On December 21, 2020 a
Letter,Correspondence
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.
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KAHN & GOLDBERG, LLP
ATTORNEYS AT LAW
MICHELE KAHN 555 FIFTH AVENUE TELEPHONE: (212) 687-5066
mk@kahngoldberg.com 14th FLOOR FACSIMILE: (212) 983-8415
NEW YORK, N.Y. 10017 WEBSITE: www.kahngoldberg.com
ERIC GOLDBERG
eg@kahngoldberg.com
April 4, 2023
VIA ECF AND EMAIL
Hon. Joel M. Cohen, J.S.C.
Commercial Division, Supreme Court
60 Centre Street, Courtroom 208
New York, NY 10007
Re: Tekiner v. Bremen House, et al.; Index No. 657193/2020;
Request to Strike Improper Papers Filed by Pryor Cashman
Dear Justice Cohen:
I represent Plaintiff Zeynep Tekiner. On behalf of all Plaintiffs, I write to ask that your
Honor strike from the docket and refuse to consider the Affirmation of Todd E. Soloway in Further
Opposition to Plaintiffs’ Motion for Appointment of Temporary Receiver Or Preliminary Injunction and
the exhibits thereto, which were wrongfully filed by Pryor Cashman at NYSCEF Docs. 1509, 1510, 1511,
and 1512.
Defendants did not seek or obtain permission to file a sur-reply. Had Defendants sought
permission to do so, Plaintiffs would have opposed such request on the basis that, among other things, an
additional submission is unnecessary. The letters attached as exhibits to Mr. Soloway’s affirmation were
submitted by Plaintiffs in connection with their reply (NYSCEF Docs. 1513, 1514, and 1515), and Mr.
Soloway’s characterization of those letters has little value.
We therefore request that your Honor have docket numbers 1509, 1510, 1511, and 1512 stricken
from the record and removed from NYSCEF and that your Honor not consider them.
Respectfully submitted,
Michele Kahn
cc: PARKER IBRAHIM & BERG LLP
(Sanjay P. Ibrahim and Scott W. Parker)
FOLEY HOAG LLP
(Benjamin H. Weissman and Joanna McDonough)
PRYOR CASHMAN LLP
(Todd E. Soloway, Bryan T. Mohler,
and Meghan E. Hill)
Tekiner/Ltr to Ct Pryor Improper Filing 4-4-23
Document Filed Date
April 04, 2023
Case Filing Date
December 21, 2020
Category
Commercial Division
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KAHN & GOLDBERG, LLP ATTORNEYS AT LAW MICHELE KAHN 555 FIFTH AVENUE TELEPHONE: (212) 687-5066 mk@kahngoldberg.com 14th FLOOR FACSIMILE: (212) 983-8415 NEW YORK, N.Y. 10017 WEBSITE: www.kahngoldberg.com ERIC GOLDBERG eg@kahngoldberg.com April 4, 2023 VIA ECF AND EMAIL Hon. Joel M. Cohen, J.S.C. Commercial Division, Supreme Court 60 Centre Street, Courtroom 208 New York, NY 10007 Re: Tekiner v. Bremen House, et al.; Index No. 657193/2020; Request to Strike Improper Papers Filed by Pryor Cashman Dear Justice Cohen: I represent Plaintiff Zeynep Tekiner. On behalf of all Plaintiffs, I write to ask that your Honor strike from the docket and refuse to consider the Affirmation of Todd E. Soloway in Further Opposition to Plaintiffs’ Motion for Appointment of Temporary Receiver Or Preliminary Injunction and the exhibits thereto, which were wrongfully filed by Pryor Cashman at NYSCEF Docs. 1509, 1510, 1511, and 1512. Defendants did not seek or obtain permission to file a sur-reply. Had Defendants sought permission to do so, Plaintiffs would have opposed such request on the basis that, among other things, an additional submission is unnecessary. The letters attached as exhibits to Mr. Soloway’s affirmation were submitted by Plaintiffs in connection with their reply (NYSCEF Docs. 1513, 1514, and 1515), and Mr. Soloway’s characterization of those letters has little value. We therefore request that your Honor have docket numbers 1509, 1510, 1511, and 1512 stricken from the record and removed from NYSCEF and that your Honor not consider them. Respectfully submitted, Michele Kahn cc: PARKER IBRAHIM & BERG LLP (Sanjay P. Ibrahim and Scott W. Parker) FOLEY HOAG LLP (Benjamin H. Weissman and Joanna McDonough) PRYOR CASHMAN LLP (Todd E. Soloway, Bryan T. Mohler, and Meghan E. Hill) Tekiner/Ltr to Ct Pryor Improper Filing 4-4-23