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 02/14/2023 09:34 AM         INDEX NO. 657193/2020
NYSCEF DOC. NO. 1264                               RECEIVED NYSCEF: 02/14/2023




                       EXHIBIT V
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM                                                     INDEX NO. 657193/2020
NYSCEF DOC. NO. 1264                                                                         RECEIVED NYSCEF: 02/14/2023




    From:                              Mohler, Bryan T. 
    Sent:                              Monday, February 13, 2023 6:21 PM
    To:                                Weissman, Benjamin
    Cc:                                Michele Kahn; Soloway, Todd E.; Hill, Meghan E.; Cato, Shayonna; McDonough, Joanna;
                                       Shaw, Rachel E.; Hart, Christopher
    Subject:                           RE: Tekiner v. Bremen House 657193/2020


    **EXTERNAL**

    Ben,

   Thanks – please send over the Zoom information when you have it. As you know, the Court directed that this follow up
   deposition is to be “narrowly focused on any new documents” produced after Gonca’s October 12, 2022
   deposition. [Dkt. No. 857, Tr. 21:14-18.] Accordingly, the deposition is limited to documents with a Bates stamp of
   Brem00369639 forward. Let me know if you want to discuss.

   Bryan

    Bryan T. Mohler | PRYOR CASHMAN LLP
    7 Times Square | New York, New York 10036-6569
    Office: (212) 326-0466 | Mobile: (419) 290-8351
    bmohler@pryorcashman.com


   From: Weissman, Benjamin 
   Sent: Monday, February 13, 2023 10:23 AM
   To: Mohler, Bryan T. 
   Cc: Michele Kahn ; Soloway, Todd E. ; Hill, Meghan E.
   ; Cato, Shayonna ; McDonough, Joanna
   ; Shaw, Rachel E. ; Hart, Christopher
   
   Subject: RE: Tekiner v. Bremen House 657193/2020

   Bryan,

   We are confirming Gonca’s deposition for Wednesday, Feb. 15 at 10am. We will proceed over zoom. We will send you
   zoom details as soon as we have them.

   Ben

   From: Mohler, Bryan T. 
   Sent: Thursday, February 9, 2023 1:29 PM
   To: Weissman, Benjamin 
   Cc: Michele Kahn ; Soloway, Todd E. ; Hill, Meghan E.
   ; Younger, Stephen P. ; Cato, Shayonna
   ; McDonough, Joanna ; Shaw, Rachel E.
   
   Subject: RE: Tekiner v. Bremen House 657193/2020

    **EXTERNAL**

                                                                1
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM                                                        INDEX NO. 657193/2020
NYSCEF DOC. NO. 1264                                                                           RECEIVED NYSCEF: 02/14/2023


    Ben,

    At the January 12, 2023 hearing, Judge Cohen encouraged the parties to attempt to agree on the completion of certain
    of the discovery Plaintiffs seek in their motions. You never contacted us after the hearing. Now, after Defendants
    proactively offered to agree to the completion of three depositions, you fail to respond for nearly a week only to again
    decline to complete them and accuse Defendants of “gamesmanship.” This is pretextual. Plaintiffs are represented by
    three law firms, and there is no explanation for your failure (once again) to take these depositions. Defendants reserve
    all rights.

    Bryan

    Bryan T. Mohler | PRYOR CASHMAN LLP
    7 Times Square | New York, New York 10036-6569
    Office: (212) 326-0466 | Mobile: (419) 290-8351
    bmohler@pryorcashman.com


    From: Weissman, Benjamin 
    Sent: Wednesday, February 8, 2023 7:55 PM
    To: Shaw, Rachel E. 
    Cc: Michele Kahn ; Mohler, Bryan T. ; Soloway, Todd E.
    ; Hill, Meghan E. ; Younger, Stephen P.
    ; Cato, Shayonna ; McDonough, Joanna
    
    Subject: Re: Tekiner v. Bremen House 657193/2020

    Rachel,

    Tomorrow does not work for us to depose Baumann. We will get back to you regarding Gonca and Stewart.

    We note, however, that we did not receive a response to my January 11, 2023 email requesting dates for Gonca's
    deposition the week of Jan. 16. Now, more than 3 weeks later, we receive an offer of a deposition of a key party witness,
    and two nonparty witnesses, at the moment when our briefing is due on the pending motions and on the eve of the
    hearing with the court. That kind of gamesmanship is unfortunate, and Plaintiffs reserve all rights.

    Ben

    On Feb 3, 2023, at 3:39 PM, Shaw, Rachel E.  wrote:


    **EXTERNAL**
    ________________________________
    Ben,

    While reserving all rights, we will make Denise Baumann available for her deposition on February 9. We will also make
    Gonca Tekiner Chelsea available on any day February 13-15.

    Subject to his availability, we will also agree to the deposition of non-party John Stewart if completed before the hearing
    on February 17.

    Please advise.

    _______________________________________
                                                                 2
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM                                                           INDEX NO. 657193/2020
NYSCEF DOC. NO. 1264                                                                               RECEIVED NYSCEF: 02/14/2023
    Rachel Shaw
    Pryor Cashman LLP
    7 Times Square, New York, NY 10036-6569
    rshaw@pryorcashman.com

    Direct Tel: 212.326.0441
    Direct Fax: 212.798.6947

    www.pryorcashman.com
    A member of Interlaw, an International Association of Independent Law Firms
    [image003.png]




    From: Weissman, Benjamin 
    Sent: Wednesday, January 18, 2023 5:59 PM
    To: Michele Kahn ; Mohler, Bryan T. ; Soloway, Todd E.
    ; Hill, Meghan E. ; Shaw, Rachel E.
    
    Cc: Younger, Stephen P. ; Cato, Shayonna ; McDonough, Joanna
    ; Kelly, Rachel ; Allis, Hayley 
    Subject: RE: Tekiner v. Bremen House 657193/2020 - Briefing Schedule on Pending Motions

    Thanks, all. This is fine with us. We will affix your signatures and file.

    From: Michele Kahn >
    Sent: Wednesday, January 18, 2023 5:45 PM
    To: 'Mohler, Bryan T.' >; Weissman,
    Benjamin >; 'Soloway, Todd E.'
    >; 'Hill, Meghan E.'
    >; 'Shaw, Rachel E.'
    >
    Cc: Younger, Stephen P. >; Cato, Shayonna
    >; McDonough, Joanna
    >; Kelly, Rachel
    >; Allis, Hayley
    >
    Subject: RE: Tekiner v. Bremen House 657193/2020 - Briefing Schedule on Pending Motions

    **EXTERNAL**
    ________________________________
    Bryan. If it is fine with Ben, I actually like having all the opposition and reply dates for all the motions on the same day,
    and I was wondering why we had different dates for Zeynep’s motion to amend.

    Ben, you can affix my signature with Bryan’s change.

    Thanks, Michele


    Michele Kahn, Esq.

                                                                     3
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM                                                     INDEX NO. 657193/2020
NYSCEF DOC. NO. 1264                                                                         RECEIVED NYSCEF: 02/14/2023
    Kahn & Goldberg, LLP
    555 Fifth Avenue, 14th Floor
    New York, NY 10017
    Tel. (212) 687-5066
    Fax (212) 986-5316
    mk@kahngoldberg.com
    www.kahngoldberg.com

    From: Mohler, Bryan T. [mailto:BMohler@PRYORCASHMAN.com]
    Sent: Wednesday, January 18, 2023 5:37 PM
    To: Michele Kahn >; 'Weissman, Benjamin'
    >; Soloway, Todd E.
    >; Hill, Meghan E.
    >; Shaw, Rachel E.
    >
    Cc: 'Younger, Stephen P.' >; 'Cato, Shayonna'
    >; 'McDonough, Joanna'
    >; 'Kelly, Rachel'
    >; 'Allis, Hayley'
    >
    Subject: RE: Tekiner v. Bremen House 657193/2020 - Briefing Schedule on Pending Motions

    Ben, Michele,

    I am attaching the stipulation with one edit in tracked changes. In my email from Friday, I proposed that the briefing
    schedule on Zeynep’s motion for leave to amend be the same as for the motions to compel, but I then specified the
    wrong dates. It should be – as with the compel motions – opposition due January 27, reply due February 10 (not Jan 20
    and Feb 3 as I mistakenly indicated). With that correction, we are good with the stipulation and you can affix my
    signature. Let me know if we need to discuss.

    Bryan

    Bryan T. Mohler | Pryor Cashman LLP
    7 Times Square | New York, New York 10036-6569
    Office: (212) 326-0466 | Mobile: (419) 290-8351
    bmohler@pryorcashman.com

    From: Michele Kahn >
    Sent: Tuesday, January 17, 2023 5:23 PM
    To: 'Weissman, Benjamin' >; Mohler, Bryan T.
    >; Soloway, Todd E.
    >; Hill, Meghan E.
    >; Shaw, Rachel E.
    >
    Cc: 'Younger, Stephen P.' >; 'Cato, Shayonna'
    >; 'McDonough, Joanna'
    >; 'Kelly, Rachel'
    >; 'Allis, Hayley'
    >
    Subject: RE: Tekiner v. Bremen House 657193/2020 - Briefing Schedule on Pending Motions

    Ben. The revised stipulation is fine with me and you can affix my signature.

                                                                4
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM                                                      INDEX NO. 657193/2020
NYSCEF DOC. NO. 1264                                                                          RECEIVED NYSCEF: 02/14/2023


    Thanks, Michele


    Michele Kahn, Esq.
    Kahn & Goldberg, LLP
    555 Fifth Avenue, 14th Floor
    New York, NY 10017
    Tel. (212) 687-5066
    Fax (212) 986-5316
    mk@kahngoldberg.com
    www.kahngoldberg.com

    From: Weissman, Benjamin [mailto:bweissman@foleyhoag.com]
    Sent: Tuesday, January 17, 2023 4:56 PM
    To: Michele Kahn >; 'Mohler, Bryan T.'
    >; 'Soloway, Todd E.'
    >; 'Hill, Meghan E.'
    >; 'Shaw, Rachel E.'
    >
    Cc: Younger, Stephen P. >; Cato, Shayonna
    >; McDonough, Joanna
    >; Kelly, Rachel
    >; Allis, Hayley
    >
    Subject: RE: Tekiner v. Bremen House 657193/2020 - Briefing Schedule on Pending Motions

    Thanks Michele. Given that the court just signed the order to show cause on Motion Sequence #46 (Plaintiffs’ motion to
    vacate notes of issue) and set its own briefing schedule, I’ve taken that motion out of the attached. Please review this
    version and let me know if any comments or if ok to sign and file.

    Thanks,
    Ben

    From: Michele Kahn >
    Sent: Tuesday, January 17, 2023 4:33 PM
    To: Weissman, Benjamin >; 'Mohler, Bryan T.'
    >; 'Soloway, Todd E.'
    >; 'Hill, Meghan E.'
    >; 'Shaw, Rachel E.'
    >
    Cc: Younger, Stephen P. >; Cato, Shayonna
    >; McDonough, Joanna
    >; Kelly, Rachel
    >; Allis, Hayley
    >
    Subject: RE: Tekiner v. Bremen House 657193/2020 - Briefing Schedule on Pending Motions

    **EXTERNAL**
    ________________________________
    Ben. The stipulation is fine and you can affix my “/s/” signature.


                                                                  5
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM                                                     INDEX NO. 657193/2020
NYSCEF DOC. NO. 1264                                                                         RECEIVED NYSCEF: 02/14/2023
    Thanks, Michele


    Michele Kahn, Esq.
    Kahn & Goldberg, LLP
    555 Fifth Avenue, 14th Floor
    New York, NY 10017
    Tel. (212) 687-5066
    Fax (212) 986-5316
    mk@kahngoldberg.com
    www.kahngoldberg.com

    From: Weissman, Benjamin [mailto:bweissman@foleyhoag.com]
    Sent: Tuesday, January 17, 2023 4:08 PM
    To: Michele Kahn >; 'Mohler, Bryan T.'
    >; 'Soloway, Todd E.'
    >; 'Hill, Meghan E.'
    >; 'Shaw, Rachel E.'
    >
    Cc: Younger, Stephen P. >; Cato, Shayonna
    >; McDonough, Joanna
    >; Kelly, Rachel
    >; Allis, Hayley
    >
    Subject: RE: Tekiner v. Bremen House 657193/2020 - Briefing Schedule on Pending Motions

    All,

    Please see the attached stipulation for your review. Please let me know any comments and if we can file with your /s/
    signature.

    Thanks,
    Ben

    From: Michele Kahn >
    Sent: Friday, January 13, 2023 5:49 PM
    To: 'Mohler, Bryan T.' >; Weissman,
    Benjamin >; 'Soloway, Todd E.'
    >; 'Hill, Meghan E.'
    >; 'Shaw, Rachel E.'
    >
    Cc: Younger, Stephen P. >; Cato, Shayonna
    >; McDonough, Joanna
    >; Kelly, Rachel
    >; Allis, Hayley
    >
    Subject: RE: Tekiner v. Bremen House 657193/2020 - Briefing Schedule on Pending Motions

    **EXTERNAL**
    ________________________________
    Bryan, I saw you called but I was on the phone.


                                                               6
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM                                                       INDEX NO. 657193/2020
NYSCEF DOC. NO. 1264                                                                          RECEIVED NYSCEF: 02/14/2023
    I am in agreement with the three points you and Ben discussed.

    On Zeynep’s motion for leave to amend – agreed -- your opposition due January 20, my reply due February 3.

    Thank you, Michele

    Michele Kahn, Esq.
    Kahn & Goldberg, LLP
    555 Fifth Avenue, 14th Floor
    New York, NY 10017
    Tel. (212) 687-5066
    Fax (212) 986-5316
    mk@kahngoldberg.com
    www.kahngoldberg.com

    From: Mohler, Bryan T. [mailto:BMohler@PRYORCASHMAN.com]
    Sent: Friday, January 13, 2023 5:42 PM
    To: Weissman, Benjamin >; Soloway, Todd E.
    >; Hill, Meghan E.
    >; Shaw, Rachel E.
    >
    Cc: Michele Kahn >; Younger, Stephen P.
    >; Cato, Shayonna
    >; McDonough, Joanna
    >; Kelly, Rachel
    >; Allis, Hayley
    >
    Subject: RE: Tekiner v. Bremen House 657193/2020 - Briefing Schedule on Pending Motions

    All –

    I spoke with Ben this afternoon, and we agreed as follows:

    1. The parties will file combined opposition and reply for the pending compel motions (motion sequence nos. 44, 45 and
    12.27.22 Motion to Compel), and will jointly request increased word limits of 14,000 for Defendants’ opposition and
    8,400 for Plaintiffs’ reply.
    2. The parties will separately brief the motion to strike note of issue (motion sequence no. 46), and will not request
    increased word limits on that motion.
    3. For each of these motions, Defendants’ opposition will be due January 27, with Plaintiffs’ reply due February 10.

    Ben is preparing a stipulation that we will aim to file on Tuesday.

    Michelle – I called you to propose the same briefing schedule (opposition due January 20, reply due February 3) on
    Zeynep’s motion for leave to amend. Let me know if that is agreeable, and we can include it in the stipulation Ben is
    preparing.

    Bryan

    Bryan T. Mohler | Pryor Cashman LLP
    7 Times Square | New York, New York 10036-6569
    Office: (212) 326-0466 | Mobile: (419) 290-8351
    bmohler@pryorcashman.com

                                                                  7
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM                                                     INDEX NO. 657193/2020
NYSCEF DOC. NO. 1264                                                                         RECEIVED NYSCEF: 02/14/2023


    From: Weissman, Benjamin >
    Sent: Friday, January 13, 2023 10:17 AM
    To: Soloway, Todd E. >; Hill, Meghan E.
    >; Mohler, Bryan T.
    >; Shaw, Rachel E.
    >
    Cc: Michele Kahn >; Younger, Stephen P.
    >; Cato, Shayonna
    >; McDonough, Joanna
    >; Kelly, Rachel
    >; Allis, Hayley
    >
    Subject: Tekiner v. Bremen House 657193/2020 - Briefing Schedule on Pending Motions


    Counsel,

    As discussed at yesterday’s court appearance, we propose the following briefing schedule on Plaintiffs’ pending motions
    (Motion #s 44, 45, 46, and 12.27.22 Motion to Compel): Defendants’ opposition due January 20, Plaintiffs’ reply due
    February 3. We also propose that the parties submit combined briefing on all four motions, and agree to doubled word
    limits for the briefs and affirmations: 14,000 for Defendants’ opposition and 8,400 for Plaintiffs’ reply.

    Best,
    Ben




    Benjamin H. Weissman | Associate

    FOLEY HOAG LLP
    1301 Avenue of the Americas
    New York, New York 10019
    (212) 812-0351 phone




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    ________________________________

                                                               8
FILED: NEW YORK COUNTY CLERK 02/14/2023 09:34 AM                                                            INDEX NO. 657193/2020
NYSCEF DOC. NO. 1264                                                                                RECEIVED NYSCEF: 02/14/2023


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                                                                    9