Thu 9 Jun 2022 16 33 58 0000 Re Fw Discovery Closing In About 5 Weeks 1814950D 2¶

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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________________________________
Rich Capriola


Winter Capriola Zenner, LLC
One Ameris Center
3490 Piedmont Road NE, Suite 800
Atlanta, GA 30305
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rcapriola@wczlaw.com<mailto:rcapriola@wczlaw.com>
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404.844.5700
404.844.5637








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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.
Thank you.

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


[cid:image001.jpg@01D87BFD.2FF33540]<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<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 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<mailto:szeeman@gmail.com>>
Sent: Wednesday, June 8, 2022 3:46 PM
To: Richard J. Capriola <rcapriola@wczlaw.com<mailto:rcapriola@wczlaw.com>>
Cc: Joanie J. Williams <jwilliams@wczlaw.com<mailto: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 shortl