Tue 8 Mar 2022 22 51 54 0000 Re Automatic Reply Survey Update Question 17F6Bbb8 2¶

I’m waiting to hear back from her. I tried calling (since she had asked for a call a while back and I didn’t want her to think we’re ignoring her). If I don’t hear back by tomorrow, I’ll send an email follow up.

[cid:image001.png@01D83315.16B26730]
Lucy Aquino<http://Lucy.Aquino@swiftcurrie.com/>
404.888.6202<tel:404.888.6202>
NOTICE:  This email message and all attachments may contain legally privileged and confidential information intended solely for the addressee.  If you are not an intended recipient, your receipt of this email and its attachments is the result of an inadvertent disclosure or unauthorized transmittal.  Sender reserves and asserts all rights to confidentiality, including all privileges that may apply.  Pursuant to those rights and privileges, you are hereby notified that you may not read, copy, distribute or otherwise use this message or its attachments. If you have received this message in error, please notify the sender by email and delete all copies of the message and the attachments immediately.  NO DUTIES ARE INTENDED OR CREATED BY THIS COMMUNICATION.  If you do not have a signed fee contract or engagement letter with this firm, this firm does NOT represent you as your attorney.​

From: Richard J. Capriola <rcapriola@wczlaw.com>
Sent: Tuesday, March 8, 2022 4:32 PM
To: Lucy Aquino <Lucy.Aquino@swiftcurrie.com>
Cc: Tania Tuttle <ttuttle@mmatllaw.com>; Sally L. Monico <SCook@mmatllaw.com>; Sarah Zeeman <szeeman@gmail.com>
Subject: RE: Automatic reply: Survey update question

Hi Lucy.  is Plaintiff willing to grant an extension on the discovery requests?

Rich




[cid:image002.jpg@01D83315.16B26730]<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<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: Sally L. Monico <SCook@mmatllaw.com<mailto:SCook@mmatllaw.com>>
Sent: Monday, March 7, 2022 11:10 AM
To: Sarah Zeeman <szeeman@gmail.com<mailto:szeeman@gmail.com>>; Lucy Aquino <Lucy.Aquino@swiftcurrie.com<mailto:Lucy.Aquino@swiftcurrie.com>>; Richard J. Capriola <rcapriola@wczlaw.com<mailto:rcapriola@wczlaw.com>>
Cc: Tania Tuttle <ttuttle@mmatllaw.com<mailto:ttuttle@mmatllaw.com>>
Subject: RE: Automatic reply: Survey update question



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.

Sarah,

I spoke with Stewart last week and relayed your request for a new survey and at this time we are not authorized to order a new survey.   If you have questions about the title company’s determination please reach out to Amy Azza.   Her contact info is below.

Amy N. Azza
Claims Counsel
Stewart Title Guaranty Company
200 Fifth Avenue, Suite 301
Waltham, MA  02451
O (781) 697-3327 | F (781) 697-3335
stewart.com<http://www.stewart.com/> | Amy.Azza@stewart.com<mailto:Amy.Azza@stewart.com>
[cid:image003.jpg@01D83315.16B26730]


After reviewing the plat (PB 96 Pg 14) and the survey obtained by your prior counsel the metes and bounds for your property appear to be consistent (within the margin of error) on the recent 2021 survey.  If you have concerns about pins being moved since September or have reason to call into question the survey obtained by your prior counsel then you are more than welcome to contact a surveyor to obtain a new survey.  We use/recommend Mark Chastain or Jeff McClung.

https://chastainassociates.com/<https://chastainassociates.com/>

https://mcclungsurveying.com/<https://mcclungsurveying.com/>

On the subject of discovery, Lucy, have you had a chance to contact Lisa Rose regarding an extension of time to response to the requests?

I am working on a draft/outline of the responses and will cir