Fri 3 Apr 2026 21 32 06 0000 Re External Drive Shipping Information For Client File Reque 19D5542C 2¶

Sarah,

With regard to the March Order, you have all documents. The Order stemmed from the hearing, which you were present for, wherein the Judge said that we needed to submit an order to the Court to approve the plat reconfiguration to avoid the variance process which was Gaddy’s proposal and agreed to by all parties at the hearing. The Judge, as you know, was quite frustrated at the delay from Gaddy on the survey and frustrated with all parties – she heavily monitored the case. When the Judge demanded the Order, it was delivered and only included what was already agreed upon at the hearing.

You were aware of the Order, as was your private counsel. With regard to “case closed”, I have explained that in length and provided the superior court rules regarding the same; this was not done by us or any other counsel – it was the Court. This case settled in May 2024 and remains outstanding due to the parties and any motion to enforce/motion for sanctions is not going to be well received by the Judge.

The City Attorney redlines does not include another case and we did not apply anything to it. It is ‘Proposed” and was redlined by the City Attorney – it is their “stamp” that says acknowledged and consented to which is what they need to include so the City can push the reconfiguration plat through for approval. Again, it’s a draft and nothing is entered. There are very few redlines and I am again asking that you please prioritize the review so a motion for sanctions against you isn’t filed.

We do not keep a “call log”. Is there any specific time period? Marimar is no longer with Stewart and we have a new claims contact that was just assigned; we speak with him on Monday. The bills themselves belong to Stewart and any call log would have to be created by going through the bills one by one which is an extremely time consuming task and would need to be approved by Stewart given the billable hours that would need to be spent. If there is a set time period, we can ask if we can create a basic call log for that period, but we still need permission to do so.

On the Plat, you did approve the final plat. The language on the front page was, to my knowledge, removed given your objections. Your approval was of the plat and the topography over the course of several months and meetings.

I want to highlight the fact that the settlement was read into the record of the Court in May 2024 and refusing to review or engage in productive conversations regarding the settlement to get it finalized is inhibiting our ability to represent you. If you prefer Jeff to finalize the document, please let me know and I can share the same with Stewart. Nothing has been done outside the scope of your agreed upon terms and all actions taken have been at your direction, agreement, and/or order of the Court.

In order to represent you, we need you to focus on the settlement and redlined proposed order. The alternative is the motion to enforce/motion for sanctions that will be filed against you and that is something we want to avoid. I am advising you to give substantive responses that we can share with opposing counsel so we can avoid Court involvement. If you are choosing not to follow advice of counsel, please confirm the same and I will stop bringing it up until directed otherwise.

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>


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From: Sarah Zeeman <szeeman@gmail.com>
Sent: Friday, April 3, 2026 11:37 AM
To: Brett Ledermeier <bledermeier@mmatllaw.com>
Cc: Tania Tuttle <ttuttle@mmatllaw.com>
Subject: Re: External Drive Shipping Information for Client file Request


Brett,

Thank you for the update.

I am continuing to review the documents and need a complete and accurate record before I can provide an informed response.

As I continue my review, please provide:

  *   A call log for all calls with all parties on this case, along with a summary of each call (date, participants, substance, and any representations made)
  *   Copies of all documents submitted or pr