Mon 10 Jan 2022 17 48 35 0500 Re Sarah Zeeman Legal Representation Wczlaw 17E462Dd 2¶

.


On Mon, Jan 10, 2022 at 5:19 PM Richard J. Capriola <rcapriola@wczlaw.com>
wrote:

> Sarah,
>
>                 I am not able to open the tickets.  Can you resend them as
> PDF?
>
yes

>
>
> We will prepare the counterclaim for your review on Wednesday.  I have
> copied my partner, Eric Coleman, who will work with me on your case.
>
>
>
> Have you notified your defense counsel that we have been engaged and to
> contact us to coordinate the filing of the counterclaim along with their
> answer? If not, is it ok if we contact them?
>
Yes. Lucy from swiftcurrie is sending her response now
 The other lawyer  (title) is being replaced

>
>
>
>
       Was the original fence maintained by you in any way after it was
>> installed by the builder?  yes - had a tree removed from growing under
>> it uploading footage & receipt of tree removal .What, if any
>> communications took place between you and Sweatman before he replaced the
>> fence? Yes Did he ask for approval? no he told me what he was doing a
>> few times - adding to dropbox   Did you object to it being moved other
>> than the police report?
>>
> no police report. Yes, May 2021  I told him it was my fence bc of adverse
> possession verbally from my deck in front of his wife that was recording
> me, and his landscaper was there. ( he akcnowledges i said  in a 6/25
> letter attached  *I did say they could tear i**t down weeks later*- the
> day they were tearing it down his helper guy let me know
> concealed/carried - I never said they could move 3 feet in
>

Uploading all of his demands and letters to dropbox now

> [image: mail letter 06252021 pg 2.jpg][image: mail letter 06252021 pg
> 1.jpg]
>
> Rich
>
>
>
>
>
> <http://www.wczlaw.net/>
>
>
>
> ------------------------------
>
> *Rich Capriola*
>
>
>
> Winter Capriola Zenner, LLC
>
> One Ameris Center
> 3490 Piedmont Road NE, Suite 800
> <https://www.google.com/maps/search/3490+Piedmont+Road+NE,+Suite+800+%0D%0AAtlanta,+GA+30305?entry=gmail&source=g>
> Atlanta, GA 30305
> <https://www.google.com/maps/search/3490+Piedmont+Road+NE,+Suite+800+%0D%0AAtlanta,+GA+30305?entry=gmail&source=g>
> www.wczlaw.com
>
> rcapriola@wczlaw.com
>
> View Bio <https://wczlaw.com/attorneys/chadd-l-reynolds/>
>
> *tel*
>
> *dir tel*
>
> 404.844.5700
>
> 404.844.5637
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
> This communication (together with all attachments) may contain privileged
> or confidential information and its sender reserves and asserts all rights
> that may apply to it. If you are not the intended recipient or believe that
> you have received this communication in error, please do not print, copy,
> retransmit, disseminate or otherwise use the information. Also, please
> indicate to the sender that you have received this communication in error
> and delete the copy you received. Thank you.
>
> Tax Advice Disclosure: To ensure compliance with requirements imposed by
> the IRS under Circular 230, we inform you that any U.S. federal tax advice
> contained in this communication (including any attachments), unless
> otherwise specifically stated, was not intended or written to be used, and
> cannot be used, for the purpose of (1) avoiding penalties under the
> Internal Revenue Code or (2) promoting, marketing or recommending to
> another party any matters addressed herein.
>
>
>
>
>
> *From:* Sarah Zeeman <szeeman@gmail.com>
> *Sent:* Friday, January 7, 2022 4:42 PM
> *To:* Richard J. Capriola <rcapriola@wczlaw.com>
> *Cc:* Joanie J. Williams <jwilliams@wczlaw.com>; Jennifer Bent <
> jbent@wczlaw.com>
> *Subject:* Re: Sarah Zeeman - Legal Representation - wczlaw
>
>
>
>
>
> *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.*
>
>
>
> + Insurance
>
> ·  Stewart: <SCook@mmatllaw.com> <ttuttle@mmatllaw.com><
> bledermeier@mmatllaw.com>
>
> ·  Travelers: <Lucy.Aquino@swiftcurrie.com> <
> David.Atkinson@swiftcurrie.com>
>
>
>
>
>
> On Fri, Jan 7, 2022 at 4:31 PM Sarah Zeeman <szeeman@gmail.com> wrote:
>
> Payment completed.
> Uploaded items from the outline to dropbox.
> Additional info:
>
>    1. Added the 5 code violation tickets/ urls (semi-addressed by COB) to
>    the dropbox "paper page"
>    https://www.dropbox.com/scl/fi/pr0yqvy7htv8q4fwaongw/_-Code-Vio.paper?dl=0&rlkey=sld3xed05xyafsm8ppgfl3sm5
>
>
>    1. Added police reports cutting cables, trespassing, after-hours
>    construction etc + FOIAs
>
>
>    1. Municode link for 35% lot coverage in COB -
>    https://library.municode.com/ga/brookhaven/ordinances/code_of_ordinances?nodeId=1069777
>
>
>    1. MS Doctor report - https://prnt.sc/22grc41
>
>
>    1. I have hundreds of photos/videos - can be included if helpful
>
> Can we also add in these subjects if applicable for the counter:
>
> Mold & deck damage from mold, foundation/structure damage (engineer tbd),
> erosion, loss of use to the northeast side of property line  & backyard, etc
>
>
>
>
>
>
>
>
>
> On Fr