Re Zeeman Discovery 45¶

All, just following up on this.  



I am scheduled to begin maternity leave next week and was hoping to get on the same page regarding document production before I go out.  Eric/Rich, do you all have time for a call tomorrow or Friday to discuss?



On that subject, Brett Ledermeier in our offices, copied here, will be handling this matter while I am on leave.  Brett is up to speed and can jump in where needed.  I will also be providing Sarah with Brett's contact information.  



Thanks.  





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 that I will be on maternity leave starting April 15, 2022.  For assistance please contact Tania (ttuttle@mmatllaw.com <mailto:ttuttle@mmatllaw.com> ), Brett (bledermeier@mmatllaw.com <mailto:bledermeier@mmatllaw.com> ) or Darcy (ddefruscio@mmatllaw.com <mailto:ddefruscio@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: Sally L. Monico 
Sent: Thursday, April 7, 2022 9:23 AM
To: Eric B. Coleman <ecoleman@wczlaw.com>; Richard J. Capriola <rcapriola@wczlaw.com>; Lucy Aquino <Lucy.Aquino@swiftcurrie.com>
Cc: Tania Tuttle <ttuttle@mmatllaw.com>
Subject: Zeeman Discovery



Morning all,  I was planning on sending the verification to Lisa.  When I do I want to give her an update on the document production.  



We have reviewed the docs responsive to the RPDs related to the defense of the litigation as well as the numerous photos and videos.  I am happy to prepare those documents for production with appropriate labeling.  



Eric and Rich, how do you plan on producing documents related to counterclaims, i.e. COB emails, police reports?  I just want to make sure we are on the same page and have consistent production.  



Let me know if you want to jump on a call to discuss.  



Thanks.  



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





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-b9f1-2c8a9bf470a8/243c8c9e-f53a-465d-a79e-7181c8468474.