Thu 9 Jun 2022 13 38 30 0400 Re Fw Discovery Closing In About 5 Weeks 181498Bd 2¶

The whole left side- the grass could not grow on top of the buried cement-
he alluded to grass not growing on cement in his ultimatum video.
I'm trying to find  a clearer pic/video of the blocks


[image: IMG_9612.jpg]

[image: UNADJUSTEDNONRAW_thumb_4004.jpg]






On Thu, Jun 9, 2022 at 12:34 PM Richard J. Capriola <rcapriola@wczlaw.com>
wrote:

> Do you have a photos of the buried cement blocks?  I will refer to it to
> better define what we are talking about.
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> <http://www.wczlaw.net/>
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> ------------------------------
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> *Rich Capriola*
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> Winter Capriola Zenner, LLC
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> *From:* Sarah Zeeman <szeeman@gmail.com>
> *Sent:* Thursday, June 9, 2022 12:32 PM
> *To:* Richard J. Capriola <rcapriola@wczlaw.com>
> *Cc:* Joanie J. Williams <jwilliams@wczlaw.com>
> *Subject:* Re: FW: Discovery Closing in about 5 weeks
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> Ok. Go ahead and send.
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> Thank you.
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> On Thu, Jun 9, 2022 at 12:27 PM Richard J. Capriola <rcapriola@wczlaw.com>
> wrote:
>
> Sarah,
>
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> 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
>
>
>
>
>
>
>
>
>
>
>
>
>
>
>
> This communication (together with all attachments) may contain privileged
> or confidential information and its sender reserves and asserts all rights
> that may apply to it. If you are not the intended recipient or believe that
> you have received this communication in error, please do not print, copy,
> retransmit, disseminate or otherwise use the information. Also, please
> indicate to the sender that you have received this communication in error
> and delete the copy you received. Thank you.
>
> Tax Advice Disclosure: To ensure compliance with requirements imposed by
> the IRS under Circular 230, we inform you that any U.S. federal tax advice
> contained in this communication (including any attachments), unless
> otherwise specifically stated, was not intended or written to be used, and
> cannot be used, for the purpose of (1) avoiding penalties under the
> Internal Revenue Code or (2) promoting, marketing or recommending to
> another party any matters addressed herein.
>
>
>
>
>
> *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
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>
> Hi, I still have not received the survey. The engineers  need it todo
> their report. Am doubtful repair estimates will be returned w