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 |
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. (Iām 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.
>
Attachments¶
image001.jpg (image/jpeg, 4 KB)
Screen Shot 2022-03-27 at 6.19.17 PM.png (image/png, 1 MB)
- 22-03.18.22-Responses to ROGS sz edit 3.28.22.docx ā application/vnd.openxmlformats-officedocument.wordprocessingml.document, 88 KB
