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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 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1169 RECEIVED NYSCEF: 01/31/2023 EXHIBIT 37 FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1169 RECEIVED NYSCEF: 01/31/2023 Archived: Monday, January 30, 2023 1:30:42 PM From: Weissman, Benjamin Sent: Friday, December 23, 2022 11:26:46 AM To: Scott Parker Paul Schwartzman Cc: Hill, Meghan E. Younger, Stephen P. 'mk' Sanjay Ibrahim Subject: RE: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman [PIB- LEGAL_DMS.FID449713] Importance: Normal Sensitivity: None Dear Mr. Schwartzman: We still have not heard back from you. Please respond by COB today with: (1) all documents responsive to the subpoena, and (2) your availability for a deposition in the first two weeks of January. We reserve all rights, including to move to compel your compliance. Regards, Benjamin Weissman | Associate FOLEY HOAG LLP FOLEY HOAG LLP 1301 Avenue of the Americas New York, New York 10019 +12128120351 phone From: Scott Parker Sent: Thursday, November 3, 2022 6:13 PM To: Paul Schwartzman Cc: 'Hill, Meghan E.' ; Younger, Stephen P. ; 'mk' ; Sanjay Ibrahim Subject: RE: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman [PIB- LEGAL_DMS.FID449713] Mr. Schwartzman, we have not heard back from you. Kindly let us know when you are available this month for your deposition. Best, Scott From: Scott Parker Sent: Friday, October 14, 2022 3:35 PM To: Paul Schwartzman Cc: 'Hill, Meghan E.' ; 'Younger, Stephen P.' ; 'mk' ; Sanjay Ibrahim Subject: RE: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman [PIB- LEGAL_DMS.FID449713] FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1169 RECEIVED NYSCEF: 01/31/2023 Mr. Schwartzman, we could also do October 24, 25, or 26. Best, Scott Scott Parker Office 908.333.6220 | Mobile 973.309.3156 Ext. 101 From: Scott Parker Sent: Friday, October 14, 2022 2:38 PM To: Paul Schwartzman Cc: 'Hill, Meghan E.' ; 'Younger, Stephen P.' ; 'mk' ; Sanjay Ibrahim Subject: RE: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman [PIB- LEGAL_DMS.FID449713] Paul, hope all is well. We need to move your deposition – currently scheduled for October 17th – until later in the week (I know you had previously said that the later the better for you). Would you please let us know what works best for you? There is now another deposition scheduled on the 17 th. Thank you very much. Best, Scott From: Scott Parker Sent: Friday, September 23, 2022 10:48 AM To: Paul Schwartzman Cc: 'Hill, Meghan E.' ; 'Younger, Stephen P.' ; 'mk' ; Sanjay Ibrahim Subject: RE: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman [PIB- LEGAL_DMS.FID449713] Paul, thanks very much. We will proceed with your deposition on Monday, October 17 at 9 am. We are glad to hold the deposition virtually, and we will send you a link in advance of the deposition. Best, Scott Scott Parker Office 908.333.6220 | Mobile 973.309.3156 Ext. 101 From: Paul Schwartzman Sent: Wednesday, September 21, 2022 3:43 PM To: Scott Parker Cc: 'Hill, Meghan E.' ; 'Younger, Stephen P.' ; 'mk' ; Sanjay Ibrahim Subject: [EXTERNAL] RE: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman [PIB-LEGAL_DMS.FID449713] FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1169 RECEIVED NYSCEF: 01/31/2023 After October 15th , the later the better for me. ps From: Paul Schwartzman [mailto:paulhowar@aol.com] Sent: Tuesday, September 20, 2022 4:11 PM To: 'Scott Parker' Cc: 'Hill, Meghan E.'; 'Younger, Stephen P.'; 'mk'; 'Sanjay Ibrahim' Subject: RE: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman [PIB- LEGAL_DMS.FID449713] I will call you tomorrow. ps From: Scott Parker [mailto:Scott.Parker@piblaw.com] Sent: Monday, September 19, 2022 7:54 PM To: paulhowar@aol.com Cc: Hill, Meghan E.; Younger, Stephen P.; mk; Sanjay Ibrahim Subject: RE: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman [PIB- LEGAL_DMS.FID449713] Mr. Schwartzman, pursuant to our conversation on Tuesday, you told me that you would get back to me regarding dates that you were available for your deposition. You have not done so. Therefore, this is to advise you that, unless you advise us by 4 pm tomorrow what dates you are available, we will select the date for you. Please feel free to contact me to discuss. Best, 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 Confidentiality: This email message is for the sole use of the intended recipient(s) and may contain confidential and privileged information. Any unauthorized review, use, disclosure or distribution is strictly prohibited. If you are not the intended recipient, contact the sender via reply email and destroy all copies of the original message. From: Scott Parker Sent: Thursday, September 1, 2022 5:26 PM To: paulhowar@aol.com Cc: Hill, Meghan E. ; Younger, Stephen P. ; mk ; Sanjay Ibrahim Subject: RE: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman [PIB- LEGAL_DMS.FID449713] FILED: NEW YORK COUNTY CLERK 01/31/2023 03:42 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1169 RECEIVED NYSCEF: 01/31/2023 Mr. Schwartzman, I am circling back on our August 18 correspondence. The court order that we sent you that date denied Defendants’ motion to quash the subpoena served upon you and your company. Again, would you please confirm when you are available this month for deposition? Further, per our letter, would you please confirm if you have any responsive corporate documents in your possession that belong to the Defendants, or any responsive documents in your possession that do not belong to the Defendants? Best, Scott Scott Parker Office 908.333.6220 | Mobile 973.309.3156 Ext. 101 From: Scott Parker Sent: Thursday, August 18, 2022 4:50 PM To: paulhowar@aol.com Cc: Hill, Meghan E. ; Younger, Stephen P. ; mk ; Sanjay Ibrahim Subject: Tekiner v Bremen House (Index No. 657193/2020) - 8.18.22 correspondence to P. Schwartzman [PIB- LEGAL_DMS.FID449713] Dear Mr. Schwartzman, please see the attached correspondence, which is also being sent to you via FedEx. Best, Scott 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.