Thu 13 Jan 2022 10 06 24 0500 Re Sweatman V. Zeeman Draft Of Counterclaim 17E53F9C 2¶

Have not coordinated with Lucy yet. I welcome adding her to this
communication.
Can come sign after a 1030 call - eta 11:20 am ish
Cameras adjusted, can remove altogether if needed.
Lucy's document has the NE missing  (6 occurrences) for the address.

[image: UNADJUSTEDNONRAW_thumb_54cc.jpg]
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On Thu, Jan 13, 2022 at 9:46 AM Richard J. Capriola <rcapriola@wczlaw.com>
wrote:

> Sara,
>
>
>
> We will revise to incorporate those of your comments needed at this
> stage.
>
>
>
> Did you make arrangements with Lucy to sign a verification?  If not, we
> will prepare and send it to you to sign before a notary.  If it is easier,
> you can come in and sign at my office.  The verification is a sworn
> attestation from you that the facts in the answer and counterclaim are true
> and accurate.  It is required to be filed with the answer in this context
> when responding to a verified complaint and when seeking injunctive relief
> in the counterclaim.
>
>
>
> Out of an abundance of caution, i would prefer that you reposition the
> camera facing the bay window.  Most of what it captures is his property.
> We don’t want to give him any arguments that you are doing what he is
> doing.  While I agree it is very different than a camera pointed at your
> window, it is best to not give them any grounds to draw a comparison.
>
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> <http://www.wczlaw.net/>
>
>
>
> ------------------------------
>
> *Rich Capriola*
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>
> Winter Capriola Zenner, LLC
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> Atlanta, GA 30305
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> *From:* Sarah Zeeman <szeeman@gmail.com>
> *Sent:* Thursday, January 13, 2022 7:05 AM
> *To:* Eric B. Coleman <ecoleman@wczlaw.com>
> *Cc:* Richard J. Capriola <rcapriola@wczlaw.com>
> *Subject:* Re: Sweatman v. Zeeman - Draft of Counterclaim
>
>
>
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> *CAUTION: This email originated from outside the organization. Do not
> click links or open attachments unless you recognize the sender and know
> the content is safe.*
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> Please add NE to the addresses:
>
>
>
> 2740 Grove Street NE
>
> 2746 Grove Street NE
>
>
>
> On Wed, Jan 12, 2022 at 6:43 PM Sarah Zeeman <szeeman@gmail.com> wrote:
>
> Topics:
>
> 1. The stress from all of this has impacted my health as I have Multiple
> Sclerosis, does the note in my medical records from my MS doctor help?
>
> 2. He put the drainage in a long time ago without the city's approval.
> I only found out in 2021 when he reinstalled it, and it became worse. Its
> been causing damaged since at least 2017 (I have photos). Should we mention
> there was damage before 2021 and the cause?
>
> 3. I have two outdoor cameras - one facing the window in the suit & one
> facing my back door. Attached is the view of window one - just making sure
> it is ok as the two are not pointing into his home.
>
> 4. In the camera section,  I'm forced to cover all my windows on the NE
> side to receive privacy with curtains and yoga mats, so no natural light is
> accessed
>
>
>
> If all topics/details listed are not needed at this time- I'm still
> good with this draft.
>
>
>
> Thank you,
>
> Sarah
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>
>
> On Wed, Jan 12, 2022 at 4:50 PM Eric B. Coleman <ecoleman@wczlaw.com>
> wrote:
>
> Ms. Zeeman:
>
>
>
> Attached is a draft of the Counterclaim that we have prepared on your
> behalf. Please let me know if you have any edits, questions, or comments.
>
>
>
>
>
> *Eric B. Coleman <http://www.wczlaw.net/attorneys/eric-coleman/>*
>
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