Tue 8 Mar 2022 21 32 11 0000 Re Automatic Reply Survey Update Question 17F6B727 2¶

Hi Lucy.  is Plaintiff willing to grant an extension on the discovery requests?

Rich




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________________________________
Rich Capriola


Winter Capriola Zenner, LLC
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From: Sally L. Monico <SCook@mmatllaw.com>
Sent: Monday, March 7, 2022 11:10 AM
To: Sarah Zeeman <szeeman@gmail.com>; Lucy Aquino <Lucy.Aquino@swiftcurrie.com>; Richard J. Capriola <rcapriola@wczlaw.com>
Cc: Tania Tuttle <ttuttle@mmatllaw.com>
Subject: RE: Automatic reply: Survey update question



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Sarah,

I spoke with Stewart last week and relayed your request for a new survey and at this time we are not authorized to order a new survey.   If you have questions about the title company's determination please reach out to Amy Azza.   Her contact info is below.

Amy N. Azza
Claims Counsel
Stewart Title Guaranty Company
200 Fifth Avenue, Suite 301
Waltham, MA  02451
O (781) 697-3327 | F (781) 697-3335
stewart.com<http://www.stewart.com/> | Amy.Azza@stewart.com<mailto:Amy.Azza@stewart.com>
[cid:image005.jpg@01D8330A.0EA2A7E0]


After reviewing the plat (PB 96 Pg 14) and the survey obtained by your prior counsel the metes and bounds for your property appear to be consistent (within the margin of error) on the recent 2021 survey.  If you have concerns about pins being moved since September or have reason to call into question the survey obtained by your prior counsel then you are more than welcome to contact a surveyor to obtain a new survey.  We use/recommend Mark Chastain or Jeff McClung.

https://chastainassociates.com/

https://mcclungsurveying.com/

On the subject of discovery, Lucy, have you had a chance to contact Lisa Rose regarding an extension of time to response to the requests?

I am working on a draft/outline of the responses and will circulate for every ones review and contribution, hopefully before the end of the week.


Sally Monico
11625 Rainwater Drive | Ste. 125 | Alpharetta, Georgia 30009
Direct:  404.365.4506
Main: 404.266.9171
smonico@mmatllaw.com<mailto:smonico@mmatllaw.com> *PLEASE NOTE MY NEW EMAIL ADDRESS


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From: Sarah Zeeman <szeeman@gmail.com<mailto:szeeman@gmail.com>>
Sent: Saturday, March 5, 2022 12:02 PM
To: Lucy Aquino <Lucy.Aquino@swiftcurrie.com<mailto:Lucy.Aquino@swiftcurrie.com>>; Sally L. Monico <SCook@mmatllaw.com<mailto:SCook@mmatllaw.com>>
Subject: Fwd: Automatic reply: Survey update question

FYI

---------- Forwarded message ---------
From: Tania Tuttle <ttuttle@mmatllaw.com<mailto:ttuttle@mmatllaw.com>>
Date: Fri, Mar 4, 2022 at 3:16 PM
Subject: RE: Automatic reply: Survey update question
To: Sarah Zeeman <szeeman@gmail.com<mailto:szeeman@gmail.com>>, Brett Ledermeier <bledermeier@mmatllaw.com<mailto:bledermeier@mmatllaw.com>>, Darcy A. DeFruscio <ddefruscio@mmatllaw.com<mailto:ddefruscio@mmatllaw.com>>

I know that she was speaking to Stewart about it as its required on our end but, as for