Fri 1 Apr 2022 14 57 22 0000 Re Zeeman Discovery 17Fe5A19 2¶

I’m sorry. I think that confused me. So you are using the term “jungle gym” facetiously I take it? What we are talking about is the wood beams installed around the HVAC for the fence?

From: Sarah Zeeman <szeeman@gmail.com>
Sent: Friday, April 01, 2022 10:54 AM
To: Eric B. Coleman <ecoleman@wczlaw.com>
Cc: Sally L. Monico <SCook@mmatllaw.com>; Tania Tuttle <ttuttle@mmatllaw.com>; Lucy Aquino <Lucy.Aquino@swiftcurrie.com>; Richard J. Capriola <rcapriola@wczlaw.com>; Joanie J. Williams <jwilliams@wczlaw.com>
Subject: Re: Zeeman Discovery



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Reading through it still.
There is no playset, I just refer to the wood beams he placed over an HVAC as a jungle gym.

In addition, Sweatman will produce three audio recordings from Linda at the City of Brookhaven that are responsive to this request.[EBC1]

•      Sorry for the confusion. Linda Abaray recordings are not fully about this request - one of them she states how she signed off on the unfinished sides of the fence line facing my property  - I think that works against me.

________________________________





On Fri, Apr 1, 2022 at 10:49 AM Eric B. Coleman <ecoleman@wczlaw.com<mailto:ecoleman@wczlaw.com>> wrote:
That would explain why I did not see them among the documents. That is no problem. We can respond that we are working on that and will update the response later.

There are a couple of other minor places where I think I need a little more input from you, Sarah. Otherwise, Sally and her team will work on polishing these responses and getting them to final today. We will update our portions as needed. Rich and I are both available today as needed.

From: Sarah Zeeman <szeeman@gmail.com<mailto:szeeman@gmail.com>>
Sent: Friday, April 01, 2022 10:46 AM
To: Eric B. Coleman <ecoleman@wczlaw.com<mailto:ecoleman@wczlaw.com>>
Cc: Sally L. Monico <SCook@mmatllaw.com<mailto:SCook@mmatllaw.com>>; 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>>; Joanie J. Williams <jwilliams@wczlaw.com<mailto:jwilliams@wczlaw.com>>
Subject: Re: Zeeman Discovery



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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<mailto: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<mailto:SCook@mmatllaw.com>>
Sent: Thursday, March 31, 2022 5:26 PM
To: Sarah Zeeman <szeeman@gmail.com<mailto:szeeman@gmail.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



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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
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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>>; L