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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
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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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