Wed 8 Jun 2022 15 59 49 0000 Fw Discovery Closing In About 5 Weeks 181440B3 2¶

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/>
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404.844.5700
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 add the following:

  *   All documents referencing or otherwise relating to any damage you seek to recover including all attorneys fees you seek to recover
  *   To the extent not otherwise produced in response to the above requests, please produce all documents and electronically stored information which documents, references, or relates to any and all communications of any kind (written, text message, emails or other documents) with the City of Brookhaven or any other governmental of regulatory body concerning or referencing any and all improvements or renovations which have been constructed upon 2746 Grove Street in the last three years.
  *   All permit applications and permits regarding 2746 Grove Street
  *   All surveys and plats regarding or relating to 2746 Grove Street or 2740 Grove Street
  *   Please produce any and all consultant, contractor, or engineering correspondence, invoices, opinions, plans, designs, or proposals  that address or relate to any issue related to this litigation.






[cid:image002.jpg@01D87B29.FF7394B0]<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 c