Wed 8 Jun 2022 15 46 00 0400 Re Fw Discovery Closing In About 5 Weeks 18144Da3 2¶

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>
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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> <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
>
> rcapriola@wczlaw.com
>
> View Bio <https://wczlaw.com/attorneys/chadd-l-reynolds/>
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> 404.844.5637
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> *From:* Richard J. Capriola
> *Sent:* Wednesday, June 8, 2022 11:46 AM
> *To:* 'Joseph G. Emanuel' <joseph.emanuel@swiftcurrie.com>; Tania Tuttle <
> ttuttle@mmatllaw.com>
> *Cc:* Eric B. Coleman <ecoleman@wczlaw.com>; Brett Ledermeier <
> bledermeier@mmatllaw.com>; Joanie J. Williams <jwilliams@wczlaw.com>
> *Subject:* RE: Discovery Closing in about 5 weeks
>
>
>
> Thanks Joe.  Please incorporate the following:
>
>
>
> Interrogatories:
>
>    - 28 and 29 are the same.  Please change 29 to ask about entry onto
>    2740 “with” the express permission of Respondent.
>    - 31 and 32 are duplicative
>    - Please add the following rog:
>       - For any buried drainage pipe that existed on 2746 Grove Street
>       prior to 2021 that discharged onto 2740 Grove Street or toward the property
>       line between 2746 Grove Street and 2740 Grove Street state the following:
>          - The date and reason it was installed
>          - The date and reason it was removed or modified
>          - The person or entity that installed it
>          - The source of water that traveled through it
>          - The volume and velocity of water that traveled through it
>          - All documents, invoices, plans, designs, calculations,
>          estimates, communications, permits, and correspondence related to it
>          - Any photographs or video of it or its installation or removal
>          - The identify of any person with knowledge regarding its
>          installation, modification, removal, or function.
>
> Document Requests:
>
>                 Please