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  • 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)Commercial Division document preview
  • 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)Commercial Division document preview
  • 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)Commercial Division document preview
  • 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)Commercial Division document preview
  • 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)Commercial Division document preview
  • 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)Commercial Division document preview
  • 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)Commercial Division document preview
  • 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)Commercial Division document preview
						
                                

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FILED: NEW YORK COUNTY CLERK 01/31/2023 03:24 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1157 RECEIVED NYSCEF: 01/31/2023 EXHIBIT 25 INDEX NO. 657193/2020 To: FILED: Topping, NEWSean[sean.topping@nortonrosefulbright.com] YORK COUNTY CLERK 01/31/2023 03:24 AM Cc: NYSCEF Corder,NO. DOC. Victoria[victoria.corder@nortonrosefulbright.com]; 1157 Archer, Judith A.[judith.archer@nortonrosefulbright.com]; RECEIVED NYSCEF: Ward, 01/31/2023 Luke[luke.ward@nortonrosefulbright.com]; Evan Mandel[em@mandelbhandari.com]; Younger, Stephen P.[spyounger@foleyhoag.com]; Leah Vickers[lv@mandelbhandari.com] From: Shomik Ghosh[sg@mandelbhandari.com] Sent: Fri 11/12/2021 9:57:53 PM (UTC) Subject: Re: Tekiner v. Bremen House et al. - Accountant/Broker Privilege Thank you Sean. We will review your position on the communications. If we decide to raise these issues with the Court, however, it will be by a separate Rule 14 letter and not through amendment of our existing letter. On Fri, Nov 12, 2021 at 3:47 PM Topping, Sean wrote: Shomik, We believe your emails mischaracterize Defendants’ position. To be clear, Defendants have logged all privileged communications. The Companies’ accountants and/or brokers have been included on otherwise privileged communications because of their positions and/or roles in Company transactions. Their presence on those communications does not waive the privilege. In the limited circumstances where Defendants communicated with accountants and/or brokers concerning legal advice provided by counsel, Defendants have properly logged those communications and explained why they are privileged. Any responsive communications that were not privileged have been produced. As such, Defendants do not agree to produce withheld communications with the third parties named below. We also disagree that a “categorical ruling” is warranted in this case. However, if your intent is to raise this issue with the Court, Defendants would agree to allow Plaintiff to amend her pending Rule 14 letter concerning privilege log issues to add this issue as well. Given the number and breadth of Rule 14 submissions before the Court, we believe it would be more efficient to have all of Plaintiff’s concerns with Defendants’ privilege log raised together. Best, Sean Sean Topping | Associate Pronouns: he / him / his Norton Rose Fulbright US LLP 1301 Avenue of the Americas, New York, New York 10019-6022, United States Tel +1 212 318 3361 | Fax +1 212 318 3400 sean.topping@nortonrosefulbright.com NORTON ROSE FULBRIGHT Law around the world nortonrosefulbright.com From: Shomik Ghosh [mailto:sg@mandelbhandari.com] Sent: Friday, November 12, 2021 9:59 AM To: Topping, Sean ; Corder, Victoria ; Archer, Judith A. ; Ward, Luke Cc: Evan Mandel ; Younger, Stephen P. ; Leah Vickers FILED: INDEX NO. 657193/2020 Subject: Re: NEW TekinerYORK v. Bremen COUNTY House et al.CLERK 01/31/2023 - Accountant/Broker Privilege 03:24 AM NYSCEF DOC. NO. 1157 RECEIVED NYSCEF: 01/31/2023 [External Email – Use Caution] Sean, Following up on this. This is not intended to be a "gotcha" question. During our call, you stated Defendants were planning on asserting that communications involving the parties below were protected attorney-client communications. If that is still your position, please let us know so we can promptly raise this issue with the Court and seek a categorical ruling on the applicability of attorney-client privilege to communications involving third-party brokers and accountants. Thanks, Shomik On Thu, Nov 11, 2021 at 12:38 PM Shomik Ghosh wrote: Sean, During our previous meet & confer, we discussed Defendants’ withholding of a number of communications as privileged within which (a) communications involving counsel for Defendants included third-parties, thus waiving any attorney-client privilege; and (b) where Defendants communicated with third-parties with no counsel present. During our discussion, you stated that Defendants were taking the position that communications with third-party real estate brokers and accountants (including the parties below) were privileged, regardless of whether counsel was included in the communication. Would you please confirm for us that this remains Defendants' position? If not, Plaintiff requests that communications in which the following third-parties are present be immediately produced: Marcus Millichap Corcoran Warburg Realty Paul Schwartzman Steve Levine Beck/Baumann Thank you, Shomik -- FILED: NEW YORK COUNTY CLERK 01/31/2023 03:24 AM INDEX NO. 657193/2020 Shomik Ghosh NYSCEF DOC. NO. 1157 RECEIVED NYSCEF: 01/31/2023 Mandel Bhandari LLP 80 Pine Street, NY, NY 10005 e sg@mandelbhandari.com p 203-285-4398 -- Shomik Ghosh Mandel Bhandari LLP 80 Pine Street, NY, NY 10005 e sg@mandelbhandari.com p 203-285-4398 CONFIDENTIALITY NOTICE: This email, including any attachments, is confidential and may be privileged. If you are not the intended recipient please notify the sender immediately, and please delete it; you should not copy it or use it for any purpose or disclose its contents to any other person. Norton Rose Fulbright entities reserve the right to monitor all email communications through their networks. Norton Rose Fulbright Australia, Norton Rose Fulbright LLP, Norton Rose Fulbright Canada LLP, Norton Rose Fulbright South Africa Inc and Norton Rose Fulbright US LLP are separate legal entities and all of them are members of Norton Rose Fulbright Verein, a Swiss verein. Norton Rose Fulbright Verein helps coordinate the activities of the members but does not itself provide legal services to clients. Details of each entity, with certain regulatory information, are available at nortonrosefulbright.com. -- Shomik Ghosh Mandel Bhandari LLP 80 Pine Street, NY, NY 10005 e sg@mandelbhandari.com p 203-285-4398