Thu 13 Jan 2022 16 06 58 0000 Re Sweatman V. Zeeman Draft Of Counterclaim 17E54316 2¶

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,

[cid:image005.png@01D8086D.9CE4AFC0]
Lucy Aquino<http://Lucy.Aquino@swiftcurrie.com/>
404.888.6202<tel:404.888.6202>
NOTICE:  This email message and all attachments may contain legally privileged and confidential information intended solely for the addressee.  If you are not an intended recipient, your receipt of this email and its attachments is the result of an inadvertent disclosure or unauthorized transmittal.  Sender reserves and asserts all rights to confidentiality, including all privileges that may apply.  Pursuant to those rights and privileges, you are hereby notified that you may not read, copy, distribute or otherwise use this message or its attachments. If you have received this message in error, please notify the sender by email and delete all copies of the message and the attachments immediately.  NO DUTIES ARE INTENDED OR CREATED BY THIS COMMUNICATION.  If you do not have a signed fee contract or engagement letter with this firm, this firm does NOT represent you as your attorney.​

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


[cid:image006.jpg@01D8086D.9CE4AFC0]<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







This communication (together with all attachments) may contain privileged or confidential information and its sender reserves and asserts all rights that may apply to it. If you are not the intended recipient or believe that you have received this communication in error, please do not print, copy, retransmit, disseminate or otherwise use the information. Also, please indicate to the sender that you have received this communication in error and delete the copy you received. Thank you.
Tax Advice Disclosure: To ensure compliance with requirements imposed by the IRS under Circular 230, we inform you that any U.S. federal tax advice contained in this communication (including any attachments), unless otherwise specifically stated, was not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any matters addressed herein.


From: Sarah Zeeman <szeeman@gmail.com<mailto:szeeman@gmail.com>>
Sent: Thursday, January 13, 2022 10:06 AM
To: Richard J. Capriola <rcapriola@wczlaw.com<mailto:rcapriola@wczlaw.com>>
Cc: Eric B. Coleman <ecoleman@wczlaw.com<mailto:ecoleman@wczlaw.com>>; Joanie J. Williams <jwilliams@wczlaw.com<mailto:jwilliams@wczlaw.com>>
Subject: Re: Sweatman v. Zeeman - Draft of Counterclaim



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.

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.

[cid:image002.jpg@01D8086D.AD7FA1F0]
.


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 commen