Preview
FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1056 RECEIVED NYSCEF: 01/09/2023
EXHIBIT 25
Deposition Scheduling Email Exchange Between Counsel
Concluding on December 21, 2022
FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1056 RECEIVED NYSCEF: 01/09/2023
Archived: Monday, January 9, 2023 2:15:30 PM
From: Soloway, Todd E.
Sent: Wednesday, December 21, 2022 2:49:31 PM
To: McDonough, Joanna 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
Importance: Normal
Sensitivity: None
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,
FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1056 RECEIVED NYSCEF: 01/09/2023
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.
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
FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1056 RECEIVED NYSCEF: 01/09/2023
฀?Bryan, the Court put no time limit on the renewed depositions.
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***
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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.
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***CONFIDENTIALITY NOTICE***
This email contains confidential information which may also be legally privileged and which is intended only for the use of the
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FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1056 RECEIVED NYSCEF: 01/09/2023 EXHIBIT 25 Deposition Scheduling Email Exchange Between Counsel Concluding on December 21, 2022 FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1056 RECEIVED NYSCEF: 01/09/2023 Archived: Monday, January 9, 2023 2:15:30 PM From: Soloway, Todd E. Sent: Wednesday, December 21, 2022 2:49:31 PM To: McDonough, Joanna 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 Importance: Normal Sensitivity: None 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, FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1056 RECEIVED NYSCEF: 01/09/2023 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. 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 FILED: NEW YORK COUNTY CLERK 01/09/2023 06:46 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1056 RECEIVED NYSCEF: 01/09/2023 ฀?Bryan, the Court put no time limit on the renewed depositions. 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 received this email in error, please notify us immediately by reply email and delete this message from your inbox.