Thu 13 Jan 2022 11 51 55 0500 Re Sweatman V. Zeeman Draft Of Counterclaim 17E545A6 2¶

If it helps - harassment/violation of sweatman putting items in my mailbox
- then emailing me 3/1/20 with the letter letting me know they entered my
mailbox.

attached.

they may not help.
 I'll be @ the office by 1215 to sign


On Thu, Jan 13, 2022 at 11:32 AM Sarah Zeeman <szeeman@gmail.com> wrote:

> 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
>>
>> View Bio <https://wczlaw.com/attorneys/chadd-l-reynolds/>
>>
>> *tel*
>>
>> *dir tel*
>>
>> 404.844.5700
>>
>> 404.844.5637
>>
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>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
>>
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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 - Draf