Thu 9 Jun 2022 15 45 47 0400 Re Fw Discovery Closing In About 5 Weeks 1814A006 2¶

It probably won't help - but here is the google earth view of no grass
growing where the cement blocks were buried underground

On Thu, Jun 9, 2022 at 2:19 PM Sarah Zeeman <szeeman@gmail.com> wrote:

> 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
>>
>>
>> [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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>>> *Rich Capriola*
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>>>
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>>> Winter Capriola Zenner, LLC
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>>> *tel*
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>>> *dir tel*
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>>> 404.844.5700
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>>> 404.844.5637
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>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
>>>
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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
>>>
>>>
>>>
>>>
>>>
>>> *CAUTION: This email originated from outside the organization. Do not
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>>> 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 n