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 12/27/2022 03:59 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 993 RECEIVED NYSCEF: 12/27/2022
EXHIBIT L
FILED: NEW YORK COUNTY CLERK 12/27/2022 03:59 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 993 RECEIVED NYSCEF: 12/27/2022
From: Hill, Meghan E.
Sent: Friday, October 7, 2022 4:49 PM
To: Scott Parker; Younger, Stephen P.
Cc: Michele Kahn; Sanjay Ibrahim; Soloway, Todd E.; Mohler, Bryan T.; Shaw, Rachel E.
Subject: [EXTERNAL] RE: Deposition Schedule for Tekiner v. Bremen House Inc. [PIB-
LEGAL_DMS.FID449713]
Scott –
Defendants do not see any basis for an extension of the fact discovery end date. We will oppose any such application.
Gonca will appear for her deposition in New York on Tuesday, October 12, 2022 at 10:00 am. Berrin will appear for her
deposition in New York on Friday, October 14, 2022 at 10:00 am. We received login information for Gonca’s remote
deposition; please also forward information for Berrin’s remote deposition.
As previously noticed, Defendants will take Yasemin’s deposition in person on Tuesday October 11, 2022 at 10:00
am. To accommodate Michelle’s request, Defendants will take Zeynep’s deposition in person on Friday October 14,
2022 at 10:00 am.
As we noted in our letter dated September 27, 2022, it is our understanding that neither Mr. Michaels nor Mr. Beck has
been served. If that is the case, then we will accept service, effective today, of the subpoenas on both of them, provided
that each of Messrs. Beck and Michaels have until October 27, 2022 to respond to the respective subpoenas – although
we will not require that they be deposed on that date. We will also represent them at their depositions. As you were
previously informed, all responsive documents from Messrs. Beck and Michaels have previously been produced in
connection with Defendants’ productions. As we previously requested in our September 27 letter, we again ask that you
confirm that you intend to proceed with Mr. Beck’s and Mr. Michaels’s depositions at 9:00 am on Monday, October 17,
so that we may inquire to confirm their availabilities on that date and time.
Please also confirm that Mr. Schwartzman will be deposed at 9:00 am on Monday, October 17. Your October 4, 2022
email also mentions the depositions of John Stewart, Jessica Mojica, and Gurer Aykal. When will you be deposing those
individuals? We again remind you that Mr. Aykal will be out of the country beginning on October 15, 2022.
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
1
Document Filed Date
December 27, 2022
Case Filing Date
December 21, 2020
Category
Commercial Division
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