Thu 9 Jun 2022 19 48 24 0000 Re Fw Discovery Closing In About 5 Weeks 1814A02D 2¶

Thanks  I like the photo with the backhoe.

From: Sarah Zeeman <szeeman@gmail.com>
Sent: Thursday, June 9, 2022 3:46 PM
To: Richard J. Capriola <rcapriola@wczlaw.com>
Subject: Re: FW: Discovery Closing in about 5 weeks



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 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<mailto:szeeman@gmail.com>> wrote:
you can barely make it out in front of the bobcat- I can't find a clear shot


[cid:image001.jpg@01D87C18.5767A820]


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


[cid:image002.jpg@01D87C18.5767A820]

[cid:image003.jpg@01D87C18.5767A820]






On Thu, Jun 9, 2022 at 12:34 PM Richard J. Capriola <rcapriola@wczlaw.com<mailto: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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From: Sarah Zeeman <szeeman@gmail.com<mailto:szeeman@gmail.com>>
Sent: Thursday, June 9, 2022 12:32 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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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


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________________________________
Rich Capriola

Winter Capriola Zenner, LLC
One Ameris Center
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www.wczlaw.com<http://www.wczlaw.com/>
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404.844.5637







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