Fri 18 Feb 2022 20 57 02 0000 Fw Zeeman Counterclaim 17F0E9Ff 2¶

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.

Thanks
Rich




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Rich Capriola


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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,

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.

A few questions:


  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?

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.

Thanks and have a great weekend.


Sally Monico
11625 Rainwater Drive | Ste. 125 | Alpharetta, Georgia 30009
Direct:  404.365.4506
Main: 404.266.9171
smonico@mmatllaw.com<mailto:smonico@mmatllaw.com> *PLEASE NOTE MY NEW EMAIL ADDRESS


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From: Sarah Zeeman <szeeman@gmail.com<mailto:szeeman@gmail.com>>
Sent: Thursday, January 13, 2022 2:50 PM
To: Sally L. Monico <SCook@mmatllaw.com<mailto:SCook@mmatllaw.com>>
Cc: Richard J. Capriola <rcapriola@wczlaw.com<mailto:rcapriola@wczlaw.com>>; Lucy Aquino <Lucy.Aquino@swiftcurrie.com<mailto:Lucy.Aquino@swiftcurrie.com>>; Tania Tuttle <ttuttle@mmatllaw.com<mailto:ttuttle@mmatllaw.com>>; Eric B. Coleman <ecoleman@wczlaw.com<mailto:ecoleman@wczlaw.com>>
Subject: Re: Zeeman counterclaim

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.

On Thu, Jan 13, 2022 at 2:40 PM Sarah Zeeman <szeeman@gmail.com<mailto: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 atlanta.

On Thu, Jan 13, 2022 at 2:13 PM Sarah Zeeman <szeeman@gmail.com<mailto:szeeman@gmail.com>> wrote:
Mortgage atl was the broker in 2015- I but a call into him to confirm etc,

On Thu, Jan 13, 2022 at 2:05 PM Sally L. Monico <SCook@mmatllaw.com<mailto:SCook@mmatllaw.com>> wrote:
Sarah, attached is the most recent recorded security deed on the property.  I just checked GSCCCA and it has n