On December 21, 2020 a
Party Discovery
was filed
involving a dispute between
Yasemin Tekiner,
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,
and
254-258 W. 35Th St. Llc,
Berrin Tekiner,
Billur Akipek
In Her Capacity As A Trustee Of The Yasemin Tekiner 2011 Descendants Trust,
Bremen House Inc.,
Bremen House Texas, Inc.,
German News Company, Inc.,
German News Texas, Inc.,
Gonca Tekiner,
Zeynep Tekiner,
for Commercial Division
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 01/09/2023 07:07 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1067 RECEIVED NYSCEF: 01/09/2023
EXHIBIT 36
December 30, 2022 Foley Hoag Production Cover Letter Regarding
Documents Received from Santander
FILED: NEW YORK COUNTY CLERK 01/09/2023 07:07 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1067 RECEIVED NYSCEF: 01/09/2023
Seaport West
155 Seaport Boulevard
Boston, MA 02210-2600
617.832.1000 main
617.832.7000 fax
Joanna McDonough
617-832-3050 direct
jmcdonough@foleyhoag.com
December 30, 2022
Via E-mail
Todd Soloway
Pryor Cashman
7 Times Square
40th Floor
New York, NY 10036
Re: Tekiner v. Bremen House - Third Party Production
Counsel:
Plaintiff Yasemin Tekiner (“Plaintiff”) is producing 32 documents received from
Santander Bank, N.A. (“Santander”) this week in response to Plaintiff’s subpoena dated
August 9, 2022, the Court’s October 25, 2022 order, and letter correspondence from Plaintiff
to Santander dated December 5, 2022.
Santander did not produce documents with Bates numbers or confidentiality
designations, so Plaintiff applied these for ease of use and consistent with Defendants’
confidentiality treatment of third-party documents. This production includes documents
bearing Bates numbers SANTANDER000001 - SANTANDER002455.
Foley Hoag will be producing these documents via our secure file transfer system,
Biscom. The password to access this production is:
Password
842Pagtt
Let us know if you have any trouble accessing these documents.
Sincerely,
Joanna McDonough
ATTORNEYS AT LAW BOSTON | NEW YORK |PARIS | WASHINGTON |FOLEYHOAG.COM
FH11240781.1
FILED: NEW YORK COUNTY CLERK 01/09/2023 07:07 PM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1067 RECEIVED NYSCEF: 01/09/2023
Page 2
cc: Meghan Hill
Rachel Shaw
Bryan Mohler
Clare Tilton
FH11240781.1
Document Filed Date
January 09, 2023
Case Filing Date
December 21, 2020
Category
Commercial Division
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FILED: NEW YORK COUNTY CLERK 01/09/2023 07:07 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1067 RECEIVED NYSCEF: 01/09/2023 EXHIBIT 36 December 30, 2022 Foley Hoag Production Cover Letter Regarding Documents Received from Santander FILED: NEW YORK COUNTY CLERK 01/09/2023 07:07 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1067 RECEIVED NYSCEF: 01/09/2023 Seaport West 155 Seaport Boulevard Boston, MA 02210-2600 617.832.1000 main 617.832.7000 fax Joanna McDonough 617-832-3050 direct jmcdonough@foleyhoag.com December 30, 2022 Via E-mail Todd Soloway Pryor Cashman 7 Times Square 40th Floor New York, NY 10036 Re: Tekiner v. Bremen House - Third Party Production Counsel: Plaintiff Yasemin Tekiner (“Plaintiff”) is producing 32 documents received from Santander Bank, N.A. (“Santander”) this week in response to Plaintiff’s subpoena dated August 9, 2022, the Court’s October 25, 2022 order, and letter correspondence from Plaintiff to Santander dated December 5, 2022. Santander did not produce documents with Bates numbers or confidentiality designations, so Plaintiff applied these for ease of use and consistent with Defendants’ confidentiality treatment of third-party documents. This production includes documents bearing Bates numbers SANTANDER000001 - SANTANDER002455. Foley Hoag will be producing these documents via our secure file transfer system, Biscom. The password to access this production is: Password 842Pagtt Let us know if you have any trouble accessing these documents. Sincerely, Joanna McDonough ATTORNEYS AT LAW BOSTON | NEW YORK |PARIS | WASHINGTON |FOLEYHOAG.COM FH11240781.1 FILED: NEW YORK COUNTY CLERK 01/09/2023 07:07 PM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1067 RECEIVED NYSCEF: 01/09/2023 Page 2 cc: Meghan Hill Rachel Shaw Bryan Mohler Clare Tilton FH11240781.1