Re Zeeman Settlement 1¶

Attached please find the settlement and mutual release agreement draft. I have sent it to the insured and opposing counsel as well. Its quite lengthy and extremely detailed, but I wanted to make sure all bases were covered. Let me know if you have any questions and/or proposed revisions. Note: I included Stewart into the Zeeman defined term. I can add a signature line as well if youd like. 



Brett Michael-Schiff Ledermeier 
Senior Associate, Real Estate Litigation


Mailing:  850 Windy Hill Road | Unit 1762 | Smyrna, GA 30081

11625 Rainwater Drive  |  Ste 125   |   Alpharetta, Ga 30009
Direct:  404.365.4564

Main: 770.200.7000

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






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From: Brett Ledermeier 
Sent: Monday, February 10, 2025 4:44 PM
To: Eric Zeni <Eric.Zeni@stewart.com>
Cc: Marimar Soltero <Marimar.Soltero@stewart.com>; Justin Davis <Justin.Davis@stewart.com>
Subject: RE: [External] Re: Voided settlement check - Request to re-issue and mail with tracking



Eric/Marimar, 



As an update, opposing counsel informed us and the Judge that they will be going the court order route. Ive asked that they prepare a consent order to address any non-conformities (impervious surfaces or otherwise); they are pushing back asking that we prepare it. I am working on the settlement now that I have a decision and will send you a draft for review once completed. 



Brett Michael-Schiff Ledermeier 
Senior Associate, Real Estate Litigation


Mailing:  850 Windy Hill Road | Unit 1762 | Smyrna, GA 30081

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: Eric Zeni <Eric.Zeni@stewart.com <mailto:Eric.Zeni@stewart.com> > 
Sent: Wednesday, February 5, 2025 5:41 PM
To: Brett Ledermeier <bledermeier@mmatllaw.com <mailto:bledermeier@mmatllaw.com> >
Cc: Marimar Soltero <Marimar.Soltero@stewart.com <mailto:Marimar.Soltero@stewart.com> >; Justin Davis <Justin.Davis@stewart.com <mailto:Justin.Davis@stewart.com> >
Subject: RE: [External] Re: Voided settlement check - Request to re-issue and mail with tracking



I agree.  Lets let these deadlines pass, see what the neighbor elects to do re the court order, and proceed in an intelligent manner.  As you noted in the transcript, the Court already addressed the issue of the check and required a completed settlement agreement.  The judge is not going to change his mind now.





From: Brett Ledermeier <bledermeier@mmatllaw.com <mailto:bledermeier@mmatllaw.com> > 
Sent: Wednesday, February 5, 2025 5:37 PM
To: Eric Zeni <Eric.Zeni@stewart.com <mailto:Eric.Zeni@stewart.com> >
Cc: Marimar Soltero <Marimar.Soltero@stewart.com <mailto:Marimar.Soltero@stewart.com> >; Justin Davis <Justin.Davis@stewart.com <mailto:Justin.Davis@stewart.com> >
Subject: RE: [External] Re: Voided settlement check - Request to re-issue and mail with tracking



I am sure you saw or will see Sarahs email. I would strongly advise against going to the Judge to ask for settlement funds before execution. I will advise the same. The Judge has hard set deadlines all of which occur in the next week and the Judge already has strong opinions of this case and the parties. 



Brett Michael-Schiff Ledermeier 
Senior Associate, Real Estate Litigation


Mailing:  850 Windy Hill Road | Unit 1762 | Smyrna, GA 30081

11625 Rainwater Drive  |  Ste 125   |   Alpharetta, Ga 30009
Direct:  404.365.4564

Main: 770.200.7000

bledermeier@mmatllaw.com <mailto:blederm