Re Zeeman Discovery 26¶

All, see attached final drafts of ROGS and RPDS for your review.  



Please review the track changes and comments.  Eric and I have discussed objections he will add to RPD responses.   



Sarah, I did my best to keep most of your voice/narrative responses but did remove certain portions which were non-responsive to the individual requests.  I also revised to make some of the terms used consistent throughout.  



Please review and let me know if we have your approval to finalize and produce to counsel for Sweatman.  





Sally Monico
11625 Rainwater Drive | Ste. 125 | Alpharetta, Georgia 30009
Direct:  404.365.4506

Main: 404.266.9171

smonico@mmatllaw.com <mailto:smonico@mmatllaw.com>  *PLEASE NOTE MY NEW EMAIL ADDRESS





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No attorney-client relationship exists by virtue of this communication in absence of an engagement letter or fee contract. In addition, unless you are in the To: or CC: line of this email, you are not an intended recipient. The information accompanying this email transmission may contain confidential or legally privileged information meant for ONLY the intended recipient. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution or reliance upon the contents of this email is strictly prohibited. If you receive this email in error, please delete this email and notify the sender immediately. 







From: Sarah Zeeman <szeeman@gmail.com> 
Sent: Friday, April 1, 2022 3:06 PM
To: Sally L. Monico <SCook@mmatllaw.com>
Cc: Eric B. Coleman <ecoleman@wczlaw.com>; Tania Tuttle <ttuttle@mmatllaw.com>; Lucy Aquino <Lucy.Aquino@swiftcurrie.com>; Richard J. Capriola <rcapriola@wczlaw.com>; Joanie J. Williams <jwilliams@wczlaw.com>
Subject: Re: Zeeman Discovery



Lights  should be july 16

The Sweatmans shined lights into windows of Zeeman's property on multiple occurrences including, but not limited to December 26, 2020; July 16, 2021[SZ1] ; and September 30, 2021, as

________________________________

 [SZ1]July 16



also - remove - all 3  recordings. 

It's only in one or 2 of Linda's recordings

In addition, Sweatman will produce three audio recordings from Linda Abaray at



On Fri, Apr 1, 2022 at 2:37 PM Sarah Zeeman <szeeman@gmail.com <mailto:szeeman@gmail.com> > wrote:

    yes -june 25 

    https://prnt.sc/bWvOa7ejU3Qr

    https://www.dropbox.com/s/uibjotxogk4yqem/Sarah%20Zeeman%20Demand%20letter_communication%20Sweatman.pdf?dl=0



    On Fri, Apr 1, 2022 at 2:32 PM Sarah Zeeman <szeeman@gmail.com <mailto:szeeman@gmail.com> > wrote:

        I'm incorrect again - sorry - I got a certified letter in from them about the fence june 2021, let me see if any others 



        On Fri, Apr 1, 2022 at 2:29 PM Sarah Zeeman <szeeman@gmail.com <mailto:szeeman@gmail.com> > wrote:

            did not hear from them again about just the fence part until August 2021



            On Fri, Apr 1, 2022 at 2:24 PM Sarah Zeeman <szeeman@gmail.com <mailto:szeeman@gmail.com> > wrote:

                additional Fence -convos in march 2021 - I couldn't remember exactly but this clears it up some -  I went ahead and did apply during this time frame but didn't submit all the items yet for the permit as it wasn't fully decided on the vendor/design but wanted to get the process started moving with COB.



                After this email, exchange I did not hear from them until August 2021



                On Fri, Apr 1, 2022 at 1:45 PM Sally L. Monico <SCook@mmatllaw.com <mailto:SCook@mmatllaw.com> > wrote:

                    Got it, I will run with this draft and circulate a final copy shortly.  





                    Sally Monico
                    11625 Rainwater Drive | Ste. 125 | Alpharetta, Georgia 30009
                    Direct:  404.365.4506

                    Main: 404.266.9171

                    smonico@mmatllaw.com <mailto:smonico@mmatllaw.com>  *PLEASE NOTE MY NEW EMAIL ADDRESS





                    CONFIDENTIALITY NOTICE
                    No attorney-client relationship exists by virtue of this communication in absence of an engagement letter or fee contract. In addition, unless you are in the To: or CC: line of this email, you are not an intended recipient. The information accompanying this email transmission may contain confidential or legally privileged information meant for ONLY the intended recipient. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution or reliance upon the contents of this email is strictly prohibited. If you receive this email in error, please delete this email and notify the sender immediately. 







                    From: Eric B. Coleman <ecoleman@wczlaw.com <mailto:ecoleman@wczlaw.com> > 
                    Sent: Friday, April 1, 2022 1:40 PM
                    To: Sally L. Monico <SCook@mmatllaw.com <mailto:SCook@mmatllaw.com> >; Sarah Zeeman <szeeman@gmail.com <mailto:szeeman@gmail.com> >
                    Cc: Tania Tuttle <ttuttle@mmatllaw.com <mailto:ttuttle@mmatllaw