Thu 13 Jan 2022 14 46 39 0000 Re Sweatman V. Zeeman Draft Of Counterclaim 17E53E7B 2¶

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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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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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<mailto: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



On Wed, Jan 12, 2022 at 4:50 PM Eric B. Coleman <ecoleman@wczlaw.com<mailto: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/>
Attorney at Law
Partner

One Ameris Center
3490 Piedmont Road NE | Suite 800
Atlanta, Georgia 30305

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mobile: 678.975.0703

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