Thu 31 Mar 2022 17 17 00 0400 Re Zeeman Discovery 17Fe1D6B 2¶

Hi all, Is there a time I should block out tomorrow?

On Wed, Mar 30, 2022 at 1:17 PM Sally L. Monico <SCook@mmatllaw.com> wrote:

> Sarah, I am still waiting to hear from Chastain regarding final quote
> (with notation of sewer easement and issues outlined in your prior email)
> and dates for field work.  As Tania noted in the previous emails they are
> not the quickest but in our opinion they are the best when it comes to
> disputed matters which may require expert testimony.  I will be sure to let
> you know as soon as they provide me with proposed dates.  Your patience is
> appreciated.
>
>
>
>
>
> *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
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>
> *From:* Sarah Zeeman <szeeman@gmail.com>
> *Sent:* Wednesday, March 30, 2022 1:03 PM
> *To:* Sally L. Monico <SCook@mmatllaw.com>
> *Subject:* Re: Zeeman Discovery
>
>
>
> Hi
>
> Is the survey scheduled?
>
> I need to make sure I block off my calendar  so work  meetings do get
> scheduled in there
>
>
>
> On Wed, Mar 30, 2022 at 1:00 PM Sarah Zeeman <szeeman@gmail.com> wrote:
>
> +200 more photos are in process to be added in Dropbox
>
>
>
> On Wed, Mar 30, 2022 at 12:59 PM Sarah Zeeman <szeeman@gmail.com> wrote:
>
> Hi all - still working on uploading everything. Dropbox = not a fan of
> video,
>
>
>
> @rich I’ll be dropping by with the rest of the files/videotext messages
> hopefully this afternoon
>
>
>
> On Wed, Mar 30, 2022 at 12:57 PM Sally L. Monico <SCook@mmatllaw.com>
> wrote:
>
> Eric,
>
>
>
> Thanks for your call.  As we discussed, attached are our initial drafts of
> the responses to interrogatories and requests for production.  You will
> note our comments in the margins regarding which requests pertain to the
> defense of the case-in-chief vs. the counterclaims.  We will take lead on
> requests pertaining to defense of case-in-chief and will defer to you to
> handle finalizing/crafting responses to requests dealing with Ms. Zeeman’s
> counterclaims.
>
>
>
> Also attached is Ms. Zeeman’s notes/additions to our initial draft of
> responses to interrogatories.  Ms. Zeeman has done a nice job organizing
> the responses and the documents responsive to each RPD in the dropbox
> link.  We will be using Ms. Zeeman’s most recent draft as our master copy.
>
>
>
> I look forward to hearing from you once you’ve had a chance to review.
>
>
>
> Thanks.
>
>
>
>
>
> *Sally Monico*
> 11625 Rainwater Drive | Ste. 125 | Alpharetta, Georgia 30009
> <https://www.google.com/maps/search/11625+Rainwater+Drive+%7C+Ste.+125+%7C+Alpharetta,+Georgia+30009?entry=gmail&source=g>
> 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.
>
>
>
>
>
> Smokeball Reference:
> 5ab3d264-03bd-4ce8-b9f1-2c8a9bf470a8/386f76b2-6761-427a-a998-60dcbe9ab931.
>