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. 1193 RECEIVED NYSCEF: 01/31/2023
EXHIBIT 61
INDEX NO. 657193/2020
To:
FILED: Evan Mandel[em@mandelbhandari.com];
NEW YORK COUNTY CLERKShomik Ghosh[sg@mandelbhandari.com];
01/31/2023 04:02 AM Leah Vickers[lv@mandelbhandari.com]
Cc:
NYSCEF Archer,NO.
DOC. Judith A.[judith.archer@nortonrosefulbright.com]; Topping, Sean[sean.topping@nortonrosefulbright.com]
1193 RECEIVED NYSCEF: 01/31/2023
From: Corder, Victoria[/O=NORTON ROSE/OU=EXTERNAL
(FYDIBOHF25SPDLT)/CN=RECIPIENTS/CN=6D2E4869386042CBAA01874C0B60EA90]
Sent: Mon 11/29/2021 11:23:26 PM (UTC)
Subject: Tekiner v. Bremen House
Evan,
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
NORTON ROSE FULBRIGHT
Law around the world
nortonrosefulbright.com
Document Filed Date
January 31, 2023
Case Filing Date
December 21, 2020
Category
Commercial Division
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Preview
FILED: NEW YORK COUNTY CLERK 01/31/2023 04:02 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1193 RECEIVED NYSCEF: 01/31/2023 EXHIBIT 61 INDEX NO. 657193/2020 To: FILED: Evan Mandel[em@mandelbhandari.com]; NEW YORK COUNTY CLERKShomik Ghosh[sg@mandelbhandari.com]; 01/31/2023 04:02 AM Leah Vickers[lv@mandelbhandari.com] Cc: NYSCEF Archer,NO. DOC. Judith A.[judith.archer@nortonrosefulbright.com]; Topping, Sean[sean.topping@nortonrosefulbright.com] 1193 RECEIVED NYSCEF: 01/31/2023 From: Corder, Victoria[/O=NORTON ROSE/OU=EXTERNAL (FYDIBOHF25SPDLT)/CN=RECIPIENTS/CN=6D2E4869386042CBAA01874C0B60EA90] Sent: Mon 11/29/2021 11:23:26 PM (UTC) Subject: Tekiner v. Bremen House Evan, 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 NORTON ROSE FULBRIGHT Law around the world nortonrosefulbright.com