Fri 1 Apr 2022 16 34 04 0400 Re Zeeman Discovery 17Fe6D5C 2¶

edits attached

On Fri, Apr 1, 2022 at 4:06 PM Eric B. Coleman <ecoleman@wczlaw.com> wrote:

> I’ve added our objections and our portions related to the counterclaim.
>
>
>
> *From:* Sally L. Monico <SCook@mmatllaw.com>
> *Sent:* Friday, April 01, 2022 3:39 PM
> *To:* Sarah Zeeman <szeeman@gmail.com>
> *Cc:* Eric B. Coleman <ecoleman@wczlaw.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
>
>
>
>
>
> *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.*
>
>
>
> All, see attached final drafts of ROGS and RPDS for your review.
>
>
>
> Please review the track changes and comments.  Eric and I have discussed
> objections he will add to RPD responses.
>
>
>
> Sarah, I did my best to keep most of your voice/narrative responses but
> did remove certain portions which were non-responsive to the individual
> requests.  I also revised to make some of the terms used consistent
> throughout.
>
>
>
> Please review and let me know if we have your approval to finalize and
> produce to counsel for Sweatman.
>
>
>
>
>
> *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*
>
>
>
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>
> *From:* Sarah Zeeman <szeeman@gmail.com>
> *Sent:* Friday, April 1, 2022 3:06 PM
> *To:* Sally L. Monico <SCook@mmatllaw.com>
> *Cc:* Eric B. Coleman <ecoleman@wczlaw.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
>
>
>
> *Lights  should be july 16*
>
> The Sweatmans shined lights into windows of Zeeman’s property on multiple
> occurrences including, but not limited to December 26, 2020; July 16, 2021
> [SZ1] <#m_-1134075650376690420_m_3094825090642323918__msocom_1> ; and
> September 30, 2021, as
> ------------------------------
>
>  [SZ1] <#m_-1134075650376690420_m_3094825090642323918__msoanchor_1>July 16
>
>
>
> also - remove - *all 3  recordings. *
>
> *It's only in one or 2 of Linda's recordings*
>
> In addition, Sweatman will produce three audio recordings from Linda
> Abaray at
>
>
>
> On Fri, Apr 1, 2022 at 2:37 PM Sarah Zeeman <szeeman@gmail.com> wrote:
>
> yes -june 25
>
> https://prnt.sc/bWvOa7ejU3Qr
>
>
> https://www.dropbox.com/s/uibjotxogk4yqem/Sarah%20Zeeman%20Demand%20letter_communication%20Sweatman.pdf?dl=0
>
>
>
> On Fri, Apr 1, 2022 at 2:32 PM Sarah Zeeman <szeeman@gmail.com> wrote:
>
> I'm incorrect again - sorry - I got a certified letter in from them about
> the fence june 2021, let me see if any others
>
>
>
> On Fri, Apr 1, 2022 at 2:29 PM Sarah Zeeman <szeeman@gmail.com> wrote:
>
> did not hear from them again about just the fence part until August 2021
>
>
>
> On Fri, Apr 1, 2022 at 2:24 PM Sarah Zeeman <szeeman@gmail.com> wrote:
>
> additional Fence -convos in march 2021 - I couldn't remember exactly but
> this clears it up some -  I went ahead and did apply during this time frame
> but didn't submit all the items yet for the permit as it wasn't fully
> decided on the vendor/design but wanted to get the process started moving
> with COB.
>
>
>
> After this email, exchange I did not hear from them until August 2021
>
>
>
> On Fri, Apr 1, 2022 at 1:45 PM Sally L. Monico <SCook@mmatllaw.com> wrote:
>
> Got it, I will run with this draft and circulate a final copy shortly.
>
>
>
>
>
> *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 r