Thu 9 Jun 2022 16 27 11 0000 Re Fw Discovery Closing In About 5 Weeks 181494A9 2¶

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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________________________________
Rich Capriola


Winter Capriola Zenner, LLC
One Ameris Center
3490 Piedmont Road NE, Suite 800
Atlanta, GA 30305
www.wczlaw.com<http://www.wczlaw.com/>
rcapriola@wczlaw.com<mailto:rcapriola@wczlaw.com>
View Bio<https://wczlaw.com/attorneys/chadd-l-reynolds/>
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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



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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 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<mailto: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.




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________________________________
Rich Capriola

Winter Capriola Zenner, LLC
One Ameris Center
3490 Piedmont Road NE, Suite 800
Atlanta, GA 30305
www.wczlaw.com<http://www.wczlaw.com/>
rcapriola@wczlaw.com<mailto: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