Fri 1 Apr 2022 10 46 05 0400 Re Zeeman Discovery 17Fe5973 2¶

I don't have estimates, I haven't gotten the engineer report back yet to
schedule estimates.

On Fri, Apr 1, 2022 at 10:29 AM Eric B. Coleman <ecoleman@wczlaw.com> wrote:

> Here is my current working draft.
>
>
>
> We need to work on getting an itemization of damages pulled from the
> various estimates.
>
>
>
> *From:* Sally L. Monico <SCook@mmatllaw.com>
> *Sent:* Thursday, March 31, 2022 5:26 PM
> *To:* Sarah Zeeman <szeeman@gmail.com>
> *Cc:* Tania Tuttle <ttuttle@mmatllaw.com>; Lucy Aquino <
> Lucy.Aquino@swiftcurrie.com>; Richard J. Capriola <rcapriola@wczlaw.com>;
> Eric B. Coleman <ecoleman@wczlaw.com>; Joanie J. Williams <
> jwilliams@wczlaw.com>
> *Subject:* RE: Zeeman Discovery
>
>
>
>
>
> *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.*
>
>
>
> Hi Sarah,
>
>
>
> I am waiting for Eric and Rich’s revisions/additions to the prepared
> responses.  Once I have those I will put everything together and clean up
> the official responses for your final review.
>
>
>
>
>
> *Sally Monico*
> 11625 Rainwater Drive | Ste. 125 | Alpharetta, Georgia 30009
> Direct:  404.365.4506
>
> Main: 404.266.9171
>
> smonico@mmatllaw.com **PLEASE NOTE MY NEW EMAIL ADDRESS*
>
>
>
> CONFIDENTIALITY NOTICE
> No attorney-client relationship exists by virtue of this communication in
> absence of an engagement letter or fee contract. In addition, unless you
> are in the To: or CC: line of this email, you are not an intended
> recipient. The information accompanying this email transmission may
> contain confidential or legally privileged information meant for ONLY
> the intended recipient. If you are not the intended recipient, you
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> sender immediately.
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>
>
> *From:* Sarah Zeeman <szeeman@gmail.com>
> *Sent:* Thursday, March 31, 2022 5:17 PM
> *To:* Sally L. Monico <SCook@mmatllaw.com>
> *Cc:* Tania Tuttle <ttuttle@mmatllaw.com>; Lucy Aquino <
> Lucy.Aquino@swiftcurrie.com>; Richard J. Capriola <rcapriola@wczlaw.com>;
> Eric B. Coleman <ecoleman@wczlaw.com>; Joanie J. Williams <
> jwilliams@wczlaw.com>
> *Subject:* Re: Zeeman Discovery
>
>
>
> Hi all, Is there a time I should block out tomorrow?
>
>
>
> On Wed, Mar 30, 2022 at 1:17 PM Sally L. Monico <SCook@mmatllaw.com>
> wrote:
>
> Sarah, I am still waiting to hear from Chastain regarding final quote
> (with notation of sewer easement and issues outlined in your prior email)
> and dates for field work.  As Tania noted in the previous emails they are
> not the quickest but in our opinion they are the best when it comes to
> disputed matters which may require expert testimony.  I will be sure to let
> you know as soon as they provide me with proposed dates.  Your patience is
> appreciated.
>
>
>
>
>
> *Sally Monico*
> 11625 Rainwater Drive | Ste. 125 | Alpharetta, Georgia 30009
> Direct:  404.365.4506
>
> Main: 404.266.9171
>
> smonico@mmatllaw.com **PLEASE NOTE MY NEW EMAIL ADDRESS*
>
>
>
> CONFIDENTIALITY NOTICE
> No attorney-client relationship exists by virtue of this communication in
> absence of an engagement letter or fee contract. In addition, unless you
> are in the To: or CC: line of this email, you are not an intended
> recipient. The information accompanying this email transmission may
> contain confidential or legally privileged information meant for ONLY
> the intended recipient. If you are not the intended recipient, you
> are hereby notified that any disclosure, copying, distribution or
> reliance upon the contents of this email is strictly prohibited. If you
> receive this email in error, please delete this email and notify the
> sender immediately.
>
>
>
>
>
>
>
> *From:* Sarah Zeeman <szeeman@gmail.com>
> *Sent:* Wednesday, March 30, 2022 1:03 PM
> *To:* Sally L. Monico <SCook@mmatllaw.com>
> *Subject:* Re: Zeeman Discovery
>
>
>
> Hi
>
> Is the survey scheduled?
>
> I need to make sure I block off my calendar  so work  meetings do get
> scheduled in there
>
>
>
> On Wed, Mar 30, 2022 at 1:00 PM Sarah Zeeman <szeeman@gmail.com> wrote:
>
> +200 more photos are in process to be added in Dropbox
>
>
>
> On Wed, Mar 30, 2022 at 12:59 PM Sarah Zeeman <szeeman@gmail.com> wrote:
>
> Hi all - still working on uploading everything. Dropbox = not a fan of
> video,
>
>
>
> @rich I’ll be dropping by with the rest of the files/videotext messages
> hopefully this afternoon
>
>
>
> On Wed, Mar 30, 2022 at 12:57 PM Sally L. Monico <SCook@mmatllaw.com>
> wrote:
>
> Eric,
>
>
>
> Thanks for your call.  As we discussed, attached are our initial drafts of
> the responses to interrogatories and requests for production.  You will
> note our comments in the margins regarding which requests pertain to the
> defense of the case-in-chief vs. the counterc