Rpds To Sweatman¶

IN THE SUPERIOR COURT OF DEKALB COUNTY STATE OF GEORGIA

JONATHAN SWEATMAN,

Petitioner,

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V.

Civil Action File No. 21CV9795

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SARAH ZEEMAN,

Respondent.

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RESPONDENT?’S FIRST REQUEST FOR PRODUCTION TO PETITIONER

COME NOW Sarah Zeeman and, Respondent herein, and pursuant to O.C.G.A. §§ 9-11-

26 and 9-11-34, request that Petitioner Jonathan Sweatman (“you”) produce for inspection and/or copying the following documents which are in the possession, custody, or control of you or your counsel. 1.

Please produce all documents related to, identified by you, relied upon by you, or

otherwise referred to in your responses to Respondent’s First Interrogatories. 2.

Please produce all documents and things which will, or could be, used by you to support any claim set out in your Petition. 3.

Please produce all documents and things which will, or could be, used by you to support your calculation of damages in this civil action.

4.

Please produce all documents and things which will, or could be, used by you to support your defenses in this civil action.

5. To the extent not otherwise produced in response to the above requests, please produce all documents and electronically stored information of any kind which documents, references, or otherwise relates to any and all improvements or renovations which have been constructed upon

2746 Grove Street in the last three years. 6. To the extent not otherwise produced in response to the above requests, please produce all documents and electronically stored information of any kind which documents, references, or

otherwise relates to the lights and cameras referenced in Respondent’s Interrogatories (including receipts, estimates, and invoices for the purchase and/or installation of such lights and cameras). 7.

To the extent not otherwise produced in response to the above requests, please produce all video which you have ever recorded of 2740 Grove Street.

8. To the extent not otherwise produced in response to the above requests, please produce all documents and electronically stored information of any kind which documents, references, or

otherwise relates to the fences referenced in Respondent’s Interrogatories (including receipts, estimates, and invoices for the purchase and/or installation of such fences).

9. To the extent not otherwise produced in response to the above requests, please produce all documents and electronically stored information of any kind which documents, references, or

otherwise relates to the porch referenced in Respondent’s Interrogatories (including receipts, estimates, and invoices for the purchase and/or installation of such porch). 10.

To the extent not otherwise produced in response to the above requests, please produce all documents and electronically stored information of any kind which documents, references, or

otherwise relates to the deck referenced in Respondent’s Interrogatories (including receipts, estimates, and invoices for the purchase and/or installation of such deck). 11.

To the extent not otherwise produced in response to the above requests, please produce all documents and electronically stored information which documents, references, or relates to any and all communications of any kind (written, text message, emails or other documents) with any person or entity concerning or referencing any and all land disturbing activities which have

occurred upon 2746 Grove Street since the time you first acquired an interest therein. 12.

To the extent not otherwise produced in response to the above requests, please produce all documents and electronically stored information which documents, references, or relates to any and all communications of any kind (written, text message, emails or other documents) with any person or entity concerning or referencing any and all improvements or renovations which

have been constructed upon 2746 Grove Street in the last three years.

13.

To the extent not otherwise produced in response to the above requests, please produce all documents and electronically stored information which documents, references, or relates to any and all communications of any kind (written, text message, emails or other documents)

between you, or any person acting on your behalf, and Sarah Zeeman, or any person acting on her behalf) which is related to any issue involved in this litigation. 14.

To the extent not otherwise produced in response to the above requests, please produce all documents and electronically stored information which documents, references, or relates to any and all communications of any kind (written, text message, emails or other documents)

between you, or any person acting on your behalf, and any third-party which makes reference to Sarah Zeeman or 2740 Grove Street and which is related to any issue involved in this litigation.

15. Please produce any and all consultant, contractor, or engineering reports that address any issue related to this litigation.

16. To the extent not otherwise produced in response to the above requests, please produce any and all photographs, videos, or digital images in your custody, possession or control which depict any property, improvement, or renovation related to this litigation or which depict any party to this litigation.

17.

To the extent not otherwise produced in response to the above requests, please produce all documents and electronically stored information which sets out statements obtained from any person (written, oral, or recorded) concerning any aspect of this litigation. 18.

To the extent not otherwise produced in response to the above requests, please produce all documents or reports prepared as a result of any test, inspection, or measurement made or taken with respect to the properties located at 2740 and 2746 Grove Street. 19.

All other documents identified in your responses to Defendant’s First Interrogatories to Plaintiff or relied upon by you in preparing your interrogatory responses or responses to these requests for production.

This 8" day of June, 2022. SWIFT, CURRIE, McGHEE & HIERS, LLP /s/ Joseph G. Emanuel David M. Atkinson

Georgia Bar No. 026460 Joseph G. Emanuel

Georgia Bar No. 537196 Attorneys for Respondent Sarah Zeeman The Peachtree, Suite 300

Atlanta, GA 30309 Telephone: 404-874-8800

Facsimile: 404-888-6199 david.atkinson @swiftcurrie.com joseph.emanuel @swiftcurrie.com

4868-0555-7540, v. 1