Re Sweatman V Zeeman 39¶

Brett:



            We already noticed Ms. Zeemans deposition after not receiving any response from you or Jeff on finalizing a specific date.  I believe the 21st should work.  That said, we still do not have the supplemental documents from Ms. Zeeman and no explanation for why they would not be produced.  Have you discussed producing these with Jeff?  We have emailed several times on this issue and prepared a motion to compel we planned on filing tomorrow. Thank you.



Timothy L. Mitchell
C: (810) 348-1942 





From: Brett Ledermeier <bledermeier@mmatllaw.com> 
Sent: Tuesday, June 13, 2023 4:45 PM
To: Timothy L. Mitchell <tmitchell@cmlawfirm.com>; Lisa Rose <lisa@roselitigation.lawyer>
Cc: Jeff Banks <jeffsbanks@hotmail.com>; Sarah Riedel <banksnriedel@hotmail.com>; Chelsea Cooke <ccooke@cmlawfirm.com>
Subject: RE: SWEATMAN V ZEEMAN



All, 



If we could keep all emails with all counsel copied, I would appreciate it. Are we planning on doing joint depositions of both parties? What are the current proposed dates? I saw that the engineer is available next week, June 21st in the afternoon. Does this work with all parties? Should we try to get deposition dates for both parties once the engineer report is back? Ideally, the engineer report puts us all in a position to review Lisas outlined settlement proposal and potentially resolve this without further expansion. 



Brett Michael-Schiff Ledermeier 
11625 Rainwater Drive  |  Ste 125   |   Alpharetta, Ga 30009
Direct:  404.365.4564

Main: 770.200.7000

bledermeier@mmatllaw.com <mailto:bledermeier@mmatllaw.com> 






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. 



From: Timothy L. Mitchell <tmitchell@cmlawfirm.com <mailto:tmitchell@cmlawfirm.com> > 
Sent: Friday, June 9, 2023 9:54 AM
To: Brett Ledermeier <bledermeier@mmatllaw.com <mailto:bledermeier@mmatllaw.com> >; Lisa Rose <lisa@roselitigation.lawyer <mailto:lisa@roselitigation.lawyer> >
Cc: Jeff Banks <jeffsbanks@hotmail.com <mailto:jeffsbanks@hotmail.com> >; Sarah Riedel <banksnriedel@hotmail.com <mailto:banksnriedel@hotmail.com> >; Chelsea Cooke <ccooke@cmlawfirm.com <mailto:ccooke@cmlawfirm.com> >
Subject: RE: SWEATMAN V ZEEMAN



All:



            Good morning.  We have not heard back from anyone regarding finalizing Ms. Zeemans deposition or setting the inspection, and did not receive any supplement of the outstanding responsive records by yesterdays deadline.  Please be advised we are moving ahead with noticing Ms. Zeemans deposition and will be filing a motion to compel for the outstanding documents next week and seeking fees in connection with the cost of having to file the motion.  Thank you.



Timothy L. Mitchell
C: (810) 348-1942 





From: Brett Ledermeier <bledermeier@mmatllaw.com <mailto:bledermeier@mmatllaw.com> > 
Sent: Wednesday, June 7, 2023 10:57 AM
To: Lisa Rose <lisa@roselitigation.lawyer <mailto:lisa@roselitigation.lawyer> >; Timothy L. Mitchell <tmitchell@cmlawfirm.com <mailto:tmitchell@cmlawfirm.com> >
Cc: Jeff Banks <jeffsbanks@hotmail.com <mailto:jeffsbanks@hotmail.com> >; Sarah Riedel <banksnriedel@hotmail.com <mailto:banksnriedel@hotmail.com> >; Chelsea Cooke <ccooke@cmlawfirm.com <mailto:ccooke@cmlawfirm.com> >
Subject: RE: SWEATMAN V ZEEMAN



Either work for me. Jeff  does that work for you? We really need all counsel given our limited retention. 



Brett Michael-Schiff Ledermeier 
11625 Rainwater Drive  |  Ste 125   |   Alpharetta, Ga 30009
Direct:  404.365.4564

Main: 770.200.7000

bledermeier@mmatllaw.com <mailto:bledermeier@mmatllaw.com> 






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. 



From: Lisa Rose <lisa@rosel