Re Jonathan Sweatman V. Sarah Zeeman V. Jonathan Sweatman Plaintiff Counterclaim Defendant Jonathan Sweatmans Expert Disclosure 5¶

Timothy, 



Its my understanding that you and Jeff have already discussed out settlement proposal. So as to elaborate, below are the key points:



*   The property line, and fence, will be moved back approximately 2 8 with the fence to be moved within 30 days of execution of the settlement agreement. 
*   Ms. Zeeman will have approval to tie-in to the fence.
*   Acknowledgment that there is not currently any drainage and/or water being directed, aside from the natural flow, to Ms. Zeemans Property
*   Non-admission of guilt
*   Waiver of any and all claims, including a waiver as to any adverse possession claims), with a reservation of claims related to water-runoff in the event your client were to take action or conceal (e.g. piping, underground drainage) water re-direction on to Ms. Zeemans Property. 
*   Non-disparagement provision
*   Confidentiality provision
*   Mutual dismissal with prejudice
*   Each party covering their own legal fees
*   In the event a party is required to file suit to enforce the settlement, reasonable attorneys fees and expenses to the prevailing party
*   Payment to Mr. Sweatman in the amount of $6,000.00 which, for clarity, is my maximum authority. 



We can coordinate amended legal descriptions and having the property line marked. 



I am hopeful that we are able to reach an amicable resolution here and put this matter to rest. Please let me know if you have any questions or if youd like to set up a call to further discuss. 



This offer is open until Friday, August 4, 2023 at 5:00 PM. This is an offer of settlement and compromise only. 



Brett Michael-Schiff Ledermeier 
11625 Rainwater Drive  |  Ste 125   |   Alpharetta, Ga 30009
Direct:  404.365.4564

Main: 770.200.7000

bledermeier@mmatllaw.com <mailto:bledermeier@mmatllaw.com> 






CONFIDENTIALITY NOTICE
No attorney-client relationship exists by virtue of this communication in absence of an engagement letter or fee contract. In addition, unless you are in the To: or CC: line of this email, you are not an intended recipient. The information accompanying this email transmission may contain confidential or legally privileged information meant for ONLY the intended recipient. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution or reliance upon the contents of this email is strictly prohibited. If you receive this email in error, please delete this email and notify the sender immediately. 



From: Timothy L. Mitchell <tmitchell@cmlawfirm.com> 
Sent: Friday, July 28, 2023 2:07 PM
To: Brett Ledermeier <bledermeier@mmatllaw.com>; Sarah Riedel <banksnriedel@gmail.com>; jeffsbanks@hotmail.com
Cc: noah.caldwell@swiftcurrie.com; david.atkinson@swiftcurrie.com; lisa@roselitigation.lawyer; Tania Tuttle <ttuttle@mmatllaw.com>; Sally L. Monico <SCook@mmatllaw.com>; Chelsea Cooke <ccooke@cmlawfirm.com>
Subject: RE: Jonathan Sweatman v. Sarah Zeeman v. Jonathan Sweatman -- plaintiff/counterclaim defendant Jonathan Sweatmans expert disclosure



All:



             A reminder that you we were to receive a response by the end of the day today.  Thank you.



Timothy L. Mitchell
C: (810) 348-1942 





From: Brett Ledermeier <bledermeier@mmatllaw.com <mailto:bledermeier@mmatllaw.com> > 
Sent: Tuesday, July 25, 2023 3:21 PM
To: Timothy L. Mitchell <tmitchell@cmlawfirm.com <mailto:tmitchell@cmlawfirm.com> >; Sarah Riedel <banksnriedel@gmail.com <mailto:banksnriedel@gmail.com> >; jeffsbanks@hotmail.com <mailto:jeffsbanks@hotmail.com> 
Cc: noah.caldwell@swiftcurrie.com <mailto:noah.caldwell@swiftcurrie.com> ; david.atkinson@swiftcurrie.com <mailto:david.atkinson@swiftcurrie.com> ; lisa@roselitigation.lawyer <mailto:lisa@roselitigation.lawyer> ; Tania Tuttle <ttuttle@mmatllaw.com <mailto:ttuttle@mmatllaw.com> >; Sally L. Monico <SCook@mmatllaw.com <mailto:SCook@mmatllaw.com> >; Chelsea Cooke <ccooke@cmlawfirm.com <mailto:ccooke@cmlawfirm.com> >
Subject: RE: Jonathan Sweatman v. Sarah Zeeman v. Jonathan Sweatman -- plaintiff/counterclaim defendant Jonathan Sweatmans expert disclosure



Timothy, 



Our expert is available August 10th, 17th, and 31st. As an additional update, we expect to have a response to your settlement by Friday, if not sooner. 



Brett Michael-Schiff Ledermeier 
11625 Rainwater Drive  |  Ste 125   |   Alpharetta, Ga 30009
Direct:  404.365.4564

Main: 770.200.7000

bledermeier@mmatllaw.com <mailto:bledermeier@mmatllaw.com> 






CONFIDENTIALITY NOTICE
No attorney-client relationship exists by virtue of this communication in absence of an engagement letter or fee contract. In addition, unless you are in the To: or CC: line of this email, you are not an intended recipient. The information accompanying this email transmission may contain confidential or legally privileged information meant for ONLY the intended recipient. If you are not the intended recipient, you a