Mon 21 Feb 2022 20 01 28 0000 Re Zeeman Discovery 17F1Ddff 2¶

We want the insurance defense lawyers to take the lead drafting the discovery responses so you don’t have to pay me for it.  I will review and discuss them with you.  But you can save some money if they take the lead drafting them.

I will bring up the need for the survey in our call with the insurance defense and ask them to fund it.

Please respond to the group with your availability Friday morning.

Rich




[cid:image001.jpg@01D82731.D61BDA60]<http://www.wczlaw.net/>

________________________________
Rich Capriola


Winter Capriola Zenner, LLC
One Ameris Center
3490 Piedmont Road NE, Suite 800
Atlanta, GA 30305
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tel
dir tel
404.844.5700
404.844.5637








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From: Sarah Zeeman <szeeman@gmail.com>
Sent: Monday, February 21, 2022 9:41 AM
To: Richard J. Capriola <rcapriola@wczlaw.com>
Subject: Re: Zeeman discovery



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I Would like you to take the lead & a real survey ordered( by title insurance ?).

Sweatman moved the pins/sticks this weekend  and I took more photos &recorded it.

What is the roles of them for the call?


[cid:image002.jpg@01D82731.D61BDA60]


On Mon, Feb 21, 2022 at 9:24 AM Richard J. Capriola <rcapriola@wczlaw.com<mailto:rcapriola@wczlaw.com>> wrote:
That works for me as well.




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________________________________
Rich Capriola

Winter Capriola Zenner, LLC
One Ameris Center
3490 Piedmont Road NE, Suite 800<https://www.google.com/maps/search/3490+Piedmont+Road+NE,+Suite+800+%0D%0AAtlanta,+GA+30305?entry=gmail&source=g>
Atlanta, GA 30305<https://www.google.com/maps/search/3490+Piedmont+Road+NE,+Suite+800+%0D%0AAtlanta,+GA+30305?entry=gmail&source=g>
www.wczlaw.com<http://www.wczlaw.com/>
rcapriola@wczlaw.com<mailto:rcapriola@wczlaw.com>
View Bio<https://wczlaw.com/attorneys/chadd-l-reynolds/>
tel
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404.844.5700
404.844.5637







This communication (together with all attachments) may contain privileged or confidential information and its sender reserves and asserts all rights that may apply to it. If you are not the intended recipient or believe that you have received this communication in error, please do not print, copy, retransmit, disseminate or otherwise use the information. Also, please indicate to the sender that you have received this communication in error and delete the copy you received. Thank you.
Tax Advice Disclosure: To ensure compliance with requirements imposed by the IRS under Circular 230, we inform you that any U.S. federal tax advice contained in this communication (including any attachments), unless otherwise specifically stated, was not intended or written to be used, and cannot be used, for the purpose of (1) avoiding penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any matters addressed herein.


From: Sally L. Monico <SCook@mmatllaw.com<mailto:SCook@mmatllaw.com>>
Sent: Monday, February 21, 2022 9:22 AM
To: Lucy Aquino <Lucy.Aquino@swiftcurrie.com<mailto:Lucy.Aquino@swiftcurrie.com>>; Richard J. Capriola <rcapriola@wczlaw.com<mailto:rcapriola@wczlaw.com>>
Cc: Tania Tuttle <ttuttle@mmatllaw.com<mailto:ttuttle@mmatllaw.com>>; Eric B. Coleman <ecoleman@wczlaw.com<mailto:ecoleman@wczlaw.com>>; Sarah Zeeman <szeeman@gmail.com<mailto:szeeman@gmail.com>>
Subject: RE: Zeeman discovery



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I can do anytime before 11 AM on Friday.


Sally Monico
11625 Rainwater Drive | Ste. 125 | Alpharetta, Georgia 30009<https://www.google.com/maps/search/11625