Thu 14 Apr 2022 22 04 14 0000 Re External Re Is There A Survey Date Confirmed Yet 1802A1B1 2¶

Sarah – its what needs to happen with the lawsuit pending. Its not an admission of anything and does not effect your counterclaims.  It is a courtesy only and is to prevent them from calling the cops due to their claims.  If we didn’t give them notice and they brought the fact that we knew that your HVAC guys were going to be likely stepping on property that was theirs (not the disputed property but their undisputed property due to the close proximity of the units even if the line is where you contend), the Court would come down on us.   It is not an admission in any way.  We don’t need the Court to have an impression of you doing things to expand the litigation.  Now, if they cause any problems and we gave them the heads up, its them that are expanding things.   While this is standard and understood and communications between counsel aren’t evidence, we are happy to go back and state that this notice is for courtesy purposes only if it eases any of your concerns.

Also Sarah – please be aware that any emails that copy Amy and us on the same email are discoverable.  It is why we try to send emails separately as much as possible.

Thanks, Tania

Tania R. Tuttle
Partner, Real Estate Litigation

11625 Rainwater Drive  |  Ste 125   |   Alpharetta, Ga 30009
Main:    770-200-7000
Direct:  404.365.4575
ttuttle@mmatllaw.com<mailto:ttuttle@mmatllaw.com>
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From: Sarah Zeeman <szeeman@gmail.com>
Sent: Thursday, April 14, 2022 5:55 PM
To: Sally L. Monico <SCook@mmatllaw.com>
Cc: Amy Azza <Amy.Azza@stewart.com>; Brett Ledermeier <bledermeier@mmatllaw.com>; Tania Tuttle <ttuttle@mmatllaw.com>
Subject: Re: [External] Re: Is there a survey date confirmed yet?

Im not a lawyer but I don’t think  that was a good  idea by emailing Lisa rose, that contradicted my counter suit,



On Thu, Apr 14, 2022 at 5:18 PM Sarah Zeeman <szeeman@gmail.com<mailto:szeeman@gmail.com>> wrote:
Can you send me the email you sent to my other attorneys? I’ll be charged  for your emails etc



On Thu, Apr 14, 2022 at 3:39 PM Sally L. Monico <SCook@mmatllaw.com<mailto:SCook@mmatllaw.com>> wrote:
I contacted Lisa and gave her the heads up.

I copied Rich and Eric on the email so they are in the loop.

Sent from my iPhone

Pardon any typos.

On Apr 14, 2022, at 3:26 PM, Sarah Zeeman <szeeman@gmail.com<mailto:szeeman@gmail.com>> wrote:

Ok. Before I do, Sally - did you already contact rose law ? so I can be correct when  speak to him?



On Thu, Apr 14, 2022 at 3:23 PM Amy Azza <Amy.Azza@stewart.com<mailto:Amy.Azza@stewart.com>> wrote:
Sarah- please ask your personal attorney to advise on that.  Thank you.  Amy

Amy N. Azza
Claims Counsel
Stewart Title Guaranty Company
200 Fifth Avenue, Suite 301<https://www.google.com/maps/search/200+Fifth+Avenue,+Suite+301+%0D%0A+Waltham,+MA+02451?entry=gmail&source=g>
Waltham, MA<https://www.google.com/maps/search/200+Fifth+Avenue,+Suite+301+%0D%0A+Waltham,+MA+02451?entry=gmail&source=g>  02451<https://www.google.com/maps/search/200+Fifth+Avenue,+Suite+301+%0D%0A+Waltham,+MA+02451?entry=gmail&source=g>
O (781) 697-3327 | F (781) 697-3335
stewart.com<http://www.stewart.com/> | Amy.Azza@stewart.com<mailto:Amy.Azza@stewart.com>
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From: Sarah Zeeman <szeeman@gmail.com<mailto:szeeman@gmail.com>>
Sent: Thursday, April 14, 2022 11:24 AM
To: Sally L. Monico <SCook@mmatllaw.com<mailto:SCook@mmatllaw.com>>
Cc: Amy Azza <Amy.Azza@stewart.com<mailto:Amy.Azza@stewart.com>>; Brett Ledermeier <bledermeier@mmatllaw.com<mailto:bledermeier@mmatllaw.com>>; Tania Tuttle <ttuttle@mmatllaw.com<mailto:ttuttle@mmatllaw.com>>
Subject: [External] Re: Is there a survey date confirmed yet?

Ok.

Also My yearly hvac spring service is scheduled for the last Monday in April. Is it still ok for them to service the HVAC under the current circumstances?

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On Thu, Apr 14, 2022 at 11:21 AM Sally L. Monico <SCook@mmatllaw.com<mailto:SCook@mmatllaw.com>> wrote:
Sarah, the survey has been ordered.  The surveyor has not given us proposed dates.  I will follow up with him again.  I can promise you that we will not schedule anything when you are not available for work or otherwise.

Also, my maternity leave is set to