On December 21, 2020 a
Exhibit,Appendix
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 01/31/2023 04:02 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1194 RECEIVED NYSCEF: 01/31/2023
EXHIBIT 62
INDEX NO. 657193/2020
To:
FILED: Corder,
NEWVictoria[victoria.corder@nortonrosefulbright.com]
YORK COUNTY CLERK 01/31/2023 04:02 AM
Cc:
NYSCEF ShomikNO.
DOC. Ghosh[sg@mandelbhandari.com];
1194 Leah Vickers[lv@mandelbhandari.com]; Archer, Judith
RECEIVED NYSCEF: 01/31/2023
A.[judith.archer@nortonrosefulbright.com]; Topping, Sean[sean.topping@nortonrosefulbright.com]; Younger, Stephen
P.[spyounger@foleyhoag.com]; McDonough, Joanna[jmcdonough@foleyhoag.com]; Donald Conklin[dc@mandelbhandari.com]
From: Evan Mandel[em@mandelbhandari.com]
Sent: Thur 12/2/2021 10:30:07 PM (UTC)
Subject: Re: Tekiner v. Bremen House
Victoria,
During our call on Tuesday, you inquired as to which other depositions we wanted to proceed with in the next few weeks.
We believe that it makes sense to depose Billur, Zeynep, Gonca, Paul Schwartzman, and, to the extent her health permits a
deposition at this time, Berrin. With respect to Gurer Aykal and Lisa Rubin, we think it makes sense for them to be deposed
around the same time as each other. At this time, we think it makes sense for Plaintiff to hold off on taking other
depositions until there is a resolution of more of the document issues. Of course, we reserve our right to schedule additional
depositions should we decide that it is appropriate to do so. This approach would obviously necessitate extending the
existing discovery deadlines.
Let me know (a) if you have any concerns with this approach, (b) when Defendants would like to schedule the depositions
of Gurer and Lisa, (c) when Defendants would like to take Jasmin's deposition, and (d) what new discovery deadlines make
sense.
Evan
--
Evan Mandel
Mandel Bhandari LLP
80 Pine St., 33rd Floor
New York, NY 10005
Office: (212) 269-5600
Direct: (212) 381-0055
Fax: (646) 964-6667
em@mandelbhandari.com
On Tue, Nov 30, 2021 at 1:11 PM Evan Mandel wrote:
Victoria,
We confirm that we will proceed with the Akipek deposition on December 8. Of course, we reserve our right to
continue the deposition on another day should it be necessary to do so, particularly if Defendants produce documents
after December 8.
Evan
--
Evan Mandel
Mandel Bhandari LLP
80 Pine St., 33rd Floor
New York, NY 10005
Office: (212) 269-5600
Direct: (212) 381-0055
Fax: (646) 964-6667
em@mandelbhandari.com
On Mon, Nov 29, 2021 at 6:23 PM Corder, Victoria wrote:
INDEX NO. 657193/2020
Evan,
FILED: NEW YORK COUNTY CLERK 01/31/2023 04:02 AM
NYSCEF DOC. NO. 1194 RECEIVED NYSCEF: 01/31/2023
I am writing to confirm that Billur Akipek’ deposition will proceed on December 8, despite the fact that Plaintiff has
several discovery disputes pending before the Court and has indicated it may pursue others. Please note that we will not
produce Ms. Akipek more than once, and we will not agree to hold her deposition open until Plaintiff’s discovery
complaints are resolved. If this will be an issue, we suggest that Ms. Akipek’s deposition be scheduled for a later date.
Please let us know.
We also ask you to let us know the other depositions you plan to take as it will affect our scheduling of depositions as
well.
Regards,
Victoria V. Corder | Senior Associate
Norton Rose Fulbright US LLP
1301 Avenue of the Americas, New York, New York 10019-6022, United States
Tel +1 212 408 5457 | Fax +1 212 318 3400
victoria.corder@nortonrosefulbright.com
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