Re Sweatman V. Zeeman Zeeman Discovery Responses Statutory Electronic Serviceeric B. Coleman Ecolemanwczlaw.Com 1¶

Lisa:



Thank you for taking my call today. To reiterate our conversation, here is what we have agreed to resolve the concerns raised in your 6.4 letter:



*   Ms. Zeeman will produce relevant medical records in accordance with your narrowed request. But before doing so, my client requests that a protective order be entered in this case that limits the use of her personal medical records to this case and prohibits any public unsealed filing of the same absent a court order. The records will be destroyed at the conclusion of this matter. My office will prepare that motion and proposed order. 
*   Ms. Zeeman will produce today, via the Dropbox link below, her responsive documents absent the medical records as discussed above. We both understood and agreed that to best of my knowledge, these have not yet been reviewed by my co-counsel in this matter. To that end, we have agreed that Ms. Zeeman shall have the right to claw back any objectional documents included in the link below.
*   Ms. Zeeman will reproduce the documents that we are turning over today as soon as possible with Bates labels. 



Please let me know if I am mistaken on any of the above. 



Here is the link to the responsive material with the caveats set forth above:

https://www.dropbox.com/sh/w6dn58khxureebd/AAA8rVx8b-8cM4ZS46h4hWaWa?dl=0



Have nice weekend.



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



direct:   404.844.5663

mobile: 678.975.0703



ecoleman@wczlaw.com <mailto:ecoleman@wczlaw.com> 

www.wczlaw.com <http://www.wczlaw.com/>  | view my bio <http://www.wczlaw.com/attorneys/eric-coleman/> 



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From: Lisa Rose <lisa@roselitigation.lawyer> 
Sent: Monday, May 09, 2022 4:04 PM
To: Tania Tuttle <ttuttle@mmatllaw.com>; Richard J. Capriola <rcapriola@wczlaw.com>; david.atkinson@swiftcurrie.com
Cc: Brett Ledermeier <bledermeier@mmatllaw.com>; Eric B. Coleman <ecoleman@wczlaw.com>; Joseph G. Emanuel <joseph.emanuel@swiftcurrie.com>
Subject: RE: Sweatman v. Zeeman; Zeeman Discovery Responses - Statutory Electronic ServiceEric B. Coleman <ecoleman@wczlaw.com>





    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. 



Counsel,

Please see the attached correspondence.

-Lisa







Lisa Rose
Rose Litigation, LLC


Mailing:   4880 Lower Roswell Rd. Ste 165-522 Marietta, GA 30068

Physical: 533 Johnson Ferry Road, Bld. D, Suite 400, Marietta, GA 30068
O: 678.806.8188 <tel:770.231.9783>   E: lisa@roselitigation.lawyer  <mailto:lisa@roselitigation.lawyer>  W: www.roselitigation.lawyer <http://www.roselitigation.lawyer/> 








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From: Lisa Rose 
Sent: Tuesday, May 3, 2022 9:38 AM
To: Tania Tuttle <ttuttle@mmatllaw.com <mailto:ttuttle@mmatllaw.com> >; Brett Ledermeier <bledermeier@mmatllaw.com <mailto:bledermeier@mmatllaw.com> >; Lucy Aquino <Lucy.Aquino@swiftcurrie.com <mailto:Lucy.Aquino@swiftcurrie.com> >; Richard J. Capriola <rcapriola@wczlaw.com <mailto:rcapriola@wczlaw.com> >; Eric B. Coleman <ecoleman@wczlaw.com <mailto:ecoleman@wczlaw.com> >
Subject: RE: Sweatman v. Zeeman; Zeeman Discovery Responses - Statutory Electronic Service



Counsel:



Good morning. Last week I sent a request for permission for my client and his contractor to gain temporary access to your clients property in an effort to preserve and protect the fence. In addition to the preservation of the fence, painting and staining the fence will enhance the aesthetics of the fence for your client.  In addition, I requested an update on the documents that were to be provided shortly after 4.1.22.



I have not heard back from anyone in response to both requests, other than Tanias email below.  Please provide an update on both items.



I am available to discuss the parameters around th