you had previously said that the later the better for you). Would you please let us know what
th
works best for you? There is now another deposition scheduled on the 17 . Thank you very much.
Best,
Scott
From: Scott Parker
Sent: Friday, September 23, 2022 10:48 AM
To: Paul Schwartzman
Cc: 'Hill, Meghan E.' ; 'Younger, Stephen P.'
; 'mk' ; Sanjay Ibrahim
1
FILED: NEW YORK COUNTY CLERK 12/27/2022 03:59 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 985 RECEIVED NYSCEF: 12/27/2022
Subject: RE: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman
[PIB-LEGAL_DMS.FID449713]
Paul, thanks very much. We will proceed with your deposition on Monday, October 17 at 9 am. We are glad to
hold the deposition virtually, and we will send you a link in advance of the deposition. Best, Scott
Scott Parker
Office 908.333.6220 | Mobile 973.309.3156
Ext. 101
From: Paul Schwartzman
Sent: Wednesday, September 21, 2022 3:43 PM
To: Scott Parker
Cc: 'Hill, Meghan E.' ; 'Younger, Stephen P.'
; 'mk' ; Sanjay Ibrahim
Subject: [EXTERNAL] RE: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P.
Schwartzman [PIB-LEGAL_DMS.FID449713]
After October 15th, the later the better for me.
ps
From: Paul Schwartzman [mailto:paulhowar@aol.com]
Sent: Tuesday, September 20, 2022 4:11 PM
To: 'Scott Parker'
Cc: 'Hill, Meghan E.'; 'Younger, Stephen P.'; 'mk'; 'Sanjay Ibrahim'
Subject: RE: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman [PIB-
LEGAL_DMS.FID449713]
I will call you tomorrow.
ps
From: Scott Parker [mailto:Scott.Parker@piblaw.com]
Sent: Monday, September 19, 2022 7:54 PM
To: paulhowar@aol.com
Cc: Hill, Meghan E.; Younger, Stephen P.; mk; Sanjay Ibrahim
Subject: RE: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman [PIB-
LEGAL_DMS.FID449713]
Mr. Schwartzman, pursuant to our conversation on Tuesday, you told me that you would get back to me
regarding dates that you were available for your deposition. You have not done so. Therefore, this is to advise
you that, unless you advise us by 4 pm tomorrow what dates you are available, we will select the date for
you. Please feel free to contact me to discuss. 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
2
FILED: NEW YORK COUNTY CLERK 12/27/2022 03:59 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 985 RECEIVED NYSCEF: 12/27/2022
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: Scott Parker
Sent: Thursday, September 1, 2022 5:26 PM
To: paulhowar@aol.com
Cc: Hill, Meghan E. ; Younger, Stephen P. ;
mk ; Sanjay Ibrahim
Subject: RE: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman
[PIB-LEGAL_DMS.FID449713]
Mr. Schwartzman, I am circling back on our August 18 correspondence. The court order that we sent you that
date denied Defendants’ motion to quash the subpoena served upon you and your company. Again, would you
please confirm when you are available this month for deposition? Further, per our letter, would you please
confirm if you have any responsive corporate documents in your possession that belong to the Defendants, or
any responsive documents in your possession that do not belong to the Defendants?
Best,
Scott
Scott Parker
Office 908.333.6220 | Mobile 973.309.3156
Ext. 101
From: Scott Parker
Sent: Thursday, August 18, 2022 4:50 PM
To: paulhowar@aol.com
Cc: Hill, Meghan E. ; Younger, Stephen P. ;
mk ; Sanjay Ibrahim
Subject: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman [PIB-
LEGAL_DMS.FID449713]
Dear Mr. Schwartzman, please see the attached correspondence, which is also being sent to you via
FedEx. Best, Scott
3
Preview
FILED: NEW YORK COUNTY CLERK 12/27/2022 03:59 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 985 RECEIVED NYSCEF: 12/27/2022 EXHIBIT D FILED: NEW YORK COUNTY CLERK 12/27/2022 03:59 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 985 RECEIVED NYSCEF: 12/27/2022 From: Scott Parker Sent: Thursday, November 3, 2022 6:13 PM To: Paul Schwartzman Cc: 'Hill, Meghan E.'; Younger, Stephen P.; 'mk'; Sanjay Ibrahim Subject: RE: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman [PIB-LEGAL_DMS.FID449713] Mr. Schwartzman, we have not heard back from you. Kindly let us know when you are available this month for your deposition. Best, Scott From: Scott Parker Sent: Friday, October 14, 2022 3:35 PM To: Paul Schwartzman Cc: 'Hill, Meghan E.' ; 'Younger, Stephen P.' ; 'mk' ; Sanjay Ibrahim Subject: RE: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman [PIB- LEGAL_DMS.FID449713] Mr. Schwartzman, we could also do October 24, 25, or 26. Best, Scott Scott Parker Office 908.333.6220 | Mobile 973.309.3156 Ext. 101 From: Scott Parker Sent: Friday, October 14, 2022 2:38 PM To: Paul Schwartzman Cc: 'Hill, Meghan E.' ; 'Younger, Stephen P.' ; 'mk' ; Sanjay Ibrahim Subject: RE: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman [PIB-LEGAL_DMS.FID449713] Paul, hope all is well. We need to move your deposition – currently scheduled for October 17 th – until later in the week (I know you had previously said that the later the better for you). Would you please let us know what th works best for you? There is now another deposition scheduled on the 17 . Thank you very much. Best, Scott From: Scott Parker Sent: Friday, September 23, 2022 10:48 AM To: Paul Schwartzman Cc: 'Hill, Meghan E.' ; 'Younger, Stephen P.' ; 'mk' ; Sanjay Ibrahim 1 FILED: NEW YORK COUNTY CLERK 12/27/2022 03:59 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 985 RECEIVED NYSCEF: 12/27/2022 Subject: RE: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman [PIB-LEGAL_DMS.FID449713] Paul, thanks very much. We will proceed with your deposition on Monday, October 17 at 9 am. We are glad to hold the deposition virtually, and we will send you a link in advance of the deposition. Best, Scott Scott Parker Office 908.333.6220 | Mobile 973.309.3156 Ext. 101 From: Paul Schwartzman Sent: Wednesday, September 21, 2022 3:43 PM To: Scott Parker Cc: 'Hill, Meghan E.' ; 'Younger, Stephen P.' ; 'mk' ; Sanjay Ibrahim Subject: [EXTERNAL] RE: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman [PIB-LEGAL_DMS.FID449713] After October 15th, the later the better for me. ps From: Paul Schwartzman [mailto:paulhowar@aol.com] Sent: Tuesday, September 20, 2022 4:11 PM To: 'Scott Parker' Cc: 'Hill, Meghan E.'; 'Younger, Stephen P.'; 'mk'; 'Sanjay Ibrahim' Subject: RE: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman [PIB- LEGAL_DMS.FID449713] I will call you tomorrow. ps From: Scott Parker [mailto:Scott.Parker@piblaw.com] Sent: Monday, September 19, 2022 7:54 PM To: paulhowar@aol.com Cc: Hill, Meghan E.; Younger, Stephen P.; mk; Sanjay Ibrahim Subject: RE: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman [PIB- LEGAL_DMS.FID449713] Mr. Schwartzman, pursuant to our conversation on Tuesday, you told me that you would get back to me regarding dates that you were available for your deposition. You have not done so. Therefore, this is to advise you that, unless you advise us by 4 pm tomorrow what dates you are available, we will select the date for you. Please feel free to contact me to discuss. 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 2 FILED: NEW YORK COUNTY CLERK 12/27/2022 03:59 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 985 RECEIVED NYSCEF: 12/27/2022 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: Scott Parker Sent: Thursday, September 1, 2022 5:26 PM To: paulhowar@aol.com Cc: Hill, Meghan E. ; Younger, Stephen P. ; mk ; Sanjay Ibrahim Subject: RE: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman [PIB-LEGAL_DMS.FID449713] Mr. Schwartzman, I am circling back on our August 18 correspondence. The court order that we sent you that date denied Defendants’ motion to quash the subpoena served upon you and your company. Again, would you please confirm when you are available this month for deposition? Further, per our letter, would you please confirm if you have any responsive corporate documents in your possession that belong to the Defendants, or any responsive documents in your possession that do not belong to the Defendants? Best, Scott Scott Parker Office 908.333.6220 | Mobile 973.309.3156 Ext. 101 From: Scott Parker Sent: Thursday, August 18, 2022 4:50 PM To: paulhowar@aol.com Cc: Hill, Meghan E. ; Younger, Stephen P. ; mk ; Sanjay Ibrahim Subject: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman [PIB- LEGAL_DMS.FID449713] Dear Mr. Schwartzman, please see the attached correspondence, which is also being sent to you via FedEx. Best, Scott 3