Re Zeeman Motion To Quash Subpoena For Review 2¶

Confirmed. 





Joe Emanuel <http://joseph.emanuel@swiftcurrie.com/> 

404.888.6231 <tel:404.888.6231> 

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From: Brett Ledermeier <bledermeier@mmatllaw.com> 
Sent: Wednesday, June 29, 2022 7:32 PM
To: Joseph G. Emanuel <joseph.emanuel@swiftcurrie.com>; Richard J. Capriola <rcapriola@wczlaw.com>; Tania Tuttle <ttuttle@mmatllaw.com>; Eric B. Coleman <ecoleman@wczlaw.com>; David Atkinson <David.Atkinson@swiftcurrie.com>
Cc: Darcy A. DeFruscio <ddefruscio@mmatllaw.com>
Subject: RE: Zeeman - Motion to Quash Subpoena for Review



Thanks Joe! Just to confirm then, the deposition next week will no longer take place?



Brett Michael-Schiff Ledermeier 
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From: Joseph G. Emanuel <joseph.emanuel@swiftcurrie.com <mailto:joseph.emanuel@swiftcurrie.com> > 
Sent: Wednesday, June 29, 2022 5:59 PM
To: Richard J. Capriola <rcapriola@wczlaw.com <mailto:rcapriola@wczlaw.com> >; Tania Tuttle <ttuttle@mmatllaw.com <mailto:ttuttle@mmatllaw.com> >; Eric B. Coleman <ecoleman@wczlaw.com <mailto:ecoleman@wczlaw.com> >; David Atkinson <David.Atkinson@swiftcurrie.com <mailto:David.Atkinson@swiftcurrie.com> >
Cc: Brett Ledermeier <bledermeier@mmatllaw.com <mailto:bledermeier@mmatllaw.com> >; Darcy A. DeFruscio <ddefruscio@mmatllaw.com <mailto:ddefruscio@mmatllaw.com> >
Subject: RE: Zeeman - Motion to Quash Subpoena for Review



Lisa Rose has agreed to a Consent Motion staying discovery pending mediation, followed by a 90 day extension to the discovery period. The stay would be in effect immediately and no depositions will be conducted prior to mediation. However, she will still be serving responses to my written discovery, subject only to a 3 week extension, prior to mediation. 



The mediator and available dates are still TBA.  Plaintiff has not agreed to any of the mediators we have suggested to date, and Sarah will not agree to Phil Bettis. Lisa told me that she thinks the mediator should have judicial experience and I mentioned Judge Forsling at miles with whom Ive had great success (including in stormwater runoff cases). 



Ill draft and circulate the proposed consent motion. 





Joe Emanuel <http://joseph.emanuel@swiftcurrie.com/> 

404.888.6231 <tel:404.888.6231> 

NOTICE:  This email message and all attachments may contain legally privileged and confidential information intended solely for the addressee.  If you are not an intended recipient, your receipt of this email and its attachments is the result of an inadvertent disclosure or unauthorized transmittal.  Sender reserves and asserts all rights to confidentiality, including all privileges that may apply.  Pursuant to those rights and privileges, you are hereby notified that you may not read, copy, distribute or otherwise use this message or its attachments. If you have received this message in error, please notify the sender by email and delete all copies of the message and the attachments immediately.  NO DUTIES ARE INTENDED OR CREATED BY THIS COMMUNICATION.  If you do not have a signed fee contract or engagement letter with this firm, this firm does NOT represent you as your attorney.??



From: Richard J. Capriola <rcapriola@wczlaw.com <mailto:rcapriola@wczlaw.com> > 
Sent: Fr