17Dda86C Gmail Mmatllaw.Com 2¶

Sarah szeeman@gmail.com

iy; Gmail Litigation with neighbor - title insurance retention 9 messages

Tania Tuttle ttuttle@mmatllaw.com

Mon, Dec 13, 2021 at 9:51 AM

To: "szeeman@gmail.com" szeeman@gmail.com

Cc: "Sally L. Monico" SCook@mmatllaw.com, Brett Ledermeier bledermeier@mmatllaw.com

Ms. Zeeman:

Stewart Title has retained us to represent you in the litigation filed by your neighbor. | have reviewed the complaint and it looks like we are fighting over tiny encroachments, if they even exist. Can you let us know what day you were served? We need to set up a time this week to chat — perhaps tomorrow or Wednesday? Also, | am sending you a message via our secure document system called Smokeball. Please upload any documents you have that are relevant to this dispute such as demand letters, prior communications with neighbor, etc.

We have worked with this attorney before. Unfortunately she does tend to bring lawsuit such as this but | am hopeful we can work to get this resolved without extended litigation.

| am copying my associates, Sally Monico and Brett Ledermeier, on this email. They will be working on this with me and you can always reach out to them as well as me.

Thanks, Tania

Tania R. Tuttle Partner, Real Estate Litigation

11625 Rainwater Drive | Ste 125 Main:

|

Alpharetta, Ga 30009

770-200-7000

Direct: 404.365.4575

ttuttle@mmatllaw.com

McLain |MERRITT 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.

Sarah Zeeman szeeman@gmail.com To: Tania Tuttle ttuttle@mmatllaw.com

Cc: "Sally L. Monico" SCook@mmatllaw.com, Brett Ledermeier bledermeier@mmatllaw.com

Mon, Dec 13, 2021 at 11:18 AM

Good morning,

| just received a response for an extension from Ms. Rose and | am available any time to chat. e

Rose emails

o https://drive.google.com/file/d/1MB65zJ4EoCCpZJ8wBWG_OIMZhW1 pZXEv/view?usp=sharing Affidavit from Rose

o https://drive.google.com/file/d/1 9jzRtEdQ-uvu1 PNZG-PpJTxXM705Kmlb/view?usp=sharing Served on Saturday, November 20th

o Video: https://drive.google.com/file/d/10CvhwktiNJlyk4lArY KqUhxWP6-SMmUd/view? usp=sharing Demand letters

o https://drive.google.com/file/d/1Gt5zDK4MawEmwXj5gQRCAHsSGx4nQGQW/d/view? usp=sharing Appraisal 2006 HVAC picture - the deck is original from the builder as well. o https://drive.google.com/file/d/1LtsYBSZZZivUPPNgNLWwbkYAgbngnV56/view?usp=sharing Sweatman's jungle gym over HVAC -

°o https://drive.google.com/file/d/11 GNC9VgjMdw-1Fp1j9E2eUENenB2BP3B/view?usp=sharing o -2x4s were just removed on 12/11/21 - not sure why...? 2746 Flooding on 2740

o https://drive.google.com/file/d/1 crmhj5FmycKYnzfV_tKY QopbIHO6dhhQ/view?usp=sharing o https://drive.google.com/file/d/1teyDfUppgBeNI7wG4Z1 JY 7-yVCkXjT Jt/view?usp=sharing [Quoted text hidden]

ar Gmail - Case_summons # (21CV9795). pdf 217K

Tania Tuttle ttuttle@mmatllaw.com

Mon, Dec 13, 2021 at 11:42 AM

To: Sarah Zeeman szeeman@gmail.com

Cc: "Sally L. Monico" SCook@mmatilaw.com, Brett Ledermeier bledermeier@mmatllaw.com

Sarah — thank you, this is fantastic. | so appreciate it. We will review everything.

So Lisa granted you an extension already? To what date?

Tania R. Tuttle Partner, Real Estate Litigation

11625 Rainwater Drive | Ste 125 Main:

|

Alpharetta, Ga 30009

770-200-7000

Direct: 404.365.4575 ttuttle@mmatllaw.com

McLain | MERRITT 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.

[Quoted text hidden]

Tania Tuttle ttutthe@mmatllaw.com

Mon, Dec 13, 2021 at 11:50 AM

To: Sarah Zeeman szeeman@gmail.com Cc: "Sally L. Monico" SCook@mmatllaw.com, Brett Ledermeier bledermeier@mmatllaw.com

OK never mind — | see in the email. Stewart believed the answer deadline was the 20" but it looks like she didn’t timely file the affidavit of service, which pushes your time to answer back. We will calendar the answer deadline for the 6th

Tania R. Tuttle Partner, Real Estate Litigation

11625 Rainwater Drive | Ste 125 Main:

|

Alpharetta, Ga 30009

770-200-7000

Direct: 404.365.4575 ttuttle@mmatllaw.com

McLain |MERRITT 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: Sarah Zeeman szeeman@gmail.com Sent: Monday, December 13, 2021 11:18 AM To: Tania Tuttle ttutthee@mmatllaw.com

Cc: Sally L. Monico SCook@mmatilaw.com; Brett Ledermeier bledermeier@mmatllaw.com Subject: Re: Litigation with neighbor- title insurance retention

Good morning, [Quoted text hidden] [Quoted text hidden]

Sarah Zeeman szeeman@gmail.com To: Tania Tuttle ttuttle@mmatllaw.com

Cc: "Sally L. Monico" SCook@mmatllaw.com, Brett Ledermeier bledermeier@mmatllaw.com Hi Tania, My apologies, as | am still a bit confused about the confirmed dates as | have not signed anything?

| was served the summons on 11/20 so Stewart was/is correct about the 20th date. Summons link: https://drive.google.com/file/d/1 XhhoEBt_M--9MEditIDI-eKBIxN4zv3Y/view?usp=sharing

Suit dates on the record with Dekalb county (to my knowledge)

Mon, Dec 13, 2021 at 4:17 PM

The suit filed: 11.12

Summons served: 11.20 Response to summons due 12.20 My Request- for additional 7 days to Rose law would make the date 12.27, Rose's email commentary stating: https://prnt.sc/ 22ufjfj - | never received a proposal to sign. From Ms. Rose's email today (12/13). Email screenshot: https://prnt.sc/22udpve

Case filed 12.7.22 Summons deadline 1.6.22 Deadline to answer 1.13.22 Not sure if this overrides her 12.7 email requiring signatures by both parties?

Additionally, there are a few caveats to this matter.

The survey Sweatman included in this suit, was not correctly obtained. It was ordered and paid for by my previous attorney Rick

Ablembick who breached the agreement while he left me off of email communications and updates as he removed my $ out of escrow without approval. My agreement with Ablembick listed Ablembick to confirm survey pricing and it never occurred- https://prnt.sc/22ui358

and _ https://prnt.sc/22ugz7g | learned they took my retainer to pay $850 (unapproved $ from retainer) and paid for the survey and scheduling btw Sweatman and Rick Rick Ablembick/Clif removed me from email correspondence beginning 8.23 sporadically until 9.7 and during that time frame Sweatman, the Survey company, and Rick organized and paid for the survey to be attained and provided to Sweatman against my request https://drive.google.com/file/d/1BRCHLOzuiT Q3BIQffS_Ka6wMh7MwJK3l/view? https://prnt.sc/22uxbnz - left me off of communication 9.7 | asked not to share a survey of my property https://prnt.sc/22uncml

9.10 Sweatman (unsolicited) called Rick for an 80-minute "chat" and Rick then sent me a

bill for their un approved chit-chat

9.13 Survey was given to Sweatman 9.20 Terminated Rick Ablembick

9.21 Started submitting code violation tickets to the City of Brookhaven 10.8 Stop-work order issued but! am still waiting for a resolution as the backyard and NE side yard is unsafe/unusable https://prnt.sc/22uvgl7 [Quoted text hidden]

Sarah Zeeman szeeman@gmail.com

Tue, Dec 14, 2021 at 8:01 AM

To: Tania Tuttle ttuttle@mmatllaw.com

Cc: Brett Ledermeier bledermeier@mmatllaw.com, "Sally L. Monico" SCook@mmatllaw.com Also, an additional question to my questions above about the report date. (Which | believe in the courts eyes is still the 20th) He removed the 4x4 wood surrounding my hvac but still has the orange stings over the unit. | have been able to have my winter hvac

service done on the units due to this area and crafts....Can | have my hvac out to go service my units as it needs to be done as their routine maintenance ? [Quoted text hidden]

Sally L. Monico SCook@mmatilaw.com

Tue, Dec 14, 2021 at 10:03 AM

To: Sarah Zeeman szeeman@gmail.com, Tania Tuttle ttuttle@mmatllaw.com Cc: Brett Ledermeier bledermeier@mmatllaw.com

Sarah, good talking to you.

As | mentioned we are still reviewing all the documents. Thanks for these by the way. To confirm, | checked the docket and the

affidavit of service of the complaint was not filed until December 7, 2021. Therefore, your answer is not due until January 6th

Please give us a few days to finish reviewing the documents and to formulate a strategy for litig