Preview
FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1318 RECEIVED NYSCEF: 02/17/2023
EXHIBIT E
FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1318 RECEIVED NYSCEF: 02/17/2023
From: Hill, Meghan E.
Sent: Wednesday, August 31, 2022 3:18 PM
To: Scott Parker
Cc: Sanjay Ibrahim; Mohler, Bryan T.; Younger, Stephen P.
Subject: RE: Tekiner v. Bremen House Inc. [PIB-LEGAL_DMS.FID449713]
Attachments: 08.31.2022 Ltr S Parker.PDF
Follow Up Flag: Follow up
Flag Status: Flagged
**EXTERNAL**
Scott – See attached correspondence in response to your August 24, 2022 email. Defendants’ next production of
documents will be transmitted under separate cover.
Please confirm by no later than 9:00 am tomorrow that the return date of the Santander Bank subpoena will be
extended to September 15, 2022 in order for the parties to meet and confer regarding the scope of the documents
requested.
Meghan
_______________________________________
MEGHAN E. HILL
PRYOR CASHMAN LLP
7 Times Square, New York, NY 10036-6569
mhill@pryorcashman.com
Direct Tel: 212-326-0808 (also reachable remotely at this number)
www.pryorcashman.com
A member of Interlaw, an International Association of Independent Law Firms
From: Scott Parker
Sent: Tuesday, August 30, 2022 10:26 AM
To: Hill, Meghan E.
Cc: Sanjay Ibrahim ; Mohler, Bryan T. ; Younger,
Stephen P.
Subject: RE: Tekiner v. Bremen House Inc. [PIB-LEGAL_DMS.FID449713]
Meghan, we would be happy to meet and confer about the scope of the Santander subpoena. But we also must address
the multiple other topics that we have written to you about that you continue to ignore (see attached).
For example – when is the Special Meeting going to be held? Back on July 22 (i.e., five weeks ago), you agreed that it
would be held during the week of August 29, and you expressed a preference for the meeting to be held early that
week, to which we agreed. It is now August 30th, yet you have still not even confirmed the date of the meeting, let alone
scheduled it.
Regards,
Scott
1
FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1318 RECEIVED NYSCEF: 02/17/2023
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: Hill, Meghan E.
Sent: Monday, August 29, 2022 9:36 PM
To: Scott Parker
Cc: Sanjay Ibrahim ; Mohler, Bryan T.
Subject: [EXTERNAL] Tekiner v. Bremen House Inc.
Scott –
I left you a voicemail earlier this evening. We would like to meet and confer about the scope of the Santander subpoena.
Please give me a call to discuss.
Thanks,
Meghan
_______________________________________
MEGHAN E. HILL
PRYOR CASHMAN LLP
7 Times Square, New York, NY 10036-6569
mhill@pryorcashman.com
Direct Tel: 212-326-0808 (also reachable remotely at this number)
www.pryorcashman.com
A member of Interlaw, an International Association of Independent Law Firms
***CONFIDENTIALITY NOTICE***
This email contains confidential information which may also be legally privileged and which is intended only for the use
of the recipient(s) named above. If you are not the intended recipient, you are hereby notified that forwarding or
copying of this email, or the taking of any action in reliance on its contents, may be strictly prohibited. If you have
received this email in error, please notify us immediately by reply email and delete this message from your inbox.
2
FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1318 RECEIVED NYSCEF: 02/17/2023
***CONFIDENTIALITY NOTICE***
This email contains confidential information which may also be legally privileged and which is intended only for the use of
the recipient(s) named above. If you are not the intended recipient, you are hereby notified that forwarding or copying of
this email, or the taking of any action in reliance on its contents, may be strictly prohibited. If you have received this email
in error, please notify us immediately by reply email and delete this message from your inbox.
3
FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1318 RECEIVED NYSCEF: 02/17/2023
Meghan E. Hill
Direct Tel: 212-326-0808
Direct Fax: 212-326-0806
MHill@PRYORCASHMAN.com
August 31, 2022
VIA EMAIL
Scott Parker, Esq.
Parker Ibrahim & Berg LLP
5 Penn Plaza, Ste. 2371
New York, NY 10001
Re: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020
Dear Scott:
We write in response to the topics raised in your August 24, 2022 email.
First, we are generally available to meet and confer tomorrow regarding the Court’s August
17 orders relating to discovery. Please propose a time that works for you. We note, however, that
with regard to the mental health category, the Court directed Plaintiff to first “come up with a
narrower set of requests.” It may be more productive to meet and confer after you prepare a
proposed set of narrowed requests in line with the Court’s guidance.
Second, regarding deposition dates, we have not been able to find dates in the early part of
September that work for all parties, in part due to the upcoming holiday and various other conflicts.
We are currently looking at the weeks of September 19 and 26 for the depositions of Yasemin,
Gonca, Berrin, as well as Defendants’ deposition of Zeynep. Please let us know if you and your
clients have any conflicts during those two weeks.
Last, we jointly address Yasemin and Zeynep’s demand for a special meeting and
Yasemin’s “books and records” demands. When Pryor Cashman first appeared as counsel for
Defendants, we agreed to schedule a Special Meeting to discuss the following topics: 1) the up to
date financial status of the company, taking into account material events that occurred during the
time when Yasemin was not an officer or director; and 2) any upcoming or anticipated sales of
property by Bremen House, including the sale of 81 Tanglewylde. In exchange, you agreed to
provide, 15 days in advance, a list of questions to be discussed at the Special Meeting.
In the time since, however, Plaintiff has bombarded Defendants with series of overlapping,
untargeted, and harassing demands for additional information well beyond the letter and spirit of
our agreement. A summary timeline of these demands is below, which speaks for itself:
FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1318 RECEIVED NYSCEF: 02/17/2023
Scott Parker, Esq.
August 31, 2022
Page 2
Your July 18, 2022 letter, which enclosed and asked Defendants to agree to all the
conditions set forth in the following additional correspondence:
o a July 1, 2022 letter from Yasemin and Zeynep Tekiner to the Individual
Defendants reiterating the demands of the May 19 Demand;
o a July 5, 2022 email from Yasemin Tekiner to the Individual Defendants;
o a July 5, 2022 email from Yasemin Tekiner to Bremen House’s accountants Allen
Beck and Denise Baumann;
o a July 5, 2022 email from Yasemin Tekiner to Sadan Gurbuzturk, a Bremen House
employee;
o a July 5, 2022 email from Yasemin Tekiner to Billur Akipek;
o a July 5, 2022 email from Yasemin Tekiner to Luz Esther Golpinar, a former
Bremen House employee; and
o a July 14, 2022 email from Yasemin Tekiner to Marcus Millichap, Bremen House’s
brokers.
Your July 19, 2022 email to me setting forth additional demands in connection with the
Special Meeting.
An August 9, 2022 Subpoena Duces Tecum served on Santander Bank, which seeks twenty
categories of documents pertaining to nineteen bank accounts belonging to the Individual
Defendants, the Entity Defendants, parties that have been dismissed from this litigation,
and non-parties to the litigation.
Plaintiff’s Fourth Set of Requests for Production (“Fourth RFP”) served on August 18,
2022, propounding fifty-five additional Requests.
Your August 19, 2022 email claiming that Plaintiff was still waiting for Defendants to
produce fourteen additional categories of books and records.
Your August 22, 2022 email setting forth Plaintiff’s proposed list of twenty-two topics
(thirty-six inclusive of subparts) to be discussed at the Special Meeting.
Plaintiff has also repeatedly directly emailed one or more of the Individual Defendants
demanding information:
a July 27, 2022 email from Yasemin Tekiner to all of the Individual Defendants;
a July 27, 2022 email from Yasemin Tekiner to Billur Akipek;
a July 19, 2022 email from Yasemin Tekiner to Berrin Tekiner, Gonca Chelsea, John
Stewart and Eric Anton of Marcus Millichap;
an August 1, 2022 email from Yasemin Tekiner to Billur Akipek;
an August 17, 2022 email from Yasemin Tekiner to Billur Akipek;
an August 17, 2022 email from Yasemin Tekiner to Gonca Chelsea; and
an August 24, 2022 email from Yasemin Tekiner to Gonca Chelsea.
Without exception, the information sought by Plaintiff directly from the Individual Defendants
(and other non-parties) overlaps entirely with the information requests you have propounded.
FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1318 RECEIVED NYSCEF: 02/17/2023
Scott Parker, Esq.
August 31, 2022
Page 3
In addition, with respect to the 55 newly propounded document demands, these are on top
of the 151 separate document requests previously served by Plaintiff, bringing the total number of
document demands served by Plaintiff on Defendants to 206.1 Moreover, at least 45 of the 55 new
Requests are duplicative of earlier RFPs, and nine are duplicative – to the point of being verbatim
copied and pasted (including typos) – of Plaintiff’s numerous recent books and records demands.
Not only that, but in connection with Yasemin’s books and records demands, Pryor Cashman
produced documents responsive to at least six of the new Requests before the Fourth RFP was
even served.
It is now clear, in fact, that much of the information sought by Plaintiff (directly, through
counsel, through party and non-party discovery, and/or at a proposed Special Meeting) has been
previously disclosed through formal or informal means, or was available to her when she was a
director of Bremen House Inc. In order to make an Special Meeting productive, it is first
incumbent upon Plaintiff to review what has already been provided, and to provide a list of
questions informed by that review. The list you provided on August 22 contains numerous
questions that have already been answered in the documents provided to date, and is unworkable.
Just as one example, the very first question “what was the profit and loss of the company in 2021?,”
can be found by reference to the 2021 Profit and Loss statement (see e.g., Brem00357456 et seq.)
We are available to meet and confer regarding the Special Meeting at the same time as the
discussions about the open discovery items if that would be productive.
This letter is without prejudice to any of Defendants’ rights, none of which are hereby
waived.
Very truly yours,
Meghan E. Hill
cc: Counsel of Record (via email)
1
In all, to date Defendants have produced 119,539 documents, comprising well over 300,000 pages, in response to
the First, Second and Third RFPs. Earlier this month, in response to Yasemin’s books and records demands, we
produced an additional 500+ pages of materials. Today we are producing an additional 316 pages of materials in
response to the books and records demands.
Preview
FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1318 RECEIVED NYSCEF: 02/17/2023 EXHIBIT E FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1318 RECEIVED NYSCEF: 02/17/2023 From: Hill, Meghan E. Sent: Wednesday, August 31, 2022 3:18 PM To: Scott Parker Cc: Sanjay Ibrahim; Mohler, Bryan T.; Younger, Stephen P. Subject: RE: Tekiner v. Bremen House Inc. [PIB-LEGAL_DMS.FID449713] Attachments: 08.31.2022 Ltr S Parker.PDF Follow Up Flag: Follow up Flag Status: Flagged **EXTERNAL** Scott – See attached correspondence in response to your August 24, 2022 email. Defendants’ next production of documents will be transmitted under separate cover. Please confirm by no later than 9:00 am tomorrow that the return date of the Santander Bank subpoena will be extended to September 15, 2022 in order for the parties to meet and confer regarding the scope of the documents requested. Meghan _______________________________________ MEGHAN E. HILL PRYOR CASHMAN LLP 7 Times Square, New York, NY 10036-6569 mhill@pryorcashman.com Direct Tel: 212-326-0808 (also reachable remotely at this number) www.pryorcashman.com A member of Interlaw, an International Association of Independent Law Firms From: Scott Parker Sent: Tuesday, August 30, 2022 10:26 AM To: Hill, Meghan E. Cc: Sanjay Ibrahim ; Mohler, Bryan T. ; Younger, Stephen P. Subject: RE: Tekiner v. Bremen House Inc. [PIB-LEGAL_DMS.FID449713] Meghan, we would be happy to meet and confer about the scope of the Santander subpoena. But we also must address the multiple other topics that we have written to you about that you continue to ignore (see attached). For example – when is the Special Meeting going to be held? Back on July 22 (i.e., five weeks ago), you agreed that it would be held during the week of August 29, and you expressed a preference for the meeting to be held early that week, to which we agreed. It is now August 30th, yet you have still not even confirmed the date of the meeting, let alone scheduled it. Regards, Scott 1 FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1318 RECEIVED NYSCEF: 02/17/2023 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: Hill, Meghan E. Sent: Monday, August 29, 2022 9:36 PM To: Scott Parker Cc: Sanjay Ibrahim ; Mohler, Bryan T. Subject: [EXTERNAL] Tekiner v. Bremen House Inc. Scott – I left you a voicemail earlier this evening. We would like to meet and confer about the scope of the Santander subpoena. Please give me a call to discuss. Thanks, Meghan _______________________________________ MEGHAN E. HILL PRYOR CASHMAN LLP 7 Times Square, New York, NY 10036-6569 mhill@pryorcashman.com Direct Tel: 212-326-0808 (also reachable remotely at this number) www.pryorcashman.com A member of Interlaw, an International Association of Independent Law Firms ***CONFIDENTIALITY NOTICE*** This email contains confidential information which may also be legally privileged and which is intended only for the use of the recipient(s) named above. If you are not the intended recipient, you are hereby notified that forwarding or copying of this email, or the taking of any action in reliance on its contents, may be strictly prohibited. If you have received this email in error, please notify us immediately by reply email and delete this message from your inbox. 2 FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1318 RECEIVED NYSCEF: 02/17/2023 ***CONFIDENTIALITY NOTICE*** This email contains confidential information which may also be legally privileged and which is intended only for the use of the recipient(s) named above. If you are not the intended recipient, you are hereby notified that forwarding or copying of this email, or the taking of any action in reliance on its contents, may be strictly prohibited. If you have received this email in error, please notify us immediately by reply email and delete this message from your inbox. 3 FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1318 RECEIVED NYSCEF: 02/17/2023 Meghan E. Hill Direct Tel: 212-326-0808 Direct Fax: 212-326-0806 MHill@PRYORCASHMAN.com August 31, 2022 VIA EMAIL Scott Parker, Esq. Parker Ibrahim & Berg LLP 5 Penn Plaza, Ste. 2371 New York, NY 10001 Re: Tekiner v. Bremen House Inc. et al., Index No. 657193/2020 Dear Scott: We write in response to the topics raised in your August 24, 2022 email. First, we are generally available to meet and confer tomorrow regarding the Court’s August 17 orders relating to discovery. Please propose a time that works for you. We note, however, that with regard to the mental health category, the Court directed Plaintiff to first “come up with a narrower set of requests.” It may be more productive to meet and confer after you prepare a proposed set of narrowed requests in line with the Court’s guidance. Second, regarding deposition dates, we have not been able to find dates in the early part of September that work for all parties, in part due to the upcoming holiday and various other conflicts. We are currently looking at the weeks of September 19 and 26 for the depositions of Yasemin, Gonca, Berrin, as well as Defendants’ deposition of Zeynep. Please let us know if you and your clients have any conflicts during those two weeks. Last, we jointly address Yasemin and Zeynep’s demand for a special meeting and Yasemin’s “books and records” demands. When Pryor Cashman first appeared as counsel for Defendants, we agreed to schedule a Special Meeting to discuss the following topics: 1) the up to date financial status of the company, taking into account material events that occurred during the time when Yasemin was not an officer or director; and 2) any upcoming or anticipated sales of property by Bremen House, including the sale of 81 Tanglewylde. In exchange, you agreed to provide, 15 days in advance, a list of questions to be discussed at the Special Meeting. In the time since, however, Plaintiff has bombarded Defendants with series of overlapping, untargeted, and harassing demands for additional information well beyond the letter and spirit of our agreement. A summary timeline of these demands is below, which speaks for itself: FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1318 RECEIVED NYSCEF: 02/17/2023 Scott Parker, Esq. August 31, 2022 Page 2 Your July 18, 2022 letter, which enclosed and asked Defendants to agree to all the conditions set forth in the following additional correspondence: o a July 1, 2022 letter from Yasemin and Zeynep Tekiner to the Individual Defendants reiterating the demands of the May 19 Demand; o a July 5, 2022 email from Yasemin Tekiner to the Individual Defendants; o a July 5, 2022 email from Yasemin Tekiner to Bremen House’s accountants Allen Beck and Denise Baumann; o a July 5, 2022 email from Yasemin Tekiner to Sadan Gurbuzturk, a Bremen House employee; o a July 5, 2022 email from Yasemin Tekiner to Billur Akipek; o a July 5, 2022 email from Yasemin Tekiner to Luz Esther Golpinar, a former Bremen House employee; and o a July 14, 2022 email from Yasemin Tekiner to Marcus Millichap, Bremen House’s brokers. Your July 19, 2022 email to me setting forth additional demands in connection with the Special Meeting. An August 9, 2022 Subpoena Duces Tecum served on Santander Bank, which seeks twenty categories of documents pertaining to nineteen bank accounts belonging to the Individual Defendants, the Entity Defendants, parties that have been dismissed from this litigation, and non-parties to the litigation. Plaintiff’s Fourth Set of Requests for Production (“Fourth RFP”) served on August 18, 2022, propounding fifty-five additional Requests. Your August 19, 2022 email claiming that Plaintiff was still waiting for Defendants to produce fourteen additional categories of books and records. Your August 22, 2022 email setting forth Plaintiff’s proposed list of twenty-two topics (thirty-six inclusive of subparts) to be discussed at the Special Meeting. Plaintiff has also repeatedly directly emailed one or more of the Individual Defendants demanding information: a July 27, 2022 email from Yasemin Tekiner to all of the Individual Defendants; a July 27, 2022 email from Yasemin Tekiner to Billur Akipek; a July 19, 2022 email from Yasemin Tekiner to Berrin Tekiner, Gonca Chelsea, John Stewart and Eric Anton of Marcus Millichap; an August 1, 2022 email from Yasemin Tekiner to Billur Akipek; an August 17, 2022 email from Yasemin Tekiner to Billur Akipek; an August 17, 2022 email from Yasemin Tekiner to Gonca Chelsea; and an August 24, 2022 email from Yasemin Tekiner to Gonca Chelsea. Without exception, the information sought by Plaintiff directly from the Individual Defendants (and other non-parties) overlaps entirely with the information requests you have propounded. FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1318 RECEIVED NYSCEF: 02/17/2023 Scott Parker, Esq. August 31, 2022 Page 3 In addition, with respect to the 55 newly propounded document demands, these are on top of the 151 separate document requests previously served by Plaintiff, bringing the total number of document demands served by Plaintiff on Defendants to 206.1 Moreover, at least 45 of the 55 new Requests are duplicative of earlier RFPs, and nine are duplicative – to the point of being verbatim copied and pasted (including typos) – of Plaintiff’s numerous recent books and records demands. Not only that, but in connection with Yasemin’s books and records demands, Pryor Cashman produced documents responsive to at least six of the new Requests before the Fourth RFP was even served. It is now clear, in fact, that much of the information sought by Plaintiff (directly, through counsel, through party and non-party discovery, and/or at a proposed Special Meeting) has been previously disclosed through formal or informal means, or was available to her when she was a director of Bremen House Inc. In order to make an Special Meeting productive, it is first incumbent upon Plaintiff to review what has already been provided, and to provide a list of questions informed by that review. The list you provided on August 22 contains numerous questions that have already been answered in the documents provided to date, and is unworkable. Just as one example, the very first question “what was the profit and loss of the company in 2021?,” can be found by reference to the 2021 Profit and Loss statement (see e.g., Brem00357456 et seq.) We are available to meet and confer regarding the Special Meeting at the same time as the discussions about the open discovery items if that would be productive. This letter is without prejudice to any of Defendants’ rights, none of which are hereby waived. Very truly yours, Meghan E. Hill cc: Counsel of Record (via email) 1 In all, to date Defendants have produced 119,539 documents, comprising well over 300,000 pages, in response to the First, Second and Third RFPs. Earlier this month, in response to Yasemin’s books and records demands, we produced an additional 500+ pages of materials. Today we are producing an additional 316 pages of materials in response to the books and records demands.