Thu 9 Jun 2022 12 32 18 0400 Re Fw Discovery Closing In About 5 Weeks 181494F3 2¶

Ok. Go ahead and send.
Thank you.

On Thu, Jun 9, 2022 at 12:27 PM Richard J. Capriola <rcapriola@wczlaw.com>
wrote:

> Sarah,
>
>
>
> I will prepare and serve a second set of discovery to address some of your
> questions below and serve them today.  Please send any additional requests
> ASAP.  We will have 7 hours to ask him questions under oath so not
> everything needs to be asked in the interrogatories.  It is more important
> to get all of his documents.
>
>
>
> Rich
>
>
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> <http://www.wczlaw.net/>
>
>
>
> ------------------------------
>
> *Rich Capriola*
>
>
>
> Winter Capriola Zenner, LLC
>
> One Ameris Center
> 3490 Piedmont Road NE, Suite 800
> <https://www.google.com/maps/search/3490+Piedmont+Road+NE,+Suite+800+%0D%0AAtlanta,+GA+30305?entry=gmail&source=g>
> Atlanta, GA 30305
> <https://www.google.com/maps/search/3490+Piedmont+Road+NE,+Suite+800+%0D%0AAtlanta,+GA+30305?entry=gmail&source=g>
> www.wczlaw.com
>
> rcapriola@wczlaw.com
>
> View Bio <https://wczlaw.com/attorneys/chadd-l-reynolds/>
>
> *tel*
>
> *dir tel*
>
> 404.844.5700
>
> 404.844.5637
>
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> *From:* Sarah Zeeman <szeeman@gmail.com>
> *Sent:* Wednesday, June 8, 2022 3:46 PM
> *To:* Richard J. Capriola <rcapriola@wczlaw.com>
> *Cc:* Joanie J. Williams <jwilliams@wczlaw.com>
> *Subject:* Re: FW: Discovery Closing in about 5 weeks
>
>
>
>
>
> *CAUTION: This email originated from outside the organization. Do not
> click links or open attachments unless you recognize the sender and know
> the content is safe.*
>
>
>
> Hi, I still have not received the survey. The engineers  need it todo
> their report. Am doubtful repair estimates will be returned within 5 weeks,
> even if I got the survey/engineer reports today??
>
>
>
> Since I am paying for it- I would like for the legal mitigation person
> have construction law experience.
>
>
>
> The ROS signature page  is  incorrect  & lists: "Attorneys for Defendants
> Jane Glover Hawkins and
>
> Hawkins-Glover Properties, LLC
>
>
>
> I have several more things to add, and will do shortly
>
>
>
>    1. Request: Elevation differences before/after regrading & fill dirt
>    amount added? His Backyard & area between the homes were both
>     regraded to angle water flows into my yard/house foundation.
>    2. Request: Documentation showing plans/approval for 3rd set of stairs
>    within the sewer easement & when factored what is the real total % of
>    impervious surface? He added the 3rd set of cement stairs. never been on
>    any plan and has remained there entire time & never factored into the
>    impervious surface #s .
>    3. Request:   # 11 - Dates of when the *extra large &
>    buried underground patio size cement blocks* were initially buried
>    covered and then dug up in 2021
>    4.  Request: Documentation of what property of his is currently within
>    10 feet of DeKalb's sanitary sewer easement
>    5. (prob cant ask)Request: Documentation showing how "he openly
>    disclosed the sewer easement"  during the variance hearing allowing for a
>    variance to be awarded on top of the Dekalb sanitary sewer easement
>
>
>
> On Wed, Jun 8, 2022 at 11:59 AM Richard J. Capriola <rcapriola@wczlaw.com>
> wrote:
>
> Sarah,
>
>                 Please review the email below and the attached and let me
> know if you have any thoughts for additional documents to request from
> plaintiff or questions to ask.  We will have plenty of time in a deposition
> to ask may more questions so your primary focus should be on the
> documents.  If you have more ideas, we can serve a second set of discovery
> if issued in the next few days.
>
>
>
>
>
>
>
>
>
> <http://www.wczlaw.net/>
>
>
>
> ------------------------------
>
> *Rich Capriola*
>
>
>
> Winter Capriola Zenner, LLC
>
> One Ameris Center
> 3490 Piedmont Road NE, Suite 800
> <https://www.google.com/maps/search/3490+Piedmont+Road+NE,+Suite+800+%0D%0AAtlanta,+GA+30305?entry=gmail&source=g>
> Atlanta, GA 30305
> <https://www.google.com/maps