Thu 2 Apr 2026 22 52 26 0000 Re External Drive Shipping Information For Client File Reque 19D5065E 2¶

Sarah,

I hope all is well. Opposing counsel (insurance counsel, not Lisa) has apparently instructed Lisa to seek assistance from the Court to finalize the settlement. Nothing has been filed or communicated to the Court, but I’d ask that you prioritize review of the proposed amended order with redlines from the City of Brookhaven and Lisa so that we can respond tomorrow if possible. We really want to avoid a motion to enforce/for sanctions which also puts us in a position where the Judge could enter sanctions. I can’t move this forward without your input and approval to respond to the redlines, so please let me know if you have any questions or if there is anything else I can do to assist.

Happy to jump on a call tomorrow.

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: Tuesday, March 24, 2026 12:32 PM
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 your response. I have noted your explanation regarding the packaging and handling of the device.

At this time, my focus is on completing a thorough review of the file materials that were recently provided on the drive I supplied. Additionally, the original digital access provided did not allow for efficient review, including the inability to download files in bulk and the lack of clear organization. I am actively working through these materials as part of my review.

As part of that process, I will be assessing completeness against prior requests, including items I requested from you in December 2025 that were not provided at that time, such as communications with the City of Brookhaven Attorney, Dekalb County, opposing counsel, the expeditor, and related correspondence.

I am not in a position to provide substantive responses or proceed on outstanding matters until I have completed my review and confirmed receipt of all requested materials.

Best,

Sarah

On Tue, Mar 24, 2026 at 11:53 AM Brett Ledermeier <bledermeier@mmatllaw.com<mailto:bledermeier@mmatllaw.com>> wrote:
Sarah,

The “box” it was delivered in was not even in an amazon or other retail box; it was in a bubble wrap bag just like we sent it in. I too was looking for instructions, but there were none. The only box was a thin cardboard and see-though plastic box that the shipping label was wrapped around and ripped the box trying to remove it. The device is not fragile – it’s solid plastic – and I went in-person to FedEx and asked them to package it to ensure it was safely delivered. If it is not in its original condition, what condition is it in?

As for handling client files, we always take the utmost care and precaution with all client files. We sent the digital copies before you sent the drive; the files were again organized and uploaded to the drive upon your request and mailed per your request.

With regard to use, I merely plugged it in and it appeared as a drive on my computer. That’s all that is required for use. I believe the user guide will be available under your purchase history if you go to the device page.

While I understand you are reviewing your file, the history of litigation is known by you personally and the settlement was read into the Court record near 2 years ago. We cannot continue to delay this. We represent you and secured the settlement you agreed to, with multiple counsel. Putting us in a position where we have no response to opposing counsel and the City of Brookhaven Attorney is both precarious and one that bars our ability to represent you. If you do not want me to go back and forth on the redlined version of both the settlement and the proposed amended order, then please have Jeff do it.

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:  40