Ms. Tuttle,
On January 28, 2026, I submitted a written request to Mr. Ledermeier for my
complete client file. I did not receive a response.
On February 13, 2026, you acknowledged my request and indicated the matter
would be reviewed. On February 21, 2026, I followed up. I was subsequently
advised that I would receive everything “this week.” As of the close of
business on Friday, February 27, 2026, no production has occurred and no
firm production date has been provided.
This email serves as a final request for production of my complete client
file.
Please confirm, no later than close of business Wednesday, March 4, 2026:
1.
The exact date and method of production; and
2.
That the production will include the complete electronic client file,
including but not limited to all emails, correspondence, pleadings, drafts,
internal notes, case management entries, and all plats, surveys, drawings,
CAD files, exhibits, and related materials in any version (including draft,
revised, redlined, submitted, or filed versions), as well as all
communications or documents exchanged with surveyors, expediters, the City,
Court, opposing counsel, or any third parties relating to my matter.
If I do not receive confirmation and full production within that timeframe,
I will pursue appropriate remedies to obtain my file.
Sincerely,
Sarah Zeeman