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        01/09/2023             02:46        PM                 INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   1025                                                                               RECEIVED      NYSCEF:     01/09/2023




                                                      KAHN        &    GOLDBERG,             LLP
                                                                ATTORNEYS AT LAW


           MICHELE KAHN                                      555 FIFTH AVENUE                       TELEPHONE:      (212) 687-5066
           mk@kahngoldberg.com                                   14th FLOOR                         FACSIMILE:      (212) 983-8415
                                                           NEW YORK, N.Y. 10017                     WEBSITE:         www.kahngoldberg.com
           ERIC GOLDBERG
           eg@kahngoldberg.com

                                                                        August 10, 2022

                  VIA EMAIL: MHill@PRYORCASHMAN.com
                  Meghan E. Hill, Esq.
                  Pryor Cashman LLP
                  7 Times Square
                  New York, NY 10036-6569

                                    Re: Tekiner v. Bremen House: Index No.657193/2020; Zeynep Tekiner
                                         Phone ESI; Defendant’s Zeynep Tekiner ESI Privilege Log; Time to Reply
                                         to Defendants’ First Requests for Production to Zeynep Tekiner; and
                                         Amendment of Zeynep Tekiner’s First Amended Complaint in Intervention
                  Dear Meghan:

                           Thank you for your letter of earlier today responding to my letter of two weeks ago.

                  ZEYNEP TEKINER PHONE ESI

                           Your responses regarding Zeynep’s phone ESI are troubling.                All of the information on
                  the phone that Norton Rose chose not to produce is Zeynep’s personal information and, as the
                  attorney for her adversaries in this litigation, you have no right to possess or control her phone
                  data.

                           Pursuant to my discussions with Norton Rose, I was in the process of taking over the
                  segregated Zeynep phone ESI from Norton Rose’s Haystack account since it belongs to my
                  client.  If I do not receive your immediate assurance that you will not take over control of the
                  Zeynep ESI other than what has been produced to date, I will have no choice but to make a
                  motion to preclude you from doing so (or to return it if you wrongfully take it before I can make
                  the motion).

                           Your “assurance” that Pryor Cashman will not access the unproduced Zeynep phone ESI
                  until you give me notice that you are going to do so is no assurance at all.              I gave you a draft
                  stipulation that provides for the protection of Zeynep’s personal information.                I am willing to
                  work with you on the terms, but your proposal is unacceptable.               That information does not
                  belong to you or your clients.
   FILED:         NEW     YORK       COUNTY        CLERK        01/09/2023             02:46        PM                 INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   1025                                                                               RECEIVED      NYSCEF:     01/09/2023



                  DEFENDANTS’ PRIVILEGE LOG REGARDING ZEYNEP PHONE ESI

                           With respect to the documents listed on the “BBG_ZTek Log”, in order to avoid motion
                  practice, I asked that you review the log and make it compliant with the Court’s Orders. Rather
                  than doing so, you delay by purporting to require me to state my reasons why I believe none of
                  the documents are privileged.        Those reasons are contained in our papers on motions 10 and 12
                  and in the argument and decisions on said motions.             My reasons notwithstanding, on April 18,
                  2022, the Court set forth a procedure by which            Defendants were to propose a log of items that
                  Defendants claimed were privileged and the Court also set parameters for the log.                   Defendant’s
                  log does not comply with the Court’s direction.           For example, it includes emails regarding the
                               1
                  Extell sale.

                  DEADLINE TO REPLY TO DEFENDANTS’ FIRST REQUEST FOR PRODUCTION

                           I have been in contact with Haystack and have agreed to pay open invoices that should
                  have been paid by Norton Rose and Schoeman Updike. Unless you wrongfully take it first, I will
                  complete my takeover of the Zeynep Phone ESI from the accounts of Norton Rose and
                  Schoeman Updike in the near future.

                  AMENDMENT OF ZEYNEP’S COMPLAINT

                           I told you that the Court had granted Yasemin’s motion to add a twelfth cause of action
                  against the individual defendants for aiding and abetting Berrin’s and Billur’s breaches of
                  fiduciary duty and to make clear that her existing claims seek relief under the faithless servant
                  doctrine.   I asked you to consent to me adding the same cause of action to Zeynep’s
                  complaint.    You have now moved to dismiss Yasemin’s newly added cause of action.                      Requiring
                  me to send you a proposed marked complaint when we both already know that you will not
                  consent to my adding this cause of action seems wasteful and, frankly, in bad faith.

                  TIME TO DISCUSS THESE ISSUES

                           Since we will both be in Court Monday, I suggest that we meet after the argument to
                  discuss these issues.

                           I look forward to meeting you.

                                                                        Sincerely,



                                                                        Michele Kahn, Esq.
                  ltr Hill 8-10-22




                  1
                    I also note that, per the Court’s recent decisions on several sealing motions, Defendants’ time to claim privilege
                  may have expired.