Thu 9 Jun 2022 14 19 29 0400 Re Fw Discovery Closing In About 5 Weeks 18149B16 2¶

you can barely make it out in front of the bobcat- I can't find a clear shot


[image: UNADJUSTEDNONRAW_thumb_4952.jpg]


On Thu, Jun 9, 2022 at 1:38 PM Sarah Zeeman <szeeman@gmail.com> wrote:

> 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
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> [image: IMG_9612.jpg]
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> [image: UNADJUSTEDNONRAW_thumb_4004.jpg]
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> 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/>
>>
>>
>>
>> ------------------------------
>>
>> *Rich Capriola*
>>
>>
>>
>> Winter Capriola Zenner, LLC
>>
>> One Ameris Center
>> 3490 Piedmont Road NE, Suite 800
>> Atlanta, GA 30305
>> 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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>> This communication (together with all attachments) may contain privileged
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>> 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
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>> Internal Revenue Code or (2) promoting, marketing or recommending to
>> another party any matters addressed herein.
>>
>>
>>
>>
>>
>> *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
>>
>>
>>
>>
>>
>> *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.*
>>
>>
>>
>> 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
>>
>>
>>
>>
>>
>> <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. Willia