Fri 15 Apr 2022 08 02 13 0400 Re 2Nd Notice Spring Maintenance Visit 1802D1A3 2¶

@ Eric & Rich
1. Please advise either to move forward or postpone the yearly HVAC service
2. Discovery document concerns - 2 voice recordings

a) Haight Davis engineer 3/17/22 - mentions his concerns about the former
ATT box corner being elevated causing water pooling + other issues.

b) 2740 Grove St recording 1/7/22 - (both have the same name & could get
confused)

Version 1 (44 min)  cut to end when COB left
Version 2 (46 min) includes a 2 min personal conversation after COB left &
don't want it to be shared with Sweatman.,


On Thu, Apr 14, 2022 at 7:55 PM Sally L. Monico <SCook@mmatllaw.com> wrote:

> Sarah, per your request and as a f/u to Tania’s email below, email to Lisa
> Rose, copying your private counsel and Lucy, attached.  You are not copied
> as including you would constitute a waiver of attorney client privilege.
>
>
>
> We are supposed to have a call with Eric Coleman, Rich’s partner, copied
> here, to discuss discovery document production tomorrow at 1:00 PM.
> However, we will postpone pending your conversation with Rich.
>
>
>
> Please have Rich or Eric reach out to us to coordinate next steps
> regarding discovery once you have had a chance to discuss.
>
>
>
> We will not take any further action until we hear from Rich and Eric.
>
>
>
>
>
> *Sally Monico*
> 11625 Rainwater Drive | Ste. 125 | Alpharetta, Georgia 30009
> Direct:  404.365.4506
>
> Main: 404.266.9171
>
> smonico@mmatllaw.com
>
>
>
> *Please note that I will be on maternity leave starting April 15, 2022.
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> (ddefruscio@mmatllaw.com <ddefruscio@mmatllaw.com>) and she will connect
> you with the individual assigned to your matter.  *
>
>
>
> *If you are in need of immediate assistance or in the event of emergency
> please contact Tania Tuttle (ttuttle@mmatllaw.com <ttuttle@mmatllaw.com>).
> *
>
>
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> *From:* Sarah Zeeman <szeeman@gmail.com>
> *Sent:* Thursday, April 14, 2022 7:34 PM
> *To:* Tania Tuttle <ttuttle@mmatllaw.com>
> *Cc:* Brett Ledermeier <bledermeier@mmatllaw.com>; Sally L. Monico <
> SCook@mmatllaw.com>
> *Subject:* Re: 2nd Notice! Spring - Maintenance Visit
>
>
>
> 1. Thank you. I will confirm with Rick tomorrow if it’s best to have the
> hvac service postponed etc. this is why I requested a copy of the email(if
> possible to have ) so I could add onto it asking Rick etc.
>
>
>
> 2. What is the next step now that the discovery questions were
> submitted/logged?
>
>
>
>
>
>
>
> On Thu, Apr 14, 2022 at 7:13 PM Tania Tuttle <ttuttle@mmatllaw.com> wrote:
>
> Sarah – the chances of HVAC professionals not accidently stepping onto the
> property of the Sweatmans is beyond slim in my opinion. Its just too narrow
> an area and even if they say they could, with tempers so high, I would
> never advise you to do that if you didn’t want to provide a heads up to
> protect you and your HVAC people.  You may just want to postpone the
> service and we can send an email stating to ignore our prior correspondence
> as to the same.  I don’t want to see this blow up and cause you more
> potential damages and fees.  If Lisa came back with any questions or
> concerns, I would tell you to call it off regardless.
>
>
>
> However, if you want them to come – which is totally fine - this was the
> way it should be handled. Sally and I discussed prior to her reaching out.
> I have had two decades of experience handling these types of matters and am
> not going to take any steps that put any of your claims at issue, whether
> covered or not.  It has absolutely no effect whatsoever on any claims or
> counterclaims. It is pure courtesy and done to avoid expansion of
> litigation and additional trespass claims in such a hotly contested
> matter.  Lets say, for example, the reverse happens and the Sweatmans
> crossed into your property without any sort of warning to us or okay by you
> (your property, not disputed property), you would likely have concerns and
> would call your attorneys and/or the cops.  The Sweatmans could do the same
> – and drag your HVAC guys in if they really wanted to be difficult.  I have
> a case with a fight in which this is exactly what happened because the
> other side (HOA) gave no heads up about entering my clients property to cut
> down a tree that fell on what they