Re Discovery Closing In About 5 Weeks 14¶

I will follow up with Stewart.  I think they are going to want to see the final survey first but I believe that should be done shortly.  The actual title issues here are minimal, if any.  The problem is that Ms. Zeeman has refused all attempts to fix the title issues when the title claim was first made so I think Stewart is going to want to make sure Ms. Zeeman is open to resolution.  As long as she is open to compromise and resolution, I believe Stewart would be up for mediation first.  And I have no objection to Phil. 



From: Joseph G. Emanuel <joseph.emanuel@swiftcurrie.com> 
Sent: Tuesday, June 14, 2022 10:03 AM
To: Richard J. Capriola <rcapriola@wczlaw.com>; Tania Tuttle <ttuttle@mmatllaw.com>; Brett Ledermeier <bledermeier@mmatllaw.com>
Cc: Eric B. Coleman <ecoleman@wczlaw.com>; Joanna D. Conyers <Joanna.conyers@swiftcurrie.com>; Joanie J. Williams <jwilliams@wczlaw.com>; David Atkinson <David.Atkinson@swiftcurrie.com>
Subject: RE: Discovery Closing in about 5 weeks



All:  Plaintiffs Responses to our written discovery are due on July 8th and discovery is currently scheduled to close on July 13th. Sarahs deposition is currently scheduled for the 7th and we can notice the Sweatmans depositions for July 11-13. My understanding is that all counsel has availability on the 11-13th. 



However, Lisa suggested, and I agree, that, if possible, it would be worthwhile to attempt mediation prior to incurring the expense of party depositions which, are likely to have the effect of further deteriorating the relationship between these neighbors. Therefore, she is speaking with her clients about consenting to an extension of discovery in order to allow time to conduct mediation.  



I am new to the case, and I know that  some of these issues have been discussed previously. If our client agrees to pursue mediation is there any disagreement among counsel as to the above-suggested plan as a matter of strategy?  And do yall have strong feelings about Lisas suggested mediator Phil Bettis? 





Joe Emanuel <http://joseph.emanuel@swiftcurrie.com/> 

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From: Richard J. Capriola <rcapriola@wczlaw.com <mailto:rcapriola@wczlaw.com> > 
Sent: Wednesday, June 8, 2022 12:47 PM
To: Joseph G. Emanuel <joseph.emanuel@swiftcurrie.com <mailto:joseph.emanuel@swiftcurrie.com> >; Tania Tuttle <ttuttle@mmatllaw.com <mailto:ttuttle@mmatllaw.com> >
Cc: Eric B. Coleman <ecoleman@wczlaw.com <mailto:ecoleman@wczlaw.com> >; Joanna D. Conyers <Joanna.conyers@swiftcurrie.com <mailto:Joanna.conyers@swiftcurrie.com> >; Brett Ledermeier <bledermeier@mmatllaw.com <mailto:bledermeier@mmatllaw.com> >; Joanie J. Williams <jwilliams@wczlaw.com <mailto:jwilliams@wczlaw.com> >; David Atkinson <David.Atkinson@swiftcurrie.com <mailto:David.Atkinson@swiftcurrie.com> >
Subject: RE: Discovery Closing in about 5 weeks



#32 Looks good.  



If you can hand serve the discovery today, then they must respond by July 8th.  That only leaves July 11-13 for depositions.  I am open July 11-13.  



When you talk to Sarah, please let her know about her deposition on July 7th and the subpoenas served on Ski and Chastain.  



Tania  just wanted to be sure Chastain is not the surveyor that was hired by your firm to do the most recent survey.  If it is, we need to protect its survey as work product.  











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