Mon 6 Apr 2026 16 37 34 0000 Re External Drive Shipping Information For Client File Reque 19D63A83 2¶

Sarah,

At the hearing, the Judge made it clear that the decision on a variance versus Court Order was reserved for Plaintiff as it was his property at issue with non-conformities. Once that decision was made, the Judge required an Order. The plat itself was already approved by you and only reflects what is actually on the land. The language on the first page, as indicated in my previous email, was not signed by either party and is not signed on the Order entered by the Court or the plat presumably submitted by Gaddy for approval. This was discussed in length and is standard, required language on any new plat; it was still submitted without signature per your request(s) over the course of several months.

As you are also aware, you had private counsel, home insurance counsel, and title insurance counsel. Our retention was limited in scope, which you are also aware, and included only title matters. You have received all pleadings and documents, timely, and were present at the hearings, zoom meetings, and plat reconfiguration meetings. Your engagement to finalize the settlement is required which includes responding, substantively, so that we can send your response. The terms of the settlement were already agreed upon in May 2024 so the requirements are limited to that scope and have been consistently delayed/refused/ignored despite numerous requests which is why I asked if you preferred your private counsel handle the remaining portions.

As for call logs, I outlined that we do not keep call log records, and that evidence of calls would require time-extensive creation from invoices which belong to Stewart and require advance permission. I asked if there was a limited period in time for call logs that you are seeking and, if so, we can request permission.

Finally, with regard to any contention that this was in any way mishandled or handled in a way that was not in your best interest, we disagree, respectfully. We have repeatedly requested information from you and/or given advice of counsel which has been objected to outright or not responded to in its entirety. There are periods of time where you only communicated with your private counsel, and we are not privy to your communications with other counsel. The settlement was further delayed on the zoom meeting with the City when you showed up with yet another new counsel, without notice, and alleged “code violations” and “other violations”, refusing to provide those alleged violations for more than six (6) months. The only redlines you responded to were with Jeff, your private counsel, and to the extent you did engage us as counsel, it was in regard to all matters discussed, whether in person, at a scheduled Court hearing, and/or expressed through private counsel. Our retention is only as to title and any concerns regarding water runoff or other matters is properly directed to your private counsel.

I would also like to note that the use of AI to create lists of alleged grievances and/or complaints with our counsel is, inherently, inaccurate which is disclaimed on AI sources. The entirety of the file was provided as your case progressed over the last, nearly five (5) years, and the entire case file was again provided, recently, in two different formats (via practice management and via external drive as requested).

If you have any further questions regarding the requisite steps to avoid a motion to compel/motion for sanctions (if that is even possible at this point), I would ask that you schedule a call to discuss this matter with both Jeff and I so that we can work collaboratively. Settled litigation should not be further protracted and I have outlined the risks/concerns stemming from these actions. There can be no documentation that bears any weight on the settlement terms read into the record on May 2024 as they are enforceable and have not been complied with over the last, nearly, two (2) years. This needs to be addressed and rectified; we thank you in advance for the same.

Enjoy your day.

Brett Michael-Schiff Ledermeier
Senior Associate, Real Estate Litigation

Mailing:  850 Windy Hill Road | Unit 1762 | Smyrna, GA 30081
11625 Rainwater Drive  |  Ste 125   |   Alpharetta, Ga 30009
Direct:  404.365.4564
Main: 770.200.7000
bledermeier@mmatllaw.com<mailto:bledermeier@mmatllaw.com>


[cid:image001.jpg@01DCC5BF.53E982F0]


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 dele