Fri 1 Apr 2022 17 13 02 0400 Re Zeeman Discovery 17Fe6F97 2¶

also just making sure on this one that this is ok.-

 i said they can take down the fence and could be on the property to remove
the fence-...
but i did not give them the ok to come on my property to build a fence on
my property as shown by the guy with the shovel

1.     Workers trespassed and were shoveling cement on August 7th , 2021 –
video clip @ 16 seconds – produced by Zeeman in response to Request for
Production 12.


On Fri, Apr 1, 2022 at 5:05 PM Sarah Zeeman <szeeman@gmail.com> wrote:

> i hired the boundary lawyer right after the ultimatum- not before, does
> that matter?
>
> In early May 2021, Zeeman told Sweatman the land was hers through adverse
> possession and she hired a lawyer to represent her in the boundary line
> dispute. On August 7, 2021, Sweatman gave Zeeman an ultimatum
>
> On Fri, Apr 1, 2022 at 4:57 PM Sally L. Monico <SCook@mmatllaw.com> wrote:
>
>> Changes made.  Finals attached.
>>
>>
>>
>> Sarah with your agreement/approval I will resolve all comments and
>> finalize for submission.
>>
>>
>>
>> Thanks.
>>
>>
>>
>>
>>
>> *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
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>>
>>
>>
>>
>>
>> *From:* Sarah Zeeman <szeeman@gmail.com>
>> *Sent:* Friday, April 1, 2022 4:51 PM
>> *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
>>
>>
>>
>> *RESPONSE TO INTERROGATORY NO. 5:*
>>
>> Therefore, all windows were replaced in the same windowpane sills from
>> original construction except the four windows in the breakfast nook area
>> maintained the same sill outline of the four windows, and together they
>> became a single flat window for a less obstructed view of the backyard
>> including the ability to open at the bottom, all within the same sill
>> frame.                       By way of further answer, Zeeman refers
>> Petitioner to the non-privileged and relevant documents
>>
>>    - *The breakfast nook area with the 4 windows that became 1 large
>>    flat window doesn't open at the bottom*
>>    - *The garden window- the one he's suing over that one does open at
>>    the bottom*
>>
>>
>>
>> On Fri, Apr 1, 2022 at 4:39 PM Sarah Zeeman <szeeman@gmail.com> wrote:
>>
>> 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 an