Thu 13 Jan 2022 11 32 25 0500 Re Sweatman V. Zeeman Draft Of Counterclaim 17E5448C 2¶

Also - it's Brookhaven, Georgia now - but when purchased the property was
Atlanta,GA.

Wasn't sure if that needed to be consistent.


On Thu, Jan 13, 2022 at 11:07 AM Lucy Aquino <Lucy.Aquino@swiftcurrie.com>
wrote:

> Hi Richard,
>
>
>
> Yes, the verification is fine to sign. I’ll work on the changes to the
> Answer and send a final draft for review before filing.
>
>
>
> Thank you,
>
>
>
> *Lucy Aquino* <http://Lucy.Aquino@swiftcurrie.com/>
>
> 404.888.6202
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> *From:* Richard J. Capriola <rcapriola@wczlaw.com>
> *Sent:* Thursday, January 13, 2022 10:56 AM
> *To:* Sarah Zeeman <szeeman@gmail.com>; Lucy Aquino <
> Lucy.Aquino@swiftcurrie.com>
> *Cc:* Eric B. Coleman <ecoleman@wczlaw.com>; Joanie J. Williams <
> jwilliams@wczlaw.com>
> *Subject:* RE: Sweatman v. Zeeman - Draft of Counterclaim
>
>
>
> Sarah -  Attached is the Verified Counterclaim and the Verification Form.
> I added “NE” to the address in the counterclaim and modified paragraphs 13
> and 35 to discuss the increased flow of water prior to 2021. I added your
> personal injury claims to paragraphs 40, 47 and 52.  Please let me know if
> you have any other comments.  You can come by anytime to sign the
> verification.  Just give me a heads up when you head over.
>
>
>
> Lucy – please see Sarah’s comments below about the address and change the
> Answer to add “NE”.   Please review the attached verification and let us
> know if it is ok to have Sarah sign.  If so, she will come to my office,
> and I will send you a signed copy for you to file with the answer and
> counterclaim.  Please attach the counterclaim to the end of your Answer,
> change the title of the document to “Verified Answer and Counterclaim”, and
> file.
>
>
>
>  Note that we are seeking a declaratory ruling that Sarah owns not only
> the land taken by the movement of the fence, but also the property at issue
> in the Complaint (HVAC pads and window).
>
>
>
> Thanks
>
> Rich
>
>
>
>
>
> <http://www.wczlaw.net/>
>
>
>
> ------------------------------
>
> *Rich Capriola*
>
>
>
> Winter Capriola Zenner, LLC
>
> One Ameris Center
> 3490 Piedmont Road NE, Suite 800
> Atlanta, GA 30305
> www.wczlaw.com
>
> rcapriola@wczlaw.com
>
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> *From:* Sarah Zeeman <szeeman@gmail.com>
> *Sent:* Thursday, January 13, 2022 10:06 AM
> *To:* Richard J. Capriola <rcapriola@wczlaw.com>
> *Cc:* Eric B. Coleman <ecoleman@wczlaw.com>; Joanie J. Williams <
> jwilliams@wczlaw.com>
> *Subject:* Re: Sweatman v. Zeeman - Draft of Counterclaim
>
>
>
>
>
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> 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