Fri 1 Apr 2022 16 39 14 0400 Re Zeeman Discovery 17Fe6Da8 2¶

also need to remove him thx

*RESPONSE TO INTERROGATORY NO. 3:*


3)    Dr. Doug Stuart. Neurologist at the MS Center of Atlanta.

a)     MS Center of Atlanta

b)    3200 Downwood Cir NW # 550, Atlanta, GA 30327

c)     (404) 351-0205
<https://www.google.com/search?client=safari&rls=en&q=MS+Center+of+Atlanta&ie=UTF-8&oe=UTF-8>



On Fri, Apr 1, 2022 at 4:34 PM Sarah Zeeman <szeeman@gmail.com> wrote:

> 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_3155613448647349217_m_-1134075650376690420_m_3094825090642323918__msocom_1>
>>  ; and September 30, 2021, as
>> ------------------------------
>>
>>  [SZ1]
>> <#m_3155613448647349217_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