Preview
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1250 RECEIVED NYSCEF: 02/14/2023
EXHIBIT H
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1250 RECEIVED NYSCEF: 02/14/2023
From: Younger, Stephen P.
Sent: Thursday, October 13, 2022 1:28 PM
To: Marissa Edwards; Fred Hoensch
Cc: McDonough, Joanna
Subject: Fwd: Yasemin Tekiner v. Bremen House, Inc., et al (Our Case 72747) [PIB-
LEGAL_DMS.FID449713] -- ATTORNEY WORK PRODUCT
Sent from my iPhone
Begin forwarded message:
From: Legal Department
Date: October 13, 2022 at 12:55:38 PM EDT
To: Fred Hoensch , Legal Department
Cc: Scott Parker , Sanjay Ibrahim ,
"Younger, Stephen P." , Daniel Schleifstein
Subject: RE: Yasemin Tekiner v. Bremen House, Inc., et al (Our Case 72747) [PIB-
LEGAL_DMS.FID449713] -- ATTORNEY WORK PRODUCT
**EXTERNAL**
Hi Fred
Sorry for the delay. The off-site items came in. They were solely tax returns. As you know, we
have already produced all the tax returns for the relevant years. We compared what was in the
off-site box to the scanned copies we produced, and the only issue was the 2013 tax return we
produced was missing a page. We have scanned in the accurate/complete 2013 return from off-
site storage, and that will be coming over today as part of our production.
In addition, there was actually some documentation we were unable to produce on Friday
(Correspondence and Investments) because these documents required a manual review since
other non-responsive customers/accounts/trusts were commingled. We needed to redact out any
non-responsive information from these documents. The correspondence and investment files will
be produced to you today.
I have run an email search, doing my best to narrow the results, and my initial search resulted in
almost 2000 emails. Unfortunately, as you may be aware, there are other trusts that have
relationships with the Yasemin trust. Therefore, many of the emails may be non-responsive to
the subpoena. I will likely need at least a week to go through these email results and get them
ready for production.
If you have any other questions or concerns, please reach out. Thanks.
1
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1250 RECEIVED NYSCEF: 02/14/2023
Melissa Bennett
Vice President - Legal Department
WSFS Bank Center
500 Delaware Avenue | Wilmington, DE 19801
O: 302-571-6866
From: Fred Hoensch
Sent: Wednesday, October 12, 2022 2:02 PM
To: Legal Department
Cc: Scott Parker ; Sanjay Ibrahim ;
Younger, Stephen P. ; Daniel Schleifstein
Subject: RE: Yasemin Tekiner v. Bremen House, Inc., et al (Our Case 72747) [PIB-
LEGAL_DMS.FID449713] -- ATTORNEY WORK PRODUCT
EXTERNAL EMAIL: Do not click any links or open any attachments unless you trust the
sender and know the content is safe. Please forward any suspicious emails to
phish@wsfsbank.com
Melissa – Can you please provide an update on (i) when the email production will be ready and
(ii) when the documents that were stored offsite will be produced? Thanks in advance.
Fred
Fred Hoensch
1635 Market Street, 11th Floor, Philadelphia PA 19103
+1 267.908.9808
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, October 6, 2022 1:58 PM
To: Younger, Stephen P. ; Legal Department
2
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1250 RECEIVED NYSCEF: 02/14/2023
Cc: Sanjay Ibrahim ; McDonough, Joanna
Subject: RE: Yasemin Tekiner v. Bremen House, Inc., et al (Our Case 72747) [PIB-
LEGAL_DMS.FID449713]
Melissa, following up on your discussion with my colleague this morning, please note that
Definition No. 3 contained in the subpoena you reference below is hereby amended to state:
3. The term “Christiana Trust” shall refer to Wilmington Savings Fund Society, FSB,
WSFS Bank, Christiana Trust Company of Delaware, and the Bryn Mawr Trust
Company of Delaware, together with all of their officers, directors, employees,
independent contractors, agents, partners, corporate parents, subsidiaries, affiliates,
predecessors, successors, attorneys, and any persons acting or purporting to act on
their behalf.
Also attached please find a copy of the stipulated confidentiality order in this case. We
understand that you will be producing most of the actual documents responsive to the subpoena
tomorrow. We also understand that your email search is ongoing, and that you are going to
circle back with an estimated date for their production. With respect to the documents stored
offsite, please include those in the production as well. We understand that you will need to order
them and, as such, they may not be included in your production tomorrow.
Best,
Scott
Scott Parker
Office 908.333.6220 | Mobile 973.309.3156
Ext. 101
From: Younger, Stephen P.
Sent: Thursday, October 6, 2022 10:14 AM
To: Legal Department
Cc: Scott Parker ; Sanjay Ibrahim ;
McDonough, Joanna
Subject: [EXTERNAL] Re: Yasemin Tekiner v. Bremen House, Inc., et al (Our Case 72747)
Our co-counsel will contact you
Sent from my iPhone
On Oct 6, 2022, at 8:58 AM, Legal Department wrote:
**EXTERNAL**
________________________________
Thank you. Can someone from the firm please call me? My understanding is that counsel
emailed Matthew Holt concerning a status. Please reach out to me/the Legal Department. Mr.
Holt is not handling this matter any longer. Thank you.
3
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1250 RECEIVED NYSCEF: 02/14/2023
[image001.jpg]
Melissa Bennett
Vice President - Legal Department
WSFS Bank Center
500 Delaware Avenue | Wilmington, DE 19801
O: 302-571-6866
From: Younger, Stephen P.
Sent: Wednesday, October 5, 2022 1:21 PM
To: Legal Department
Cc: Scott Parker ; Sanjay Ibrahim ;
McDonough, Joanna
Subject: Re: Yasemin Tekiner v. Bremen House, Inc., et al (Our Case 72747)
EXTERNAL EMAIL: Do not click any links or open any attachments unless you trust the sender
and know the content is safe. Please forward any suspicious emails to
phish@wsfsbank.com
Melissa, I am copying my co-counsel Scott Parker who spoke with someone else at the bank
about this earlier and can respond.
Sent from my iPad
On Oct 5, 2022, at 1:10 PM, Legal Department
> wrote:
**EXTERNAL**
________________________________
Mr. Younger:
I left you a voicemail message today, but wanted to follow up in email as well. Wilmington
Savings Fund Society, FSB (“WSFS Bank”) is in receipt of the attached subpoena issued to it on
the above captioned matter. I know either you or someone at your firm spoke previously with
Matthew Holt at WSFS Bank related to an extension to respond through October 7. I have some
additional questions and matters I would like to discuss related to this subpoena (as detailed
below), so feel free to give me a call when you are able to do so.
First, although the subpoena is addressed to the correct entity (WSFS Bank), the Definitions
4
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1250 RECEIVED NYSCEF: 02/14/2023
included in your subpoena define “Christiana Trust” as Christiana Trust Company of Delaware,
The Bryn Mawr Trust Company of Delaware….subsidiaries, affiliates…” The specific requests
then ask for documents held by Christiana Trust. Christiana Trust as you define it here has no
involvement with or documentation responsive to this subpoena. WSFS Bank is the trustee of the
Yasemin Tekiner 2011 Descendants Trust, not Christiana Trust Company of Delaware or The
Bryn Mawr Trust Company of Delaware. Christiana Trust Company of Delaware and The Bryn
Mawr Trust Company of Delaware are subsidiaries of WSFS Financial Corporation (our holding
company). WSFS Bank is NOT a subsidiary or affiliate of Christiana Trust Company of
Delaware or The Bryn Mawr Trust Company of Delaware. In order for us to provide the
requested information, we will need you to provide a revised Definitions page that defines
Christiana Trust as Wilmington Savings Fund Society, FSB or WSFS Bank.
Next, please be advised that financial privacy laws (such as the Graham-Leach-Bliley Act)
prevent financial institutions from disclosing the non-public personal information (NPPI) of
customers without direct consent from those customers. NPPI includes information such as
account numbers, social security numbers, dates of birth, etc. Please confirm if there is a
confidentiality agreement or order in place covering third-party productions for the above
captioned matter. If no confidentiality agreement is provided, WSFS Bank will produce all
responsive documents with partial redactions, so the last few digits/numbers are still visible for
comparison purposes.
In addition, please note that we charge $22/hr. for preparation, review and redaction of
responsive documents. If a production is necessary, we will submit an invoice with the
responsive documents.
Finally, we have begun gathering and preparing the responsive documents for production, but
there are a large amount of records. As long as we receive the revised Definitions page as
detailed above, we will be able to produce records by October 7, but request that we be able to
produce on a rolling basis thereafter. We will not have all the responsive records prepared and
ready to produce on October 7. Please let me know if that is acceptable.
Thank you.
Melissa Bennett
Vice President - Legal Department
WSFS Bank Center
500 Delaware Avenue | Wilmington, DE 19801
O: 302-571-6866
5
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1250 RECEIVED NYSCEF: 02/14/2023
[https://www.wsfsbank.com/images/wsfs.png]
DISCLAIMER: This e-mail and any files transmitted with it may contain confidential and/or
proprietary information. It is intended solely for the use of the individual or entity who is the
intended recipient. Unauthorized use of this information is prohibited. If you have received this
in error, please contact the sender by replying to this message and delete this material from any
system it may be on.
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>.
[https://www.wsfsbank.com/images/wsfs.png]
DISCLAIMER: This e-mail and any files transmitted with it may contain confidential and/or
proprietary information. It is intended solely for the use of the individual or entity who is the
intended recipient. Unauthorized use of this information is prohibited. If you have received this
in error, please contact the sender by replying to this message and delete this material from any
system it may be on.
To help
protect y our
priv acy ,
Micro so ft
Office
prev ented
auto matic
download of
this pictu re
from the
In ternet.
DISCLAIMER: This e-mail and any files transmitted with it may contain confidential and/or proprietary
information. It is intended solely for the use of the individual or entity who is the intended
recipient. Unauthorized use of this information is prohibited. If you have received this in error, please
contact the sender by replying to this message and delete this material from any system it may be on.
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Preview
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1250 RECEIVED NYSCEF: 02/14/2023 EXHIBIT H FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1250 RECEIVED NYSCEF: 02/14/2023 From: Younger, Stephen P. Sent: Thursday, October 13, 2022 1:28 PM To: Marissa Edwards; Fred Hoensch Cc: McDonough, Joanna Subject: Fwd: Yasemin Tekiner v. Bremen House, Inc., et al (Our Case 72747) [PIB- LEGAL_DMS.FID449713] -- ATTORNEY WORK PRODUCT Sent from my iPhone Begin forwarded message: From: Legal Department Date: October 13, 2022 at 12:55:38 PM EDT To: Fred Hoensch , Legal Department Cc: Scott Parker , Sanjay Ibrahim , "Younger, Stephen P." , Daniel Schleifstein Subject: RE: Yasemin Tekiner v. Bremen House, Inc., et al (Our Case 72747) [PIB- LEGAL_DMS.FID449713] -- ATTORNEY WORK PRODUCT **EXTERNAL** Hi Fred Sorry for the delay. The off-site items came in. They were solely tax returns. As you know, we have already produced all the tax returns for the relevant years. We compared what was in the off-site box to the scanned copies we produced, and the only issue was the 2013 tax return we produced was missing a page. We have scanned in the accurate/complete 2013 return from off- site storage, and that will be coming over today as part of our production. In addition, there was actually some documentation we were unable to produce on Friday (Correspondence and Investments) because these documents required a manual review since other non-responsive customers/accounts/trusts were commingled. We needed to redact out any non-responsive information from these documents. The correspondence and investment files will be produced to you today. I have run an email search, doing my best to narrow the results, and my initial search resulted in almost 2000 emails. Unfortunately, as you may be aware, there are other trusts that have relationships with the Yasemin trust. Therefore, many of the emails may be non-responsive to the subpoena. I will likely need at least a week to go through these email results and get them ready for production. If you have any other questions or concerns, please reach out. Thanks. 1 FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1250 RECEIVED NYSCEF: 02/14/2023 Melissa Bennett Vice President - Legal Department WSFS Bank Center 500 Delaware Avenue | Wilmington, DE 19801 O: 302-571-6866 From: Fred Hoensch Sent: Wednesday, October 12, 2022 2:02 PM To: Legal Department Cc: Scott Parker ; Sanjay Ibrahim ; Younger, Stephen P. ; Daniel Schleifstein Subject: RE: Yasemin Tekiner v. Bremen House, Inc., et al (Our Case 72747) [PIB- LEGAL_DMS.FID449713] -- ATTORNEY WORK PRODUCT EXTERNAL EMAIL: Do not click any links or open any attachments unless you trust the sender and know the content is safe. Please forward any suspicious emails to phish@wsfsbank.com Melissa – Can you please provide an update on (i) when the email production will be ready and (ii) when the documents that were stored offsite will be produced? Thanks in advance. Fred Fred Hoensch 1635 Market Street, 11th Floor, Philadelphia PA 19103 +1 267.908.9808 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, October 6, 2022 1:58 PM To: Younger, Stephen P. ; Legal Department 2 FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1250 RECEIVED NYSCEF: 02/14/2023 Cc: Sanjay Ibrahim ; McDonough, Joanna Subject: RE: Yasemin Tekiner v. Bremen House, Inc., et al (Our Case 72747) [PIB- LEGAL_DMS.FID449713] Melissa, following up on your discussion with my colleague this morning, please note that Definition No. 3 contained in the subpoena you reference below is hereby amended to state: 3. The term “Christiana Trust” shall refer to Wilmington Savings Fund Society, FSB, WSFS Bank, Christiana Trust Company of Delaware, and the Bryn Mawr Trust Company of Delaware, together with all of their officers, directors, employees, independent contractors, agents, partners, corporate parents, subsidiaries, affiliates, predecessors, successors, attorneys, and any persons acting or purporting to act on their behalf. Also attached please find a copy of the stipulated confidentiality order in this case. We understand that you will be producing most of the actual documents responsive to the subpoena tomorrow. We also understand that your email search is ongoing, and that you are going to circle back with an estimated date for their production. With respect to the documents stored offsite, please include those in the production as well. We understand that you will need to order them and, as such, they may not be included in your production tomorrow. Best, Scott Scott Parker Office 908.333.6220 | Mobile 973.309.3156 Ext. 101 From: Younger, Stephen P. Sent: Thursday, October 6, 2022 10:14 AM To: Legal Department Cc: Scott Parker ; Sanjay Ibrahim ; McDonough, Joanna Subject: [EXTERNAL] Re: Yasemin Tekiner v. Bremen House, Inc., et al (Our Case 72747) Our co-counsel will contact you Sent from my iPhone On Oct 6, 2022, at 8:58 AM, Legal Department wrote: **EXTERNAL** ________________________________ Thank you. Can someone from the firm please call me? My understanding is that counsel emailed Matthew Holt concerning a status. Please reach out to me/the Legal Department. Mr. Holt is not handling this matter any longer. Thank you. 3 FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1250 RECEIVED NYSCEF: 02/14/2023 [image001.jpg] Melissa Bennett Vice President - Legal Department WSFS Bank Center 500 Delaware Avenue | Wilmington, DE 19801 O: 302-571-6866 From: Younger, Stephen P. Sent: Wednesday, October 5, 2022 1:21 PM To: Legal Department Cc: Scott Parker ; Sanjay Ibrahim ; McDonough, Joanna Subject: Re: Yasemin Tekiner v. Bremen House, Inc., et al (Our Case 72747) EXTERNAL EMAIL: Do not click any links or open any attachments unless you trust the sender and know the content is safe. Please forward any suspicious emails to phish@wsfsbank.com Melissa, I am copying my co-counsel Scott Parker who spoke with someone else at the bank about this earlier and can respond. Sent from my iPad On Oct 5, 2022, at 1:10 PM, Legal Department > wrote: **EXTERNAL** ________________________________ Mr. Younger: I left you a voicemail message today, but wanted to follow up in email as well. Wilmington Savings Fund Society, FSB (“WSFS Bank”) is in receipt of the attached subpoena issued to it on the above captioned matter. I know either you or someone at your firm spoke previously with Matthew Holt at WSFS Bank related to an extension to respond through October 7. I have some additional questions and matters I would like to discuss related to this subpoena (as detailed below), so feel free to give me a call when you are able to do so. First, although the subpoena is addressed to the correct entity (WSFS Bank), the Definitions 4 FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1250 RECEIVED NYSCEF: 02/14/2023 included in your subpoena define “Christiana Trust” as Christiana Trust Company of Delaware, The Bryn Mawr Trust Company of Delaware….subsidiaries, affiliates…” The specific requests then ask for documents held by Christiana Trust. Christiana Trust as you define it here has no involvement with or documentation responsive to this subpoena. WSFS Bank is the trustee of the Yasemin Tekiner 2011 Descendants Trust, not Christiana Trust Company of Delaware or The Bryn Mawr Trust Company of Delaware. Christiana Trust Company of Delaware and The Bryn Mawr Trust Company of Delaware are subsidiaries of WSFS Financial Corporation (our holding company). WSFS Bank is NOT a subsidiary or affiliate of Christiana Trust Company of Delaware or The Bryn Mawr Trust Company of Delaware. In order for us to provide the requested information, we will need you to provide a revised Definitions page that defines Christiana Trust as Wilmington Savings Fund Society, FSB or WSFS Bank. Next, please be advised that financial privacy laws (such as the Graham-Leach-Bliley Act) prevent financial institutions from disclosing the non-public personal information (NPPI) of customers without direct consent from those customers. NPPI includes information such as account numbers, social security numbers, dates of birth, etc. Please confirm if there is a confidentiality agreement or order in place covering third-party productions for the above captioned matter. If no confidentiality agreement is provided, WSFS Bank will produce all responsive documents with partial redactions, so the last few digits/numbers are still visible for comparison purposes. In addition, please note that we charge $22/hr. for preparation, review and redaction of responsive documents. If a production is necessary, we will submit an invoice with the responsive documents. Finally, we have begun gathering and preparing the responsive documents for production, but there are a large amount of records. As long as we receive the revised Definitions page as detailed above, we will be able to produce records by October 7, but request that we be able to produce on a rolling basis thereafter. We will not have all the responsive records prepared and ready to produce on October 7. Please let me know if that is acceptable. Thank you. Melissa Bennett Vice President - Legal Department WSFS Bank Center 500 Delaware Avenue | Wilmington, DE 19801 O: 302-571-6866 5 FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1250 RECEIVED NYSCEF: 02/14/2023 [https://www.wsfsbank.com/images/wsfs.png] DISCLAIMER: This e-mail and any files transmitted with it may contain confidential and/or proprietary information. It is intended solely for the use of the individual or entity who is the intended recipient. Unauthorized use of this information is prohibited. If you have received this in error, please contact the sender by replying to this message and delete this material from any system it may be on. 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>. [https://www.wsfsbank.com/images/wsfs.png] DISCLAIMER: This e-mail and any files transmitted with it may contain confidential and/or proprietary information. It is intended solely for the use of the individual or entity who is the intended recipient. Unauthorized use of this information is prohibited. If you have received this in error, please contact the sender by replying to this message and delete this material from any system it may be on. To help protect y our priv acy , Micro so ft Office prev ented auto matic download of this pictu re from the In ternet. DISCLAIMER: This e-mail and any files transmitted with it may contain confidential and/or proprietary information. It is intended solely for the use of the individual or entity who is the intended recipient. Unauthorized use of this information is prohibited. If you have received this in error, please contact the sender by replying to this message and delete this material from any system it may be on. 6