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
INDEX NO. 657193/2020
NYSCEF DOC. NO. 1611 RECEIVED NYSCEF: 05/15/2023
EXHIBIT H
INDEX NO. 657193/2020
NYSCEF DOC. NO. 1611 RECEIVED NYSCEF: 05/15/2023
From: Scott Parker
Sent: Friday, May 12, 2023 11:35 AM
To: Soloway, Todd E.; Hill, Meghan E.; Mohler, Bryan T.; Shaw, Rachel E.
Ce: Sanjay Ibrahim; Weissman, Benjamin; mk; Cato, Shayonna; Fred Hoensch
Subject: Tekiner - expert discovery [PIB-LEGAL_DMS.FID449713]
Todd, as you will recall, regarding expert discovery, Judge Cohen indicated at oral argument on February 17, 2023 that
he would consider allowing expert discovery if both sides agreed to it. Would you please confirm if you would agree to
this? Absent your agreement, we intend to move to renew our prior order to show cause for leave to take post-note of
issue discovery, seeking permission from the Court to move forward with expert discovery.
Regards,
Scott
Scott Parker
Office 908.333.6220 | Mobile 973.309.3156
Ext. 101
Document Filed Date
May 15, 2023
Case Filing Date
December 21, 2020
Category
Commercial Division
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Preview
INDEX NO. 657193/2020 NYSCEF DOC. NO. 1611 RECEIVED NYSCEF: 05/15/2023 EXHIBIT H INDEX NO. 657193/2020 NYSCEF DOC. NO. 1611 RECEIVED NYSCEF: 05/15/2023 From: Scott Parker Sent: Friday, May 12, 2023 11:35 AM To: Soloway, Todd E.; Hill, Meghan E.; Mohler, Bryan T.; Shaw, Rachel E. Ce: Sanjay Ibrahim; Weissman, Benjamin; mk; Cato, Shayonna; Fred Hoensch Subject: Tekiner - expert discovery [PIB-LEGAL_DMS.FID449713] Todd, as you will recall, regarding expert discovery, Judge Cohen indicated at oral argument on February 17, 2023 that he would consider allowing expert discovery if both sides agreed to it. Would you please confirm if you would agree to this? Absent your agreement, we intend to move to renew our prior order to show cause for leave to take post-note of issue discovery, seeking permission from the Court to move forward with expert discovery. Regards, Scott Scott Parker Office 908.333.6220 | Mobile 973.309.3156 Ext. 101