Fri 1 Apr 2022 14 29 18 0000 Re Zeeman Discovery 17Fe587E 2¶

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



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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<mailto:smonico@mmatllaw.com> *PLEASE NOTE MY NEW EMAIL ADDRESS


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From: Sarah Zeeman <szeeman@gmail.com<mailto:szeeman@gmail.com>>
Sent: Thursday, March 31, 2022 5:17 PM
To: Sally L. Monico <SCook@mmatllaw.com<mailto:SCook@mmatllaw.com>>
Cc: Tania Tuttle <ttuttle@mmatllaw.com<mailto:ttuttle@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>>; Joanie J. Williams <jwilliams@wczlaw.com<mailto: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<mailto: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<mailto:smonico@mmatllaw.com> *PLEASE NOTE MY NEW EMAIL ADDRESS


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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<mailto:szeeman@gmail.com>>
Sent: Wednesday, March 30, 2022 1:03 PM
To: Sally L. Monico <SCook@mmatllaw.com<mailto: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<mailto: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<mailto: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<mailto: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 counterclaims.  We will take lead on