Fri 18 Feb 2022 16 03 31 0500 Re Fw Zeeman Counterclaim 17F0Ea5A 2¶

Anytime Late Thursday, us 3 works.
Thx


On Fri, Feb 18, 2022 at 3:57 PM Richard J. Capriola <rcapriola@wczlaw.com>
wrote:

> Please see the attached discovery served by plaintiff and the email below
> from Sally Monico.  I think her idea of setting up a call with the 3 of us
> is a good one.  Let me know if you agree and your availability Tuesday or
> Thursday.
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> Thanks
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> Rich
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> <http://www.wczlaw.net/>
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> ------------------------------
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> *Rich Capriola*
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> Winter Capriola Zenner, LLC
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> One Ameris Center
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> *From:* Sally L. Monico <SCook@mmatllaw.com>
> *Sent:* Friday, February 18, 2022 3:53 PM
> *To:* Richard J. Capriola <rcapriola@wczlaw.com>; Lucy Aquino <
> Lucy.Aquino@swiftcurrie.com>; Eric B. Coleman <ecoleman@wczlaw.com>
> *Cc:* Tania Tuttle <ttuttle@mmatllaw.com>
> *Subject:* RE: Zeeman counterclaim
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> Good Afternoon All,
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> Our offices received the attached discovery requests in the mail
> yesterday.  I am passing along in the event you all have not yet received
> copies.
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> A few questions:
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>    1. Lisa Rose emailed everyone last week asking for a call to discuss
>    this matter.  Has anyone spoken to her?
>    2. How do you want to proceed in dividing/answering discovery?
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> At this stage I think it might be a good idea to set up a conference call
> with Sarah to discuss everything so that we can decide how to respond to
> Lisa and how to divide and conquer discovery.
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> Thanks and have a great weekend.
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> *Sally Monico*
> 11625 Rainwater Drive | Ste. 125 | Alpharetta, Georgia 30009
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> *From:* Sarah Zeeman <szeeman@gmail.com>
> *Sent:* Thursday, January 13, 2022 2:50 PM
> *To:* Sally L. Monico <SCook@mmatllaw.com>
> *Cc:* Richard J. Capriola <rcapriola@wczlaw.com>; Lucy Aquino <
> Lucy.Aquino@swiftcurrie.com>; Tania Tuttle <ttuttle@mmatllaw.com>; Eric
> B. Coleman <ecoleman@wczlaw.com>
> *Subject:* Re: Zeeman counterclaim
>
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> This is approved pending fixes to the addresses -
>
>  spoke to Sally - I'm ok with the mortgage not being fully listed
> correctly as Lucy said it hasn't been assigned.
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> On Thu, Jan 13, 2022 at 2:40 PM Sarah Zeeman <szeeman@gmail.com> wrote:
>
> Mortgage ATL owner (Brian Berman) said it should be the servicer MERS and
> it should be assigned to whomever the mortgage company is now.
>
> My payments are going to new rez, not mortgage a