Mon 10 Jan 2022 22 19 28 0000 Re Sarah Zeeman Legal Representation Wczlaw 17E46133 2¶

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

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?

                Was the original fence maintained by you in any way after it was installed by the builder?  What, if any communications took place between you and Sweatman before he replaced the fence?  Did he ask for approval?  Did you object to it being moved other than the police report?

Rich


[cid:image001.jpg@01D80645.3E7BA3F0]<http://www.wczlaw.net/>

________________________________
Rich Capriola


Winter Capriola Zenner, LLC
One Ameris Center
3490 Piedmont Road NE, Suite 800
Atlanta, GA 30305
www.wczlaw.com<http://www.wczlaw.com/>
rcapriola@wczlaw.com<mailto:rcapriola@wczlaw.com>
View Bio<https://wczlaw.com/attorneys/chadd-l-reynolds/>
tel
dir tel
404.844.5700
404.844.5637








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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



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+ Insurance
·  Stewart: <SCook@mmatllaw.com<mailto:SCook@mmatllaw.com>> <ttuttle@mmatllaw.com<mailto:ttuttle@mmatllaw.com>><bledermeier@mmatllaw.com<mailto:bledermeier@mmatllaw.com>>
·  Travelers: <Lucy.Aquino@swiftcurrie.com<mailto:Lucy.Aquino@swiftcurrie.com>> <David.Atkinson@swiftcurrie.com<mailto:David.Atkinson@swiftcurrie.com>>



On Fri, Jan 7, 2022 at 4:31 PM Sarah Zeeman <szeeman@gmail.com<mailto: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 Fri, Jan 7, 2022 at 3:29 PM Sarah Zeeman <szeeman@gmail.com<mailto:szeeman@gmail.com>> wrote:
Rich,
Thanks! No problem eta by 4pm.

On Fri, Jan 7, 2022 at 3:26 PM Richard J. Capriola <rcapriola@wczlaw.com<mailto:rcapriola@wczlaw.com>> wrote:
Sarah,

  *   The countersigned agreement is attached.
  *   I was able to access the timeline and links but is it slow and requires downloading each linked document individually.  If it is not too much trouble, please put them in Dropbox using the link below.
  *   The website is supposed to be back up, but if your troubles continue, please contact our office manager Jennifer Bent for assistance paying the retainer.

https://www.dropbox.com/sh/afrby06uuwwyezz/AAApV0K_YTQ3WwsPfXAQ6baka?dl=0


[cid:image001.jpg@01D80645.3E7BA3F0]<http://www.wczlaw.net/>

________________________________
Rich Capriola

Winter Capriola Zenner, LLC
One Ameris Center
3490 Piedmont Road NE, Suite 800
Atlanta, GA 30305
www.wczlaw.com<http://www.wczlaw.com/>
rcapriola@wczlaw.com<mailto:rcapriola@wczlaw.com>
View Bio<https://wczlaw.com/attorneys/chadd-l-reyno