Party Discovery: 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             07:07        PM                 INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   1074                                                                               RECEIVED      NYSCEF:     01/09/2023




                                                                   EXHIBIT 43
                                       October 3, 2022 Deposition Scheduling Email from
                                                Scott Parker to Counsel for Defendants
   FILED:         NEW     YORK       COUNTY        CLERK        01/09/2023             07:07        PM                 INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   1074                                                                               RECEIVED      NYSCEF:     01/09/2023
    Archived: Monday, January 9, 2023 2:51:07 PM
    From: Scott Parker
    Sent: Monday, October 3, 2022 10:45:19 PM
    To: Hill, Meghan E. Michele Kahn Sanjay Ibrahim Younger, Stephen P.
    Cc: Soloway, Todd E. Mohler, Bryan T. Shaw, Rachel E.
    Subject: RE: Deposition Schedule for Tekiner v. Bremen House Inc. [PIB-LEGAL_DMS.FID449713]
    Importance: Normal
    Sensitivity: None
    Attachments:
    PIBLogo_7dc9850a-64c8-4f36-ab69-3888860b5c21.PNG;




    Meghan,

    Thank you for finally confirming deposition dates for the parties.          With respect to these depositions:

           We agree to your proposal to have Yasemin deposed on October 11, conditioned on Gonca being deposed on October
            12.

           Per Michele’s e-mail to you at 1:33 pm today (and as she has previously advised you), Zeynep will not sit for a second
            deposition session until all individual parties have been deposed for at least one session.              Therefore, Berrin must be
            deposed on October 13, and Zeynep will continue her deposition on either October 14 or 17 (and on October 14,
            Zeynep’s counsel has advised that there must be a hard stop at 5:30 pm). Please confirm right away that you agree to
            these dates, so that we can finally lock them in.

           We reserve the right to call back both Gonca and Berrin for additional questioning after their depositions, to inquire
            about: (1) any additional previously withheld privileged (or other late produced) documents that you may produce
            after today (to date, you have produced less than 16% of the 9,537 documents that defendants previously withheld);
            and (2) any mental health documents that you may produce after today (to date, you have produced none).                      Further,
            as we noted in our September 29th letter to you, we object to your belated and unfounded substitution of Gonca for
            Sadan Gurbuzturk pursuant to CPLR 3106(d), and we reserve the right to compel Sadan’s deposition once Gonca’s
            deposition has been completed, regardless of whether fact discovery has ended.

    We will get back to you under separate cover regarding the multitude of third party depositions for which – based solely upon
    your months-long delay in confirming the party deposition dates, and your cramming the party depositions into the very end
    of the fact discovery period – you have made impossible to schedule by the close of fact discovery on October 17th.

    Regards,
    Scott


    Scott Parker
    NJ Office: 270 Davidson Avenue, Somerset, NJ 08873
    NY Office: 5 Penn Plaza, Suite 2371, New York, NY 10001
    Direct: +1 908.333.6220 | Main: +1 212.596.7037
    www.piblaw.com
   FILED:         NEW     YORK       COUNTY        CLERK        01/09/2023             07:07        PM                 INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   1074                                                                               RECEIVED      NYSCEF:     01/09/2023




    Confi denti a l i ty:
    Thi s ema i l mes s a ge i s for the s ol e us e of the i ntended reci pi ent(s ) a nd ma y conta i n confi denti a l a nd pri vi l eged i nforma ti on. Any
    una uthori zed revi ew, us e, di s cl os ure or di s tri buti on i s s tri ctl y prohi bi ted. If you a re not the i ntended reci pi ent, conta ct the s ender vi a repl y
    ema i l a nd des troy a l l copi es of the ori gi na l mes s a ge.

    From: Hill, Meghan E. 
    Sent: Monday, October 3, 2022 1:20 PM
    To: Scott Parker ; Michele Kahn ; Sanjay Ibrahim
    ; Younger, Stephen P. 
    Cc: Soloway, Todd E. ; Mohler, Bryan T. ; Shaw, Rachel
    E. 
    Subject: [EXTERNAL] Deposition Schedule for Tekiner v. Bremen House Inc.

    All:

    Defendants reserve all rights with respect to Plaintiffs’ delinquent and belated production of documents (or lack thereof).
    Notwithstanding the foregoing, we propose the following schedule for the depositions of the parties:

    Tuesday 10/11: Yasemin
    Wednesday 10/12: Gonca
    Thursday 10/13: Zeynep
    Friday 10/14: Berrin

    Gurer Aykal is traveling beginning on 10/15, so his deposition will have to be held prior to that date. Please also advise as to
    Ms. Rubin’s availability.

    Sincerely,

    Meghan
    _______________________________________
    Meghan E. Hill
    Pryor Cashman LLP
    7 Times Square, New York, NY 10036-6569
    mhill@pryorcashman.com
    Direct Tel:212-326-0808 (also reachable remotely at this number)
    www.pryorcashman.com
    A member of Interlaw, an International Association of Independent Law Firms




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