Thu 24 Mar 2022 19 21 04 0400 Re Zeeman Discovery Responses 17Fbe3Bc 2
| Field | Value |
| Category | Discovery > Written Discovery |
| Confidence | high |
| Reason | Email subject line explicitly references discovery responses |
| Original File | thu_24_mar_2022_19_21_04_-0400_re_zeeman_discovery_responses_17fbe3bc_2.eml |
| File Type | EML |
| Source | gmail-export |
thu_24_mar_2022_19_21_04_-0400_re_zeeman_discovery_responses_17fbe3bc_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 | Thu, 24 Mar 2022 19:21:04 -0400 |
Email Body
Is this ok for the 1st interrogatory draft or do I need to add more
specific details?
-will be adding text messages, 4 more individuals + COB & DeKalb, etc
McClung said they can do it in 3 weeks what is the eta date for Mark?
Having a surveyor drive from Ellijay instead of smryna is a lot.
I would like to add the sewer easement & two corner pins are missing from
COB construction, and the other 1 or 2 possibly have been altered - how
will the surveyor handle?
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*
>
>
>
>
>
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>
> Smokeball Reference:
> 5ab3d264-03bd-4ce8-b9f1-2c8a9bf470a8/2b97f939-2173-407d-859d-8c0750508aa2.
>
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