On December 21, 2020 a
Exhibit,Appendix
was filed
involving a dispute between
Yasemin Tekiner,
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,
and
254-258 W. 35Th St. Llc,
Berrin Tekiner,
Billur Akipek
In Her Capacity As A Trustee Of The Yasemin Tekiner 2011 Descendants Trust,
Bremen House Inc.,
Bremen House Texas, Inc.,
German News Company, Inc.,
German News Texas, Inc.,
Gonca Tekiner,
Zeynep Tekiner,
for Commercial Division
in the District Court of New York County.
Preview
FILED: NEW YORK COUNTY CLERK 04/11/2023 12:27 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1550 RECEIVED NYSCEF: 04/11/2023
EXHIBIT H
FILED: NEW YORK COUNTY CLERK 04/11/2023 12:27 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1550 RECEIVED NYSCEF: 04/11/2023
Michele Kahn
From: Michele Kahn
Sent: Monday, December 12, 2022 4:36 PM
'tony.harwood@aharwoodlaw.com'
To:
Cc: Tekiner'
Zeynep Tekiner (tekinerzeynep77@gmail.com);'Jasmin
Subject: RE: [EXTERNAL]
Tony. I think PIBgave a very clear indication of a positive way to move forward,
Please reconsider whether you really want me to ask f thought were clear. In my
they pretty
view,
P]Bis The are indeed being very helpful
owever, every hour spent on emails like this and the Zoom Saturday take time away
from working on the case. Also, with everything up in the air,
This situation requ ivity, counsel, and statesmanship, and yes, it may also require late hours and
weekends. I hope that you are able to help them reach a resolution and a way forward that is
beneficial to them, whatever that outcome may be.
Please do everything Dossible
Thank you, Michele
Michele Kahn, Esq.
Kahn & Goldberg, LLP
Avenue,14*
555 Fifth Floor
New York, NY 10017
Tel. (212) 687-5066
Fax (212) 986-5316
mkrekahngoldberg.com
www.kahngoldberg.com
From: tony.harwood@aharwoodlaw.com [mallto:tony.harwood@aharwoodlaw.com]
Sent: Monday, December12, 2022 3:12 PM
To: Michele Kahn
Cc: Jtekiner@gmail.com; 'Zeynep Tekiner'
Subject: RE: [EXTERNAL]
1
FILED: NEW YORK COUNTY CLERK 04/11/2023 12:27 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1550 RECEIVED NYSCEF: 04/11/2023
Michele,
learn of any problems, please let us know so we can address them immediately.
During the video conference on Saturday with you and PIR
t would help Jasmin and Zeynep to have
This could help provide clarity and hopefully expedite things.
Despite that, we are working promptly to try to find a solution.
We will get back to you and PlB as soon as reasonably possible. 1 expect it will be several days, given my schedule and
Thanks.
Anthony J. Harwood
Harwood Law PLLC
85
260 Madison Avenue, Floor
New York, NY 10016
Tel.: 212-867-6820
Fax: 212-937-3167
email: Tony.Harwood@aharwoodlaw.com
CONFIDENTIALITY NOTE - THIS E-MAIL TRANSMISSION IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY
TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL OR EXEMPT FROM
DISCLOSURE UNDER APPLICABLE LAW. If the reader of this transmission is NOT the intended recipient, or the employee
2
FILED: NEW YORK COUNTY CLERK 04/11/2023 12:27 AM INDEX NO. 657193/2020
NYSCEF DOC. NO. 1550 RECEIVED NYSCEF: 04/11/2023
or agent responsible to deliver it to the intended you are hereby notified that
recipient, any dissemination, distribution
or copying of this communication is strictly prohibited. If you have received this communication in error, please notify
Anthony Harwood immediately by telephone at 212-867-6820 and delete this message from your system.
From: Michele Kahn
Sent: Monday, December 12, 2022 11:14 AM
To: tony.harwoodpaharwoodlaw.com
Cc: Itekiner@gmail.com; Tekiner'
'Ze ne
Subject: RE: [EXTERNAL]
Importance: High
Tony. This is all coming from me not anyone else.
I cannot stress
On Saturday's call, PIB proposed
Please schedule a Zoom with Scott and Jay for today or tomorrow.
Thank you, Michele
Michele Kahn, Esq.
Kahn & Goldberg, LLP
14*
555 Fifth Avenue, Floor
New York, NY 10017
Tel. (212) 687-5066
Fax (212) 986-5316
mkokahngoldberg.com
www.kahngoldberg.com
From: tony.harwoodpaharwoodlaw.com [mailto:tony.harwood@aharwoodlaw.coml
Sent: Monday, December 12, 2022 10:06 AM
To: Scott Parker ; Sanjay Ibrahim
Cc: mk ; itekiner@gmail.com; Tekiner
Zeynep
Subject: RE: [EXTERNAL]
We're going to need a few more days.
Anthony J. Harwood
Harwood Law PLLC
260 86
Madison Avenue, Floor
New York, NY 10016
3
Document Filed Date
April 11, 2023
Case Filing Date
December 21, 2020
Category
Commercial Division
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FILED: NEW YORK COUNTY CLERK 04/11/2023 12:27 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1550 RECEIVED NYSCEF: 04/11/2023 EXHIBIT H FILED: NEW YORK COUNTY CLERK 04/11/2023 12:27 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1550 RECEIVED NYSCEF: 04/11/2023 Michele Kahn From: Michele Kahn Sent: Monday, December 12, 2022 4:36 PM 'tony.harwood@aharwoodlaw.com' To: Cc: Tekiner' Zeynep Tekiner (tekinerzeynep77@gmail.com);'Jasmin Subject: RE: [EXTERNAL] Tony. I think PIBgave a very clear indication of a positive way to move forward, Please reconsider whether you really want me to ask f thought were clear. In my they pretty view, P]Bis The are indeed being very helpful owever, every hour spent on emails like this and the Zoom Saturday take time away from working on the case. Also, with everything up in the air, This situation requ ivity, counsel, and statesmanship, and yes, it may also require late hours and weekends. I hope that you are able to help them reach a resolution and a way forward that is beneficial to them, whatever that outcome may be. Please do everything Dossible Thank you, Michele Michele Kahn, Esq. Kahn & Goldberg, LLP Avenue,14* 555 Fifth Floor New York, NY 10017 Tel. (212) 687-5066 Fax (212) 986-5316 mkrekahngoldberg.com www.kahngoldberg.com From: tony.harwood@aharwoodlaw.com [mallto:tony.harwood@aharwoodlaw.com] Sent: Monday, December12, 2022 3:12 PM To: Michele Kahn Cc: Jtekiner@gmail.com; 'Zeynep Tekiner' Subject: RE: [EXTERNAL] 1 FILED: NEW YORK COUNTY CLERK 04/11/2023 12:27 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1550 RECEIVED NYSCEF: 04/11/2023 Michele, learn of any problems, please let us know so we can address them immediately. During the video conference on Saturday with you and PIR t would help Jasmin and Zeynep to have This could help provide clarity and hopefully expedite things. Despite that, we are working promptly to try to find a solution. We will get back to you and PlB as soon as reasonably possible. 1 expect it will be several days, given my schedule and Thanks. Anthony J. Harwood Harwood Law PLLC 85 260 Madison Avenue, Floor New York, NY 10016 Tel.: 212-867-6820 Fax: 212-937-3167 email: Tony.Harwood@aharwoodlaw.com CONFIDENTIALITY NOTE - THIS E-MAIL TRANSMISSION IS INTENDED ONLY FOR THE USE OF THE INDIVIDUAL OR ENTITY TO WHICH IT IS ADDRESSED AND MAY CONTAIN INFORMATION THAT IS PRIVILEGED, CONFIDENTIAL OR EXEMPT FROM DISCLOSURE UNDER APPLICABLE LAW. If the reader of this transmission is NOT the intended recipient, or the employee 2 FILED: NEW YORK COUNTY CLERK 04/11/2023 12:27 AM INDEX NO. 657193/2020 NYSCEF DOC. NO. 1550 RECEIVED NYSCEF: 04/11/2023 or agent responsible to deliver it to the intended you are hereby notified that recipient, any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please notify Anthony Harwood immediately by telephone at 212-867-6820 and delete this message from your system. From: Michele Kahn Sent: Monday, December 12, 2022 11:14 AM To: tony.harwoodpaharwoodlaw.com Cc: Itekiner@gmail.com; Tekiner' 'Ze ne Subject: RE: [EXTERNAL] Importance: High Tony. This is all coming from me not anyone else. I cannot stress On Saturday's call, PIB proposed Please schedule a Zoom with Scott and Jay for today or tomorrow. Thank you, Michele Michele Kahn, Esq. Kahn & Goldberg, LLP 14* 555 Fifth Avenue, Floor New York, NY 10017 Tel. (212) 687-5066 Fax (212) 986-5316 mkokahngoldberg.com www.kahngoldberg.com From: tony.harwoodpaharwoodlaw.com [mailto:tony.harwood@aharwoodlaw.coml Sent: Monday, December 12, 2022 10:06 AM To: Scott Parker ; Sanjay Ibrahim Cc: mk ; itekiner@gmail.com; Tekiner Zeynep Subject: RE: [EXTERNAL] We're going to need a few more days. Anthony J. Harwood Harwood Law PLLC 260 86 Madison Avenue, Floor New York, NY 10016 3