Preview
FILED: NEW YORK COUNTY CLERK 01/04/2023 10:00 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1010 RECEIVED NYSCEF: 01/04/2023
EXHIBIT A
FILED: NEW YORK COUNTY CLERK 01/04/2023 10:00 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1010 RECEIVED NYSCEF: 01/04/2023
Weissman, Benjamin
From: Soloway, Todd E.
Sent: Monday, December 26, 2022 2:03 PM
To: Younger, Stephen P.; Weissman, Benjamin
Cc: McDonough, Joanna; Michele Kahn; Scott Parker; Downs, Paul; Shaw, Rachel E.; Hill,
Meghan E.; Mohler, Bryan T.; Allis, Hayley; Quinn, Charles; Tilton, Clare P.
Subject: RE: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020
**EXTERNAL**
Gonca has contracted Covid and is sick. She will not be able to attend her deposition
tomorrow. Later this week we will give you new dates for her 3 hour deposition. Berrin will
start at noon tomorrow. Please send to us the zoom information.
Todd E. Soloway, Esq.
Pryor Cashman LLP
7 Times Square, 40th floor
New York, New York 10036
212-421-4100 (Main)
212-326-0252 (Direct)
646-552-1478 (cell)
tsoloway@pryorcashman.com
www.pryorcashman.com
From: Younger, Stephen P.
Sent: Monday, December 26, 2022 11:44 AM
To: Weissman, Benjamin
Cc: Soloway, Todd E. ; McDonough, Joanna ;
Michele Kahn ; Scott Parker ; Downs, Paul
; Shaw, Rachel E. ; Hill, Meghan E.
; Mohler, Bryan T. ; Allis, Hayley
; Quinn, Charles
Subject: Re: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020
And we will plan to take a roughly 30 minute break in between the two depos. Plz confirm
Sent from my iPhone
On Dec 26, 2022, at 10:17 AM, Weissman, Benjamin wrote:
Good morning,
1
FILED: NEW YORK COUNTY CLERK 01/04/2023 10:00 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1010 RECEIVED NYSCEF: 01/04/2023
We would like to start the depositions of Gonca and Berrin at 8:30am tomorrow. They will proceed consecutively until
completed. Please let us know who (Berrin or Gonca) will be deposed first. We will ask the court reporter to circulate the
zoom link once you have confirmed.
Best,
Ben
From: Younger, Stephen P.
Sent: Friday, December 23, 2022 12:38 PM
To: Soloway, Todd E.
Cc: McDonough, Joanna ; Michele Kahn ; Scott Parker
; Downs, Paul ; Shaw, Rachel E. ;
Hill, Meghan E. ; Mohler, Bryan T. ; Weissman, Benjamin
; Allis, Hayley ; Quinn, Charles
Subject: Re: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020
Confirmed - due to travel and holiday schedules, we will need to discuss start times. We will do it by video/zoom - I am
taking both so they need to be consecutive. We reserve our rights to call them both back for the still not produced docs
and to complete the time allowed to us as you are trying to impose any arbitrary 3 hour limit that the judge rejected.
Happy holidays.
Sent from my iPhone
On Dec 23, 2022, at 11:58 AM, Soloway, Todd E.
> wrote:
**EXTERNAL**
________________________________
Joanna and Steve – Confirming Berrin and Gonca’s depositions on Tuesday.
Todd E. Soloway, Esq.
Pryor Cashman LLP
7 Times Square, 40th floor
New York, New York 10036
212-421-4100 (Main)
212-326-0252 (Direct)
646-552-1478 (cell)
tsoloway@pryorcashman.com
www.pryorcashman.com
From: Soloway, Todd E.
Sent: Wednesday, December 21, 2022 2:50 PM
To: McDonough, Joanna >; Younger, Stephen P.
>
Cc: Michele Kahn >; Scott Parker
>; Downs, Paul
>; Shaw, Rachel E.
>; Hill, Meghan E.
2
FILED: NEW YORK COUNTY CLERK 01/04/2023 10:00 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1010 RECEIVED NYSCEF: 01/04/2023
>; Mohler, Bryan T.
>; Weissman, Benjamin
>
Subject: RE: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020
Joanna –
Thank you for your response.
Tomorrow is a date that Mr. Younger proposed for the depositions. Ms. Bauman is available tomorrow in person and, if
necessary, by zoom. She has a long planned holiday trip beginning at 7 am on Friday morning and will not be returning
before the 27th of December. Your client has no fewer than six lawyers on this email chain (and Sanjay is not even on
the chain) and is certainly capable of taking the deposition tomorrow. Ms. Bauman will be at our offices tomorrow at
noon prepared and ready to proceed.
Todd E. Soloway, Esq.
Pryor Cashman LLP
7 Times Square, 40th floor
New York, New York 10036
212-421-4100 (Main)
212-326-0252 (Direct)
646-552-1478 (cell)
tsoloway@pryorcashman.com
www.pryorcashman.com
From: McDonough, Joanna >
Sent: Wednesday, December 21, 2022 1:29 PM
To: Soloway, Todd E. >; Younger, Stephen
P. >
Cc: Michele Kahn >; Scott Parker
>; Downs, Paul
>; Shaw, Rachel E.
>; Hill, Meghan E.
>; Mohler, Bryan T.
>; Weissman, Benjamin
>
Subject: RE: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020
Hi Todd,
Steve will be taking Ms. Bauman’s deposition and he is currently out of the country, returning tomorrow evening. Please
propose an alternative date for Ms. Bauman.
We are considering the balance of your email and will respond shortly.
Regards,
Joanna
From: Soloway, Todd E. >
3
FILED: NEW YORK COUNTY CLERK 01/04/2023 10:00 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1010 RECEIVED NYSCEF: 01/04/2023
Sent: Wednesday, December 21, 2022 9:49 AM
To: Younger, Stephen P. >
Cc: Michele Kahn >; Scott Parker
>; McDonough, Joanna
>; Downs, Paul
>; Shaw, Rachel E.
>; Hill, Meghan E.
>; Mohler, Bryan T.
>
Subject: RE: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020
**EXTERNAL**
________________________________
1. Denise Bauman will appear for a deposition tomorrow starting at noon at our offices.
2. Phil Michaels – due to year end obligations and your client’s failure to provide ample time to schedule the deposition,
he is not available on the dates proposed.
3. Gonca and Berrin will appear for depositions Tuesday December 27th at our offices for 3 hours each both starting at
10 am.
4. Billur will not be made available for a second deposition for the reasons stated in our letter from yesterday.
5. We will get back to you regarding your new notice of deposition for Sadan.
Todd E. Soloway, Esq.
Pryor Cashman LLP
7 Times Square, 40th floor
New York, New York 10036
212-421-4100 (Main)
212-326-0252 (Direct)
646-552-1478 (cell)
tsoloway@pryorcashman.com
www.pryorcashman.com
From: Younger, Stephen P. >
Sent: Tuesday, December 20, 2022 5:19 PM
To: Mohler, Bryan T. >
Cc: Michele Kahn >; Scott Parker
>; McDonough, Joanna
>; Downs, Paul
>; Soloway, Todd E.
>; Shaw, Rachel E.
>; Hill, Meghan E.
>
Subject: Re: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020
Bryan, the Court put no time limit on the renewed depositions.
4
FILED: NEW YORK COUNTY CLERK 01/04/2023 10:00 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1010 RECEIVED NYSCEF: 01/04/2023
Billur was deposed before you produced supposedly privileged docs and recently produced WhatsApp messages. We are
clearly entitled to her renewed deposition under the court ruling. Plz advise by 1 pm tomorrow of her availability or we
will add to our motion.
Is Sadan available on the date we noticed her for?
Sent from my iPad
On Dec 20, 2022, at 5:05 PM, Mohler, Bryan T. >
wrote:
**EXTERNAL**
________________________________
Counsel: Please see attached.
Bryan T. Mohler | Pryor Cashman LLP
7 Times Square | New York, New York 10036-6569
Office: (212) 326-0466 | Mobile: (419) 290-8351
bmohler@pryorcashman.com>
________________________________
***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.
<2022-12-20 Ltr to S. Younger.pdf>
Any tax advice included in this document and its attachments was not intended or written to be used, and it cannot be
used, for the purpose of avoiding penalties under the Internal Revenue Code.
This email message and any attachments are confidential and may be privileged. If you are not the intended recipient,
please notify Foley Hoag LLP immediately -- by replying to this message or by sending an email to
postmaster@foleyhoag.com -- and destroy all copies of this message and any
attachments without reading or disclosing their contents. Thank you.
For more information about Foley Hoag LLP, please visit us at www.foleyhoag.com>.
________________________________
***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
5
FILED: NEW YORK COUNTY CLERK 01/04/2023 10:00 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1010 RECEIVED NYSCEF: 01/04/2023
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.
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Preview
FILED: NEW YORK COUNTY CLERK 01/04/2023 10:00 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1010 RECEIVED NYSCEF: 01/04/2023 EXHIBIT A FILED: NEW YORK COUNTY CLERK 01/04/2023 10:00 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1010 RECEIVED NYSCEF: 01/04/2023 Weissman, Benjamin From: Soloway, Todd E. Sent: Monday, December 26, 2022 2:03 PM To: Younger, Stephen P.; Weissman, Benjamin Cc: McDonough, Joanna; Michele Kahn; Scott Parker; Downs, Paul; Shaw, Rachel E.; Hill, Meghan E.; Mohler, Bryan T.; Allis, Hayley; Quinn, Charles; Tilton, Clare P. Subject: RE: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020 **EXTERNAL** Gonca has contracted Covid and is sick. She will not be able to attend her deposition tomorrow. Later this week we will give you new dates for her 3 hour deposition. Berrin will start at noon tomorrow. Please send to us the zoom information. Todd E. Soloway, Esq. Pryor Cashman LLP 7 Times Square, 40th floor New York, New York 10036 212-421-4100 (Main) 212-326-0252 (Direct) 646-552-1478 (cell) tsoloway@pryorcashman.com www.pryorcashman.com From: Younger, Stephen P. Sent: Monday, December 26, 2022 11:44 AM To: Weissman, Benjamin Cc: Soloway, Todd E. ; McDonough, Joanna ; Michele Kahn ; Scott Parker ; Downs, Paul ; Shaw, Rachel E. ; Hill, Meghan E. ; Mohler, Bryan T. ; Allis, Hayley ; Quinn, Charles Subject: Re: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020 And we will plan to take a roughly 30 minute break in between the two depos. Plz confirm Sent from my iPhone On Dec 26, 2022, at 10:17 AM, Weissman, Benjamin wrote: Good morning, 1 FILED: NEW YORK COUNTY CLERK 01/04/2023 10:00 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1010 RECEIVED NYSCEF: 01/04/2023 We would like to start the depositions of Gonca and Berrin at 8:30am tomorrow. They will proceed consecutively until completed. Please let us know who (Berrin or Gonca) will be deposed first. We will ask the court reporter to circulate the zoom link once you have confirmed. Best, Ben From: Younger, Stephen P. Sent: Friday, December 23, 2022 12:38 PM To: Soloway, Todd E. Cc: McDonough, Joanna ; Michele Kahn ; Scott Parker ; Downs, Paul ; Shaw, Rachel E. ; Hill, Meghan E. ; Mohler, Bryan T. ; Weissman, Benjamin ; Allis, Hayley ; Quinn, Charles Subject: Re: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020 Confirmed - due to travel and holiday schedules, we will need to discuss start times. We will do it by video/zoom - I am taking both so they need to be consecutive. We reserve our rights to call them both back for the still not produced docs and to complete the time allowed to us as you are trying to impose any arbitrary 3 hour limit that the judge rejected. Happy holidays. Sent from my iPhone On Dec 23, 2022, at 11:58 AM, Soloway, Todd E. > wrote: **EXTERNAL** ________________________________ Joanna and Steve – Confirming Berrin and Gonca’s depositions on Tuesday. Todd E. Soloway, Esq. Pryor Cashman LLP 7 Times Square, 40th floor New York, New York 10036 212-421-4100 (Main) 212-326-0252 (Direct) 646-552-1478 (cell) tsoloway@pryorcashman.com www.pryorcashman.com From: Soloway, Todd E. Sent: Wednesday, December 21, 2022 2:50 PM To: McDonough, Joanna >; Younger, Stephen P. > Cc: Michele Kahn >; Scott Parker >; Downs, Paul >; Shaw, Rachel E. >; Hill, Meghan E. 2 FILED: NEW YORK COUNTY CLERK 01/04/2023 10:00 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1010 RECEIVED NYSCEF: 01/04/2023 >; Mohler, Bryan T. >; Weissman, Benjamin > Subject: RE: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020 Joanna – Thank you for your response. Tomorrow is a date that Mr. Younger proposed for the depositions. Ms. Bauman is available tomorrow in person and, if necessary, by zoom. She has a long planned holiday trip beginning at 7 am on Friday morning and will not be returning before the 27th of December. Your client has no fewer than six lawyers on this email chain (and Sanjay is not even on the chain) and is certainly capable of taking the deposition tomorrow. Ms. Bauman will be at our offices tomorrow at noon prepared and ready to proceed. Todd E. Soloway, Esq. Pryor Cashman LLP 7 Times Square, 40th floor New York, New York 10036 212-421-4100 (Main) 212-326-0252 (Direct) 646-552-1478 (cell) tsoloway@pryorcashman.com www.pryorcashman.com From: McDonough, Joanna > Sent: Wednesday, December 21, 2022 1:29 PM To: Soloway, Todd E. >; Younger, Stephen P. > Cc: Michele Kahn >; Scott Parker >; Downs, Paul >; Shaw, Rachel E. >; Hill, Meghan E. >; Mohler, Bryan T. >; Weissman, Benjamin > Subject: RE: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020 Hi Todd, Steve will be taking Ms. Bauman’s deposition and he is currently out of the country, returning tomorrow evening. Please propose an alternative date for Ms. Bauman. We are considering the balance of your email and will respond shortly. Regards, Joanna From: Soloway, Todd E. > 3 FILED: NEW YORK COUNTY CLERK 01/04/2023 10:00 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1010 RECEIVED NYSCEF: 01/04/2023 Sent: Wednesday, December 21, 2022 9:49 AM To: Younger, Stephen P. > Cc: Michele Kahn >; Scott Parker >; McDonough, Joanna >; Downs, Paul >; Shaw, Rachel E. >; Hill, Meghan E. >; Mohler, Bryan T. > Subject: RE: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020 **EXTERNAL** ________________________________ 1. Denise Bauman will appear for a deposition tomorrow starting at noon at our offices. 2. Phil Michaels – due to year end obligations and your client’s failure to provide ample time to schedule the deposition, he is not available on the dates proposed. 3. Gonca and Berrin will appear for depositions Tuesday December 27th at our offices for 3 hours each both starting at 10 am. 4. Billur will not be made available for a second deposition for the reasons stated in our letter from yesterday. 5. We will get back to you regarding your new notice of deposition for Sadan. Todd E. Soloway, Esq. Pryor Cashman LLP 7 Times Square, 40th floor New York, New York 10036 212-421-4100 (Main) 212-326-0252 (Direct) 646-552-1478 (cell) tsoloway@pryorcashman.com www.pryorcashman.com From: Younger, Stephen P. > Sent: Tuesday, December 20, 2022 5:19 PM To: Mohler, Bryan T. > Cc: Michele Kahn >; Scott Parker >; McDonough, Joanna >; Downs, Paul >; Soloway, Todd E. >; Shaw, Rachel E. >; Hill, Meghan E. > Subject: Re: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020 Bryan, the Court put no time limit on the renewed depositions. 4 FILED: NEW YORK COUNTY CLERK 01/04/2023 10:00 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1010 RECEIVED NYSCEF: 01/04/2023 Billur was deposed before you produced supposedly privileged docs and recently produced WhatsApp messages. We are clearly entitled to her renewed deposition under the court ruling. Plz advise by 1 pm tomorrow of her availability or we will add to our motion. Is Sadan available on the date we noticed her for? Sent from my iPad On Dec 20, 2022, at 5:05 PM, Mohler, Bryan T. > wrote: **EXTERNAL** ________________________________ Counsel: Please see attached. Bryan T. Mohler | Pryor Cashman LLP 7 Times Square | New York, New York 10036-6569 Office: (212) 326-0466 | Mobile: (419) 290-8351 bmohler@pryorcashman.com> ________________________________ ***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. <2022-12-20 Ltr to S. Younger.pdf> Any tax advice included in this document and its attachments was not intended or written to be used, and it cannot be used, for the purpose of avoiding penalties under the Internal Revenue Code. This email message and any attachments are confidential and may be privileged. If you are not the intended recipient, please notify Foley Hoag LLP immediately -- by replying to this message or by sending an email to postmaster@foleyhoag.com -- and destroy all copies of this message and any attachments without reading or disclosing their contents. Thank you. For more information about Foley Hoag LLP, please visit us at www.foleyhoag.com>. ________________________________ ***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 5 FILED: NEW YORK COUNTY CLERK 01/04/2023 10:00 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1010 RECEIVED NYSCEF: 01/04/2023 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. 6