Fri 1 Apr 2022 21 13 57 0000 Re Zeeman Discovery 17Fe6Fa6 2¶

Sarah, I'm not concerned about the way drafted.

You hired an attorney to represent you after there was a disagreement regarding the location of the boundary.  That's the way I read it.

Am I good to finalize and send to Sweatman counsel?


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


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From: Sarah Zeeman <szeeman@gmail.com>
Sent: Friday, April 1, 2022 5:05 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

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


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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<mailto:szeeman@gmail.com>>
Sent: Friday, April 1, 2022 4:51 PM
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

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>>
S