Fri 1 Apr 2022 17 05 17 0400 Re Zeeman Discovery 17Fe6F26 2¶

i hired the boundary lawyer right after the ultimatum- not before, does
that matter?

In early May 2021, Zeeman told Sweatman the land was hers through adverse
possession and she hired a lawyer to represent her in the boundary line
dispute. On August 7, 2021, Sweatman gave Zeeman an ultimatum

On Fri, Apr 1, 2022 at 4:57 PM Sally L. Monico <SCook@mmatllaw.com> wrote:

> Changes made.  Finals attached.
>
>
>
> Sarah with your agreement/approval I will resolve all comments and
> finalize for submission.
>
>
>
> 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*
>
>
>
> 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:* Friday, April 1, 2022 4:51 PM
> *To:* Eric B. Coleman <ecoleman@wczlaw.com>
> *Cc:* Sally L. Monico <SCook@mmatllaw.com>; Tania Tuttle <
> ttuttle@mmatllaw.com>; Lucy Aquino <Lucy.Aquino@swiftcurrie.com>; Richard
> J. Capriola <rcapriola@wczlaw.com>; Joanie J. Williams <
> jwilliams@wczlaw.com>
> *Subject:* Re: Zeeman Discovery
>
>
>
> *RESPONSE TO INTERROGATORY NO. 5:*
>
> Therefore, all windows were replaced in the same windowpane sills from
> original construction except the four windows in the breakfast nook area
> maintained the same sill outline of the four windows, and together they
> became a single flat window for a less obstructed view of the backyard
> including the ability to open at the bottom, all within the same sill
> frame.                       By way of further answer, Zeeman refers
> Petitioner to the non-privileged and relevant documents
>
>    - *The breakfast nook area with the 4 windows that became 1 large flat
>    window doesn't open at the bottom*
>    - *The garden window- the one he's suing over that one does open at
>    the bottom*
>
>
>
> On Fri, Apr 1, 2022 at 4:39 PM Sarah Zeeman <szeeman@gmail.com> wrote:
>
> also need to remove him thx
>
> *RESPONSE TO INTERROGATORY NO. 3:*
>
>
>
> 3)    Dr. Doug Stuart. Neurologist at the MS Center of Atlanta.
>
> a)     MS Center of Atlanta
>
> b)    3200 Downwood Cir NW # 550, Atlanta, GA 30327
>
> c)     (404) 351-0205
> <https://www.google.com/search?client=safari&rls=en&q=MS+Center+of+Atlanta&ie=UTF-8&oe=UTF-8>
>
>
>
>
>
> On Fri, Apr 1, 2022 at 4:34 PM Sarah Zeeman <szeeman@gmail.com> wrote:
>
> edits attached
>
>
>
> On Fri, Apr 1, 2022 at 4:06 PM Eric B. Coleman <ecoleman@wczlaw.com>
> wrote:
>
> I’ve added our objections and our portions related to the counterclaim.
>
>
>
> *From:* Sally L. Monico <SCook@mmatllaw.com>
> *Sent:* Friday, April 01, 2022 3:39 PM
> *To:* Sarah Zeeman <szeeman@gmail.com>
> *Cc:* Eric B. Coleman <ecoleman@wczlaw.com>; Tania Tuttle <
> ttuttle@mmatllaw.com>; Lucy Aquino <Lucy.Aquino@swiftcurrie.com>; Richard
> J. Capriola <rcapriola@wczlaw.com>; Joanie J. Williams <
> jwilliams@wczlaw.com>
> *Subject:* RE: Zeeman Discovery
>
>
>
>
>
> *CAUTION: This email originated from outside the organization. Do not
> click links or open attachments unless you recognize the sender and know
> the content is safe.*
>
>
>
> All, see attached final drafts of ROGS and RPDS for your review.
>
>
>
> Please review the track changes and comments.  Eric and I have discussed
> objections he will add to RPD responses.
>
>
>
> Sarah, I did my best to keep most of your voice/narrative responses but
> did remove certain portions which were non-responsive to the individual
> requests.  I also revised to make some of the terms used consistent
> throughout.
>
>
>
> Please review and let me know if we have your approval to finalize and
> produce to counsel for Sweatman.
>
>
>
>
>
> *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*
>
>
>
> 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 yo