Re Zeeman Survey Quotes 1¶

Amy, as an update on this matter we are helping prepare Ms. Zeemans responses to the Plaintiffs discovery requests.  



We helped draft the initial responses and have deferred to her private counsel as to those requests dealing with her counterclaims.  



Ms. Zeeman has provided over 1000+ photos of her property as well as files and files of documents and emails pertaining to her dispute with the neighbor.  Unfortunately many of the documents relating to the encroachments are intertwined with documents and photos related to her counterclaims but we are doing our best to divide the work of reviewing these documents with her private counsel.  



I am happy to share the dropbox link for her documents with you as well.  



I will provide copies of the discovery responses once finalized for your file.  



Have a great evening.  





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: Amy Azza <Amy.Azza@stewart.com> 
Sent: Tuesday, March 15, 2022 12:34 PM
To: Sally L. Monico <SCook@mmatllaw.com>
Cc: Tania Tuttle <ttuttle@mmatllaw.com>
Subject: RE: Zeeman Survey Quotes



Hi Sally,



Ok no problem! 



Amy N. Azza

Claims Counsel

Stewart Title Guaranty Company
200 Fifth Avenue, Suite 301

Waltham, MA  02451

O (781) 697-3327 | F (781) 697-3335
stewart.com <http://www.stewart.com/>  | Amy.Azza@stewart.com <mailto:Amy.Azza@stewart.com> 





From: Sally L. Monico <SCook@mmatllaw.com <mailto:SCook@mmatllaw.com> > 
Sent: Tuesday, March 15, 2022 12:32 PM
To: Amy Azza <Amy.Azza@stewart.com <mailto:Amy.Azza@stewart.com> >
Cc: Tania Tuttle <ttuttle@mmatllaw.com <mailto:ttuttle@mmatllaw.com> >
Subject: [External] RE: Zeeman Survey Quotes



Amy, 



I think the explanation regarding the survey should come from you as it gets into coverage.  Happy to discuss if you disagree.  





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: Amy Azza <Amy.Azza@stewart.com <mailto:Amy.Azza@stewart.com> > 
Sent: Tuesday, March 15, 2022 12:29 PM
To: Sally L. Monico <SCook@mmatllaw.com <mailto:SCook@mmatllaw.com> >
Cc: Tania Tuttle <ttuttle@mmatllaw.com <mailto:ttuttle@mmatllaw.com> >
Subject: RE: Zeeman Survey Quotes



Hi Sally,



I think we should use Chastain and Associates and I will leave it up to you to explain to Sarah about the underground improvements, etc.  ??  Thank you.  Amy



Amy N. Azza

Claims Counsel

Stewart Title Guaranty Company
200 Fifth Avenue, Suite 301

Waltham, MA  02451

O (781) 697-3327 | F (781) 697-3335
stewart.com <http://www.stewart.com/>  | Amy.Azza@stewart.com <mailto:Amy.Azza@stewart.com> 





From: Sally L. Monico <SCook@mmatllaw.com <mailto:SCook@mmatllaw.com> > 
Sent: Tuesday, March 15, 2022 11:56 AM
To: Amy Azza <Amy.Azza@stewart.com <mailto:Amy.Azza@stewart.com> >
Cc: Tania Tuttle <ttuttle@mmatllaw.com <mailto:ttuttle@mmatllaw.com> >
Subject: [External] Zeeman Survey Quotes



Amy, 



I have 2 survey quotes for you.  



Chastain and Associates

$1800

6-8 weeks 



Chastain and Associates is our go-to surveyor as they are thorough, communicative and have experience with contest surveys and litigation.  The price is much higher but this is the sur