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Mon 28 Mar 2022 09 01 24 0400 Re Zeeman Discovery Responses 17Fd09De 2

Field Value
Category Discovery > Written Discovery
Confidence high
Reason Email subject line indicates discovery responses being addressed
Original File mon_28_mar_2022_09_01_24_-0400_re_zeeman_discovery_responses_17fd09de_2.eml
File Type EML
Source gmail-export
mon_28_mar_2022_09_01_24_-0400_re_zeeman_discovery_responses_17fd09de_2.eml

Email

Header Value
From Sarah Zeeman <szeeman@gmail.com>
To "Sally L. Monico" <SCook@mmatllaw.com>
CC Lucy Aquino <Lucy.Aquino@swiftcurrie.com>, "Richard J. Capriola" <rcapriola@wczlaw.com>, Tania Tuttle <ttuttle@mmatllaw.com>, Brett Ledermeier <bledermeier@mmatllaw.com>
Subject Re: Zeeman Discovery Responses
Date Mon, 28 Mar 2022 09:01:24 -0400
Email Body
3.28.22 Draft attached.
Things to note:

1. Rich - will drop off hard drive w/ 1500+
images/video/emails/tickets/foia/ all requested documents by EOD or
tomorrow.

I still owe:

   - 5 voice recording
   -  texts
   - confirmation on a few dates,
   -  add more documents to rpds
   - the remaining  material from COB (ORRs)


2. Some Pictures- you may have to press "command I" then click on the
Inspector part to where it is labeled TIFF to see the original creation
date and meta date. *White & brown dog pics, the dogs must be blurred out *-
they are live evidence to a DeKalb court case. (I’m their foster
through DCS)

[image: Screen Shot 2022-03-27 at 6.19.17 PM.png]

2. The Former Att box corner area, the engineer said this could be an
obstacle bc ATT left it at a higher elevation/bad drain - I included an ATT
file with photos emails, etc. this is the opposite rear corner from
Sweatman.

3. In the Dekalb ORRs the plans state for a much smaller HVAC was placed
there in 1993. But the former owner replaced the units with Lennox ones
that were bigger than the original builder units. I replaced those to the
same size as the Lenoxx ones

4.  I am 100% certain Sweatmans survey has been altered. Please have the
survey scheduled asap.

On Thu, Mar 24, 2022 at 6:00 PM Sally L. Monico <SCook@mmatllaw.com> wrote:

> All,
>
>
>
> Attached please find our initial draft of the responses to
> interrogatories.  Note I am working on draft of responses to requests for
> production, but I wanted to pass this along so Sarah and Rich can start
> filling things in.
>
>
>
> Sarah, I saw your email yesterday regarding scheduling survey.  I got an
> email from Mark yesterday with the scope of work as follows:
>
>
>
> *The scope of service for a boundary survey of this tract, under these
> circumstances, would include to show the property lines as well as the
> location of all improvements and any potential encroachments on the
> neighboring property.  *
>
>
>
> Do you have any questions about the scope of the survey or is there
> anything additional you would like us to add to the work order?  If you are
> in agreement with the scope of work I will contact Mark about scheduling a
> date to come out to the property.
>
>
>
> Thanks.
>
>
>
> *Sally Monico*
> 11625 Rainwater Drive | Ste. 125 | Alpharetta, Georgia 30009
> Direct:  404.365.4506
>
> Main: 404.266.9171
>
> smonico@mmatllaw.com **PLEASE NOTE MY NEW EMAIL ADDRESS*
>
>
>
>
>
> CONFIDENTIALITY NOTICE
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>
>
>
> Smokeball Reference:
> 5ab3d264-03bd-4ce8-b9f1-2c8a9bf470a8/2b97f939-2173-407d-859d-8c0750508aa2.
>

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