Wed 5 Feb 2025 20 08 46 0000 Re External Re Voided Settlement Check Request To Re Issue 194D7Bad 2¶

Sarah,

I can’t advise as to coverage. I was stating that, as a matter of law, that is the consideration for the settlement agreement. The $10,000.00 from USAA are funds from the Plaintiff and can’t be released until we have an executed settlement unless prior consent is given.

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>


[cid:image001.jpg@01DB77DF.A36B1D40]


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: Sarah Zeeman <szeeman@gmail.com>
Sent: Wednesday, February 5, 2025 3:04 PM
To: Brett Ledermeier <bledermeier@mmatllaw.com>
Cc: Eric Zeni <Eric.Zeni@stewart.com>; Jeff Banks <jeffsbanks@hotmail.com>; Marimar Soltero <Marimar.Soltero@stewart.com>; Melissa Taylor <Melissa.Taylor@stewart.com>; Tania Tuttle <ttuttle@mmatllaw.com>
Subject: Re: [External] Re: Voided settlement check - Request to re-issue and mail with tracking

Brett.

Where can I locate what you're referring to? I do not see that within the Stewart Title Insurance policy.

On Wed, Feb 5, 2025 at 2:58 PM Brett Ledermeier <bledermeier@mmatllaw.com<mailto:bledermeier@mmatllaw.com>> wrote:
Sarah,

I would prefer to email separately given the fact that I represent you in this matter, but I am sending this here for your convenience. Settlement funds are paid as consideration for the settlement, which is a contract. In this case, the consideration includes all mutual promises, covenants, warranties, and representations including, but not limited to, the relocation of the boundary line and relocation of the fence. Similar to a closing for the purchase of real property, the funds are paid at the time of execution unless otherwise noted (often within 5-30 days depending on the settlement). In this case, they are to be released at the time of execution.

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>


[cid:image001.jpg@01DB77DF.A36B1D40]


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: Sarah Zeeman <szeeman@gmail.com<mailto:szeeman@gmail.com>>
Sent: Wednesday, February 5, 2025 2:53 PM
To: Eric Zeni <Eric.Zeni@stewart.com<mailto:Eric.Zeni@stewart.com>>
Cc: Jeff Banks <jeffsbanks@hotmail.com<mailto:jeffsbanks@hotmail.com>>; Brett Ledermeier <bledermeier@mmatllaw.com<mailto:bledermeier@mmatllaw.com>>; Marimar Soltero <Marimar.Soltero@stewart.com<mailto:Marimar.Soltero@stewart.com>>; Melissa Taylor <Melissa.Taylor@stewart.com<mailto:Melissa.Taylor@stewart.com>>
Subject: Re: [External] Re: Voided settlement check - Request to re-issue and mail with tracking

Eric,

Thank you for getting back to me.
Where is that criteria listed in writing, and can I get a copy of it"?

Best,
Sarah

On Wed, Feb 5, 2025 at 2:51 PM Eric Zeni <Eric.Zeni@stewart.com<mailto:Eric.Zeni@stewart.com>> wrote:
Sarah, you need to discuss this with Brett. If this check is part of the settlement of the lawsuit I do not think it is going to be released until a settlement agreement is finalized and fully executed.


ERIC ANTHONY ZENI, ESQ.
Chief Claims Counsel / Vice President
Stewart Title Insurance Company
711 Westchester Avenue – Suite 302
White Plains, New York 10604
O 914-993-9393 | D 914-993-4443 | F 914-206-4887
stewart.com<http://www.stewart.com/> | eric.zeni@stewart.com<mailto:eric.zeni@