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        01/31/2023             03:42        AM                 INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   1165                                                                               RECEIVED      NYSCEF:     01/31/2023




                                                    EXHIBIT                                33
   FILED:         NEW     YORK       COUNTY        CLERK        01/31/2023             03:42        AM                 INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   1165                                                                               RECEIVED      NYSCEF:     01/31/2023




                                                                                                                           Bryan T. Mohler
                                                                                                                                      Partner
                                                                                                                        Direct Tel: (212) 326-0466
                                                                                                                     BMohler@pryorcashman.com


                                                                             December 23, 2022

                  VIA EMAIL
                  Scott W. Parker, Esq.
                  Parker Ibrahim & Berg LLP
                  5 Penn Plaza, Suite 2371
                  New York, New York 10001

                           Re:      Tekiner v. Bremen House Inc. et al., Index No. 657193/2020

                  Dear Scott:

                           We   write  in  response   to  your  email,   dated  December      13, 2022,   annexing    a  color-coded
                  copy   of  the  Defendants’      Amended      Privilege   Log   purportedly     identifying   logged    documents
                  “improperly withheld as privileged.”

                           As you know, the Amended Privilege Log was served on Plaintiffs’ on October 18, 2022,
                  and pursuant to a Rule 14 letter sent by Yasemin over a month later, on November 22, 2022, was
                  discussed at a Rule 14 conference held on December 5, 2022.                  Your color-coded log is not only
                  untimely – having been served two months after the Amended Privilege Log was provided, and
                  just two weeks before the end of discovery – but, as explained below, substantively deficient for a
                  number of reasons.

                           Initially, during the December 5 conference, Ms. Klinger directed Yasemin to specifically
                  identify any logged documents on Defendants’ Amended Privilege Log she contends in good faith
                  are  not  privileged.    Rather   than  comply    with   the Court’s   directive,   Yasemin’s     color-coded    log
                  broadly   claims   that  898   of  the  1,069   (84%)    documents     on  the  Amended      Privilege   Log   were
                  improperly     withheld.    Yasemin     fails to  provide   any   meaningful     explanation    for  her  sweeping
                  assertions as directed by Ms. Klinger, resulting in absurdly overbroad claims.

                            For example, hundreds of documents were identified as purportedly not privileged simply
                  because     the   communications        were    “with    Norton     Rose”—Defendants’           former    litigation
                  attorneys—including emails exchanged during the pendency of this action.                      Similarly, Yasemin
                  claims that every communication on which Zeynep was copied is not privileged, making no effort
                  to distinguish between communications sent before her intervention as a plaintiff as opposed to
                  after—a claim the Court long ago rejected in its August 17, 2022 order.

                           In fact, it is apparent Yasemin also failed to review documents in her possession before
                  claiming    improper    redactions.     For   example,    Yasemin     challenges     the  privilege   of  over  200
                  documents     which   were   produced     with  redactions,   the  overwhelming      majority    of which    merely
   FILED:         NEW     YORK       COUNTY        CLERK        01/31/2023             03:42        AM                 INDEX    NO.   657193/2020
   NYSCEF     DOC.   NO.   1165                                                                               RECEIVED      NYSCEF:     01/31/2023




                  Scott W. Parker, Esq.
                  December 23, 2022
                  Page 2

                  contain redactions of personal identifiable information (PII) such as the names and addresses of
                  tenants.   A cursory review of these documents would make clear that the redactions were proper
                  and not controversial.

                           In all, these privilege challenges represent nothing more than Plaintiffs’ continued efforts
                  to harass Defendants in the final hours of discovery, and to manufacture a pretext for post-Note of
                  Issue discovery.     Nevertheless, Defendants have now completed a good faith re-re-review of each
                  of the 898 documents identified on your color-coded log.               While reserving all rights, Defendants
                  are  de-designating     and  producing     264   documents     previously    withheld   as  privileged    as Bates-
                  numbers Brem00406806-Brem00407554.1                 We note that of these documents, 87, or 33%, are exact
                  duplicates (based on identical hash or message ID codes) of documents already within Yasemin’s
                  possession.

                           Although     Defendants     are  designating    a  number    of  the  documents     for  production,    the
                  majority were properly withheld for completely valid bases.                Many of the documents following
                  November 2020 pertain to Yasemin’s litigation demand.                Moreover, Zeynep’s inclusion on emails
                  sent  following    Yasemin’s     commencement        of  the litigation  does   not  constitute   a waiver    of the
                  Company’s privilege.

                                                                             Very truly yours,



                                                                             Bryan T. Mohler




                  cc:    Counsel of Record (via email)




                  1
                   We also note that fifty documents that appeared on the privilege log as withheld were, in fact, previously produced
                  and are identified in the revised privilege log being provided to you.