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             06:46        PM                 INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   1053                                                                               RECEIVED      NYSCEF:     01/09/2023




                                                                   EXHIBIT 22
                                  December 6, 2022 Email Summarizing December 5, 2022
                                                        Meet & Confer Conference
   FILED:         NEW     YORK       COUNTY        CLERK        01/09/2023             06:46        PM                 INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   1053                                                                               RECEIVED      NYSCEF:     01/09/2023
    Archived: Monday, January 9, 2023 12:31:30 PM
    From: Mohler, Bryan T.
    Sent: Tuesday, December 6, 2022 6:31:34 PM
    To: Scott Parker Sanjay Ibrahim mk@kahngoldberg.com Younger, Stephen P.
    Cc: Soloway, Todd E. Hill, Meghan E. Shaw, Rachel E. Tilton, Clare P.
    Subject: Tekiner v. Bremen House, et al.
    Importance: Normal
    Sensitivity: None


    Counsel,

    I am writing to summarize the guidance provided by Ms. Klinger during yesterday’s conference.

        1. Lisa Rubin Documents: Ms. Klinger stated that, to the extent that the reasoning in the Court’s August 17, 2022 Order
           resolving Mot. Seq. No. 23 would apply equally to the 27 attachments at issue had they been explicitly identified in
           Defendants’ motion to compel, those documents should be produced.                  Plaintiff agreed to take that recommendation
           under advisement, and Defendants stated that if they were forced to make an unnecessary motion to compel the
           production of these documents, they would seek the related fees and costs.

        2. Yasemin-Zeynep Texts: Ms. Klinger stated that, before a communication may be shielded from disclosure under the
           common interest rule, the communication must satisfy the requirements of the attorney-client privilege.                    She stated
           that Plaintiff should produce any text messages between Yasemin and Zeynep that are not privileged, and further that,
           to the extent that Plaintiff asserts a privilege over these texts, Plaintiff must produce a privilege log and disclose the
           allegedly applicable common interest agreement.

        3. Mental Health Records: Ms. Klinger stated that Plaintiff has not yet addressed Defendants’ arguments concerning
           medical records outside of any time periods during which Defendants’ competence and ability to run the company are
           alleged to be at issue in the complaint (as well as outside any relevant statute of limitations), and directed Plaintiff to
           advance any such arguments by motion.

        4. Bank Records: Plaintiff stated that it intended to send a letter to Santander Bank seeking additional bank records she
           believes are responsive to the subpoena but have not yet been produced.                Plaintiff’s counsel also stated that they will
           simultaneously “dual-track” that effort by conferring with Defendants concerning any additional, responsive bank
           records Plaintiff believes are outstanding.

        5. Defendants’ Amended Privilege Log: Ms. Klinger directed Plaintiff to specifically identify any logged documents on
           Defendants’ Amended Privilege Log she contends in good faith are not privileged.                Defendants agreed to review any
           such identified documents, and to de-designate and produce any documents that are determined not be privileged.

        6. Allen Beck and Philip Michaels Subpoenas: Defendants’ counsel, as counsel for Allen Beck and Philip Michaels for the
           purposes of responding to the subpoenas, agreed to serve amended responses as discussed.

    Please immediately identify any clarification you believe is appropriate.            Defendants remain available to meet and confer.

    Bryan

    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