Thu 13 Jan 2022 15 56 06 0000 Re Sweatman V. Zeeman Draft Of Counterclaim 17E54275 2¶

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


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________________________________
Rich Capriola


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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 address.

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On Thu, Jan 13, 2022 at 9:46 AM Richard J. Capriola <rcapriola@wczlaw.com<mailto: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.




[cid:image001.jpg@01D80869.10D3BD90]<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<http://www.wczlaw.com/>
rcapriola@wczlaw.com<mailto: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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