Fri 1 Apr 2022 20 57 07 0000 Re Zeeman Discovery 17Fe6Eaf 2¶

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


[cid:image001.jpg@01D845E9.62222110]
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 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>
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<mailto: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<mailto:szeeman@gmail.com>> wrote:
edits attached

On Fri, Apr 1, 2022 at 4:06 PM Eric B. Coleman <ecoleman@wczlaw.com<mailto:ecoleman@wczlaw.com>> wrote:
I've added our objections and our portions related to the counterclaim.

From: Sally L. Monico <SCook@mmatllaw.com<mailto:SCook@mmatllaw.com>>
Sent: Friday, April 01, 2022 3:39 PM
To: Sarah Zeeman <szeeman@gmail.com<mailto:szeeman@gmail.com>>
Cc: Eric B. Coleman <ecoleman@wczlaw.com<mailto:ecoleman@wczlaw.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



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


[cid:image001.jpg@01D845E9.62222110]
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 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@gm