Letter,Correspondence: 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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                                Steven J. Mandelsberg
212 478 7360 direct
smandelsberg@thompsoncoburn.com




Via Hand Delivery and FedEx

February 27, 2023

Honorable Joel M. Cohen
Supreme Court of the State of New York
County of New York
60 Centre Street, Room 570
New York, New York 10007
Tel.: (646) 386-4927

Re:       Yasemin Tekiner et al. v. Bremen House Inc. et al., Index No. 657193/2020
          Briefing Schedule for Parker Ibrahim & Berg LLP’s Motion to Withdraw as Co-
          Counsel for Plaintiff Yasemin Tekiner

Dear Justice Cohen:

       We have been retained as counsel to Parker, Ibrahim & Berg LLP (“PIB”), co-counsel of
record to Plaintiff Yasemin Tekiner (“Yasemin”) in the above-referenced action, in connection
with PIB’s motion to withdraw as co-counsel to Yasemin. We have enclosed a copy of our Notice
of Appearance and Demand for Service of Papers on behalf of PIB.

       In accordance with Your Honor’s direction at a hearing in Chambers on February 17, 2023,
we have communicated with Anthony J. Harwood, Yasemin’s withdrawal motion-related counsel,
along with Yasemin’s other co-counsel and Plaintiff Zeynep Tekiner’s counsel, and reached an
agreement on the following briefing schedule for PIB’s renewed withdrawal motion requested by
Your Honor, with all motion papers to be submitted confidentially to Chambers and not e-filed:

      •   PIB’s renewed withdrawal motion to be submitted on March 1;

      •   Mr. Harwood’s opposition on behalf of Yasemin, and any other motion response, to be
          submitted on March 22 (Mr. Harwood having advised that he could not submit any motion
          response sooner);

      •   PIB’s reply papers (if any) in further support of its withdrawal motion to be submitted on
          or before March 29; and
Honorable Joel M. Cohen
February 27, 2023
Page 2

   •   withdrawal motion return date on March 30.

                                                    Respectfully,

                                                    /s/ Steven J. Mandelsberg
                                                    Steven J. Mandelsberg


SJM/mb
Honorable Joel M. Cohen
February 27, 2023
Page 3

TO:   Via Email
      Anthony J. Harwood, Esq.
      Harwood Law PLLC
      260 Madison Avenue, 8th Floor
      New York, New York 10016
      Tel.: (212) 867-6820
      Facsimile: (212) 937-3167
      tony.harwood@aharwoodlaw.com

      Independent Counsel for Plaintiff Yasemin Tekiner

      Benjamin Weissman, Esq.
      Foley Hoag LLP
      1301 Avenue of the Americas
      New York, New York 10019
      Tel.: (212) 812-0400
      Facsimile: (212) 812-0399
      bweissman@foleyhoag.com

      Co-Counsel for Plaintiff Yasemin Tekiner

      Gary B. Freidman, Esq.
      Greenfield Stein & Senior, LLP
      600 Third Avenue, 11th Floor
      New York, New York 10016
      Tel.: (212) 818-9600
      Facsimile: (212) 818-1264
      gfreidman@gss-law.com

      Co-Counsel for Plaintiff Yasemin Tekiner

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

      Attorneys for Plaintiff Zeynep Tekiner