Preview
FILED: NEW YORK COUNTY CLERK 01/09/2023 02:46 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1027 RECEIVED NYSCEF: 01/09/2023
From: Michele Kahn mk@kahngoldberg.com
S CE - FollowUp to Meet and ConferRe: Gonca's Journalsand Amended Complaint
To: Mohler,Bryan T. BMohler@PRYORCASHMAN.com, Hill, MeghanE. MHill@PRYORCASHMAN.com
Bryan. In follow up to our call earlier today, I understand that Zeynep believes that
Gonca made journal entries on one or more devices and/or on paper in any given period
of time. In one text exchange that I was able to find quickly, Gonca says that she kept
paper journals and also made journal entries on her Ipod and various phones. (TEKINER
63811-63817).
I'llwait to hear back from you regarding Gonca's journals and whether you will stipulate
to my adding a new cause of action to Zeynep's complaint against Gonca for aiding and
abetting breach of fiduciary duty. You agreed to get back to me by Friday, and before
then ifyou can.
"Thank you, Michele
Michele Kahn, Esq.
Kahn & Goldberg, LLP
14th
555 Fifth Avenue, Floor
New York, NY 10017
Tel. (212) 687-5066
Fax (212) 986-5316
mk@kahngoldberg.com
www.kahngoldberg.com
FILED: NEW YORK COUNTY CLERK 01/09/2023 02:46 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1027 RECEIVED NYSCEF: 01/09/2023
From: Michele Kahn mk@kahngoldberg.com
Subject: RE: Tekinerv. Bremen House Inc. et al.,
Index No. 657193/2020
Date: November 11 PDPP at P·08 PM
To: Mohler,Bryan T. BMohler@PRŽORCASHMAN.com
Bryan. Noon on Monday is good for me. Please call me at my office then.
In addition to discussing Gonca's journals, I also want to discuss whether you will
consent to Zeynep adding a cause of action against Gonca for aiding and abetting a
breach of fiduciary duty. I had asked for your consent when you first came into the case,
but once you moved to dismiss Yasemin's new aiding and abetting cause of action, itwas
obvious that we had to await the Court's decision on that motion. I'll
try to get you the
draft my new cause of action before our call.
Regards, Michele
Michele Kahn, Esq.
Kahn & Goldberg, LLP
14th
555 Fifth Avenue, Floor
New York, NY 10017
Tel. (212) 687-5066
Fax (212) 986-5316
mk@kahngoldberg.com
www.kahngoldberg.com
From: Mohler, Bryan T. [mailto:BMohler@PRYORCASHMAN.com]
Sent: Thursday, November 10, 2022 6:19 PM
To: Michele Kahn
Subject: RE: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020
Michele, how does 12:00pm on Monday work? Thanks.
Bryan T. Mohler | PRYOR oASHMAN LLP
7 Times Square |New York, New York 10036-6569
Office: (212) 326-0466 | Mobile: (419) 290-8351
bmohler@pryorcashman.com
From: Michele Kahn
Sent: Thursday, November 10, 2022 2:49 PM
To: Mohler, Bryan T.
Subject: RE: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020
Bryan. Unfortunately, I am not available at all tomorrow. I am free most of Monday.
Please let me know what works for you.
(Unless you could speak today at around 5 pm).
Michele Kahn, Esq.
Kahn & Goldberg, LLP
14th
555 Fifth Avenue, FlOOr
u- v uv mney
FILED: NEW YORK COUNTY CLERK 01/09/2023 02:46 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1027 RECEIVED NYSCEF: 01/09/2023
11UVV 1U1h, 11 1 1UUK I
Tel. (212) 687-5066
Fax (212) 986-5316
mk@kahngoldberg,c_o_m
www.kahngoldberg.com
From: Mohler, Bryan T. [mailto:BMohler@PRYORCASHMAN.coml
Sent: Thursday, November 10, 2022 2:46 PM
To: Michele Kahn
Cc: Scott Parker ; Sanjay Ibrahim
; Younger, Stephen P. ;
Soloway, Todd E. ; Hill, Meghan E.
; Tilton, Clare P.
Subject: Re: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020
Michele,
for the last minute change - I've been asked to speak to the court on another matter
Sorry
at 3pm. Can we push our call until tomorrow morning? I'm wide open then. Thanks.
Bryan
On Nov 10, 2022, at 10:22, Michele Kahn wrote:
Bryan. How is 3 pm today?
Michele Kahn, Esq.
Kahn & Goldberg, LLP
14th
555 Fifth Avenue, Floor
New York, NY 10017
Tel. (212) 687-5066
Fax (212) 986-5316
mk@kahngoldberg.com
www.kahngoldberg c_gm
From: Mohler, Bryan T. [mailto:BMohler@PRYORCASHMAN.com]
Sent: Thursday, November 10, 2022 9:42 AM
To: Michele Kahn
Cc: Scott Parker ; Sanjay Ibrahim
P.'
; 'Younger, Stephen
; Soloway, Todd E.
; Hill, Meghan E.
; Tilton, Clare P.
Subject: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020
FILED: NEW YORK COUNTY CLERK 01/09/2023 02:46 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1027 RECEIVED NYSCEF: 01/09/2023
Michele, let me know when we can discuss your inquiries regarding the
journals. I am generally available after 1:00pm today.
Bryan T. Mohler | PRYOR oASHMAN LLP
7 Times Square |New York, New York 10036-6569
Office: (212) 326-0466 | Mobile: (419) 290-8351
bmohler(@p_ryorcashman.com
FILED: NEW YORK COUNTY CLERK 01/09/2023 02:46 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1027 RECEIVED NYSCEF: 01/09/2023
From: Michele Kahn mk@kahngoldberg.com
Subject: Tekiner- Zeynep'sProposed Second Amended Complaint
nata- November 11 PDPP at 3 07 PM
To: Mohler,Bryan T. BMohler@PRYORCASHMAN.com
Bryan. Attached is a markup of Zeynep's proposed second amended complaint showing
the changes from Zeynep's current complaint (the first amended). The highlighted text is
meant to show the differences between Yasemin's amended cause of action and
Zeynep's proposed amended cause of action.
Let's discuss Monday.
Thanks, Michele
Michele Kahn, Esq.
Kahn & Goldberg, LLP
14th
555 Fifth Avenue,
New York, NY 10017
Tel. (212) 687-5066
Fax (212) 986-5316
mk@kahngoldberg.com
www.kahngoldberg.com
PD
Proposed
Secon...22.pdf
Preview
FILED: NEW YORK COUNTY CLERK 01/09/2023 02:46 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1027 RECEIVED NYSCEF: 01/09/2023 From: Michele Kahn mk@kahngoldberg.com S CE - FollowUp to Meet and ConferRe: Gonca's Journalsand Amended Complaint To: Mohler,Bryan T. BMohler@PRYORCASHMAN.com, Hill, MeghanE. MHill@PRYORCASHMAN.com Bryan. In follow up to our call earlier today, I understand that Zeynep believes that Gonca made journal entries on one or more devices and/or on paper in any given period of time. In one text exchange that I was able to find quickly, Gonca says that she kept paper journals and also made journal entries on her Ipod and various phones. (TEKINER 63811-63817). I'llwait to hear back from you regarding Gonca's journals and whether you will stipulate to my adding a new cause of action to Zeynep's complaint against Gonca for aiding and abetting breach of fiduciary duty. You agreed to get back to me by Friday, and before then ifyou can. "Thank you, Michele Michele Kahn, Esq. Kahn & Goldberg, LLP 14th 555 Fifth Avenue, Floor New York, NY 10017 Tel. (212) 687-5066 Fax (212) 986-5316 mk@kahngoldberg.com www.kahngoldberg.com FILED: NEW YORK COUNTY CLERK 01/09/2023 02:46 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1027 RECEIVED NYSCEF: 01/09/2023 From: Michele Kahn mk@kahngoldberg.com Subject: RE: Tekinerv. Bremen House Inc. et al., Index No. 657193/2020 Date: November 11 PDPP at P·08 PM To: Mohler,Bryan T. BMohler@PRŽORCASHMAN.com Bryan. Noon on Monday is good for me. Please call me at my office then. In addition to discussing Gonca's journals, I also want to discuss whether you will consent to Zeynep adding a cause of action against Gonca for aiding and abetting a breach of fiduciary duty. I had asked for your consent when you first came into the case, but once you moved to dismiss Yasemin's new aiding and abetting cause of action, itwas obvious that we had to await the Court's decision on that motion. I'll try to get you the draft my new cause of action before our call. Regards, Michele Michele Kahn, Esq. Kahn & Goldberg, LLP 14th 555 Fifth Avenue, Floor New York, NY 10017 Tel. (212) 687-5066 Fax (212) 986-5316 mk@kahngoldberg.com www.kahngoldberg.com From: Mohler, Bryan T. [mailto:BMohler@PRYORCASHMAN.com] Sent: Thursday, November 10, 2022 6:19 PM To: Michele Kahn Subject: RE: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020 Michele, how does 12:00pm on Monday work? Thanks. Bryan T. Mohler | PRYOR oASHMAN LLP 7 Times Square |New York, New York 10036-6569 Office: (212) 326-0466 | Mobile: (419) 290-8351 bmohler@pryorcashman.com From: Michele Kahn Sent: Thursday, November 10, 2022 2:49 PM To: Mohler, Bryan T. Subject: RE: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020 Bryan. Unfortunately, I am not available at all tomorrow. I am free most of Monday. Please let me know what works for you. (Unless you could speak today at around 5 pm). Michele Kahn, Esq. Kahn & Goldberg, LLP 14th 555 Fifth Avenue, FlOOr u- v uv mney FILED: NEW YORK COUNTY CLERK 01/09/2023 02:46 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1027 RECEIVED NYSCEF: 01/09/2023 11UVV 1U1h, 11 1 1UUK I Tel. (212) 687-5066 Fax (212) 986-5316 mk@kahngoldberg,c_o_m www.kahngoldberg.com From: Mohler, Bryan T. [mailto:BMohler@PRYORCASHMAN.coml Sent: Thursday, November 10, 2022 2:46 PM To: Michele Kahn Cc: Scott Parker ; Sanjay Ibrahim ; Younger, Stephen P. ; Soloway, Todd E. ; Hill, Meghan E. ; Tilton, Clare P. Subject: Re: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020 Michele, for the last minute change - I've been asked to speak to the court on another matter Sorry at 3pm. Can we push our call until tomorrow morning? I'm wide open then. Thanks. Bryan On Nov 10, 2022, at 10:22, Michele Kahn wrote: Bryan. How is 3 pm today? Michele Kahn, Esq. Kahn & Goldberg, LLP 14th 555 Fifth Avenue, Floor New York, NY 10017 Tel. (212) 687-5066 Fax (212) 986-5316 mk@kahngoldberg.com www.kahngoldberg c_gm From: Mohler, Bryan T. [mailto:BMohler@PRYORCASHMAN.com] Sent: Thursday, November 10, 2022 9:42 AM To: Michele Kahn Cc: Scott Parker ; Sanjay Ibrahim P.' ; 'Younger, Stephen ; Soloway, Todd E. ; Hill, Meghan E. ; Tilton, Clare P. Subject: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020 FILED: NEW YORK COUNTY CLERK 01/09/2023 02:46 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1027 RECEIVED NYSCEF: 01/09/2023 Michele, let me know when we can discuss your inquiries regarding the journals. I am generally available after 1:00pm today. Bryan T. Mohler | PRYOR oASHMAN LLP 7 Times Square |New York, New York 10036-6569 Office: (212) 326-0466 | Mobile: (419) 290-8351 bmohler(@p_ryorcashman.com FILED: NEW YORK COUNTY CLERK 01/09/2023 02:46 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1027 RECEIVED NYSCEF: 01/09/2023 From: Michele Kahn mk@kahngoldberg.com Subject: Tekiner- Zeynep'sProposed Second Amended Complaint nata- November 11 PDPP at 3 07 PM To: Mohler,Bryan T. BMohler@PRYORCASHMAN.com Bryan. Attached is a markup of Zeynep's proposed second amended complaint showing the changes from Zeynep's current complaint (the first amended). The highlighted text is meant to show the differences between Yasemin's amended cause of action and Zeynep's proposed amended cause of action. Let's discuss Monday. Thanks, Michele Michele Kahn, Esq. Kahn & Goldberg, LLP 14th 555 Fifth Avenue, New York, NY 10017 Tel. (212) 687-5066 Fax (212) 986-5316 mk@kahngoldberg.com www.kahngoldberg.com PD Proposed Secon...22.pdf