Preview
FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1321 RECEIVED NYSCEF: 02/17/2023
EXHIBIT H
FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1321 RECEIVED NYSCEF: 02/17/2023
From: Scott Parker
Sent: Wednesday, September 7, 2022 11:11 AM
To: Hill, Meghan E.
Cc: Sanjay Ibrahim; Mohler, Bryan T.; Younger, Stephen P.; Michele Kahn; Soloway, Todd E.
Subject: RE: Tekiner v. Bremen House Inc. [PIB-LEGAL_DMS.FID449713]
**EXTERNAL**
Meghan, per your request, here is a list of revised questions/topics for the Special Meeting. Would you please confirm if
you are going to arrange for the meeting to occur on September 15 or 16, subject to defendants’ availability? If there
are any questions that you believe have already been fully addressed through document production, please identify the
Bates ranges for those documents. Or, if there are any questions that your clients can answer in advance of the me eting
to streamline the issues, please provide those answers under separate cover. Thanks, Scott
Questions/Topics:
We would like to discuss the profit and loss of the company in 2021 (see Brem00357456-488), including: (1) the
distribution of the net income of $19,263,177.30 (see Brem00357457); and (2) the exact breakdown of the gross
payroll (85120) of $1,272,356.68 from the 2021 Profit and Loss for Bremen House Inc. (see Brem00357457,
Brem00357487, Brem00357497).
What is the profit and loss of the company so far in 2022? What is the market outlook for the company?
o What were the company’s financial projections for 2021, and were they met? How about for 2022 so
far? If not met, why not?
o Are any of the company’s properties not currently profitable? If so, which ones and why not? What is
the main driver of the company’s profitability?
o How much debt is the company currently carrying? Which properties have mortgages, and for how
much?
o Does the company currently have a line of credit? If so, how much and what has been used?
How much cash does the company currently have on hand? How does that compare to the end of 2021, 2020,
and 2019?
What is the status of the company’s tax returns (federal and state) for 2020 and 2021?
Which properties have existing code violations, and for how much?
How were the sale proceeds distributed from 1320 Madison?
Regarding the sale of the Tanglewylde property, your September 5 th letter indicated that the sale proceeds
would be used for “ordinary-course business expenses”, including the “payment of additional property taxes
among other things.” On our call today, you said that the reference to “ordinary-course business expenses” in
your letter was intended to be used the same way as that term is used on the 2021 Profit & Loss
statement. Please provide more specific information as to exactly which expenses the proceeds are going to be
applied to, and also which property taxes the Company intends to cover with these proceeds.
o Further, please identify the purchaser of the Tanglewylde property.
1
FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1321 RECEIVED NYSCEF: 02/17/2023
Other than Tanglewylde, is the company currently considering purchasing or selling any other properties? What
properties were purchased and/or sold in 2021 and 2022?
What is the percentage of vacant units (both residential and commercial) for the company’s properties,
including 35th Street?
Questions regarding 35th Street:
o What was the profit and loss for 35th Street for 2021 and 2022, including to whom are management fees
paid, how much and for what services?
o What is the status of the listing and sales effort for 35th Street? Is there a price? Have any offers been
made?
o Why does company management want to sell 35th Street?
o What is the Bremen House log-in for Marcus Millichap?
What is the status of the company’s bookkeeper?
What accounting system is the company using post-Raish?
Since December 2020, please identify which company employees have been hired and/or fired.
o Please also provide a list of current employment agreements in effect for the company and its
employees.
Are all of the company’s corporate filings up to date? Are there any delinquent filings?
o Have the deficiencies identified in Jasmin’s May 23 rd letter (including but not limited to the Texas
companies) been cured? If not, why not?
What is the status of the German News entities?
What is the status of the certificate of occupancy for the company’s office?
Is there any other pending or threatened litigation involving any of the companies or its board members or
employees?
o Is the lawsuit regarding the office units takeover, involving rent stabilized tenants, still active?
Why is the company paying for the maintenance on the Marion Lane property, if the company is no longer
paying maintenance on personal homes?
Why does Jasmin’s home have an automobile expense listed in the Profit and Loss?
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
2
FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1321 RECEIVED NYSCEF: 02/17/2023
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, September 5, 2022 9:57 PM
To: Scott Parker
Cc: Sanjay Ibrahim ; Mohler, Bryan T. ; Younger,
Stephen P. ; Michele Kahn ; Soloway, Todd E.
Subject: [EXTERNAL] RE: Tekiner v. Bremen House Inc. [PIB-LEGAL_DMS.FID449713]
Scott:
See attached letter. We will circulate a dial-in for the meet and confer tomorrow in a separate email.
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: Saturday, September 3, 2022 5:35 PM
To: Hill, Meghan E.
Cc: Sanjay Ibrahim ; Mohler, Bryan T. ; Younger,
Stephen P. ; Michele Kahn
Subject: RE: Tekiner v. Bremen House Inc. [PIB-LEGAL_DMS.FID449713]
Meghan, please see attached. We are available to meet and confer on all of these topics, plus the Santander subpoena,
on Tuesday until 2 pm.
Regards,
Scott
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
3
FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1321 RECEIVED NYSCEF: 02/17/2023
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: Wednesday, August 31, 2022 3:18 PM
To: Scott Parker
Cc: Sanjay Ibrahim ; Mohler, Bryan T. ; Younger,
Stephen P.
Subject: [EXTERNAL] RE: Tekiner v. Bremen House Inc. [PIB-LEGAL_DMS.FID449713]
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,
4
FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1321 RECEIVED NYSCEF: 02/17/2023
Scott
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.
5
FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1321 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.
***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.
6
Preview
FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1321 RECEIVED NYSCEF: 02/17/2023 EXHIBIT H FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1321 RECEIVED NYSCEF: 02/17/2023 From: Scott Parker Sent: Wednesday, September 7, 2022 11:11 AM To: Hill, Meghan E. Cc: Sanjay Ibrahim; Mohler, Bryan T.; Younger, Stephen P.; Michele Kahn; Soloway, Todd E. Subject: RE: Tekiner v. Bremen House Inc. [PIB-LEGAL_DMS.FID449713] **EXTERNAL** Meghan, per your request, here is a list of revised questions/topics for the Special Meeting. Would you please confirm if you are going to arrange for the meeting to occur on September 15 or 16, subject to defendants’ availability? If there are any questions that you believe have already been fully addressed through document production, please identify the Bates ranges for those documents. Or, if there are any questions that your clients can answer in advance of the me eting to streamline the issues, please provide those answers under separate cover. Thanks, Scott Questions/Topics: We would like to discuss the profit and loss of the company in 2021 (see Brem00357456-488), including: (1) the distribution of the net income of $19,263,177.30 (see Brem00357457); and (2) the exact breakdown of the gross payroll (85120) of $1,272,356.68 from the 2021 Profit and Loss for Bremen House Inc. (see Brem00357457, Brem00357487, Brem00357497). What is the profit and loss of the company so far in 2022? What is the market outlook for the company? o What were the company’s financial projections for 2021, and were they met? How about for 2022 so far? If not met, why not? o Are any of the company’s properties not currently profitable? If so, which ones and why not? What is the main driver of the company’s profitability? o How much debt is the company currently carrying? Which properties have mortgages, and for how much? o Does the company currently have a line of credit? If so, how much and what has been used? How much cash does the company currently have on hand? How does that compare to the end of 2021, 2020, and 2019? What is the status of the company’s tax returns (federal and state) for 2020 and 2021? Which properties have existing code violations, and for how much? How were the sale proceeds distributed from 1320 Madison? Regarding the sale of the Tanglewylde property, your September 5 th letter indicated that the sale proceeds would be used for “ordinary-course business expenses”, including the “payment of additional property taxes among other things.” On our call today, you said that the reference to “ordinary-course business expenses” in your letter was intended to be used the same way as that term is used on the 2021 Profit & Loss statement. Please provide more specific information as to exactly which expenses the proceeds are going to be applied to, and also which property taxes the Company intends to cover with these proceeds. o Further, please identify the purchaser of the Tanglewylde property. 1 FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1321 RECEIVED NYSCEF: 02/17/2023 Other than Tanglewylde, is the company currently considering purchasing or selling any other properties? What properties were purchased and/or sold in 2021 and 2022? What is the percentage of vacant units (both residential and commercial) for the company’s properties, including 35th Street? Questions regarding 35th Street: o What was the profit and loss for 35th Street for 2021 and 2022, including to whom are management fees paid, how much and for what services? o What is the status of the listing and sales effort for 35th Street? Is there a price? Have any offers been made? o Why does company management want to sell 35th Street? o What is the Bremen House log-in for Marcus Millichap? What is the status of the company’s bookkeeper? What accounting system is the company using post-Raish? Since December 2020, please identify which company employees have been hired and/or fired. o Please also provide a list of current employment agreements in effect for the company and its employees. Are all of the company’s corporate filings up to date? Are there any delinquent filings? o Have the deficiencies identified in Jasmin’s May 23 rd letter (including but not limited to the Texas companies) been cured? If not, why not? What is the status of the German News entities? What is the status of the certificate of occupancy for the company’s office? Is there any other pending or threatened litigation involving any of the companies or its board members or employees? o Is the lawsuit regarding the office units takeover, involving rent stabilized tenants, still active? Why is the company paying for the maintenance on the Marion Lane property, if the company is no longer paying maintenance on personal homes? Why does Jasmin’s home have an automobile expense listed in the Profit and Loss? 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 2 FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1321 RECEIVED NYSCEF: 02/17/2023 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, September 5, 2022 9:57 PM To: Scott Parker Cc: Sanjay Ibrahim ; Mohler, Bryan T. ; Younger, Stephen P. ; Michele Kahn ; Soloway, Todd E. Subject: [EXTERNAL] RE: Tekiner v. Bremen House Inc. [PIB-LEGAL_DMS.FID449713] Scott: See attached letter. We will circulate a dial-in for the meet and confer tomorrow in a separate email. 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: Saturday, September 3, 2022 5:35 PM To: Hill, Meghan E. Cc: Sanjay Ibrahim ; Mohler, Bryan T. ; Younger, Stephen P. ; Michele Kahn Subject: RE: Tekiner v. Bremen House Inc. [PIB-LEGAL_DMS.FID449713] Meghan, please see attached. We are available to meet and confer on all of these topics, plus the Santander subpoena, on Tuesday until 2 pm. Regards, Scott 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 3 FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1321 RECEIVED NYSCEF: 02/17/2023 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: Wednesday, August 31, 2022 3:18 PM To: Scott Parker Cc: Sanjay Ibrahim ; Mohler, Bryan T. ; Younger, Stephen P. Subject: [EXTERNAL] RE: Tekiner v. Bremen House Inc. [PIB-LEGAL_DMS.FID449713] 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, 4 FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1321 RECEIVED NYSCEF: 02/17/2023 Scott 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. 5 FILED: NEW YORK COUNTY CLERK 02/17/2023 11:39 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1321 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. ***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. 6