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Zeeman Rog 1 Draft

Field Value
Category Pleadings > Briefs & Memoranda
Confidence high
Reason Response to interrogatory requesting witness identification and knowledge summaries
Original File 22-03.24.22-zeeman-rog-1-draft.docx
File Type DOCX

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Document Text

Identify all persons having knowledge of the claims made and/or defenses raised by you in this case and provide a brief summary of the knowledge of said persons and the last known address and telephone number for said persons.

Brea Figura (Friendship) Address: 4906 Tennessee Ave Chattanooga TN 37409 Phone: 4045422265 Statement of what they know: Been to the property, has seen photos and aware of the suit and the harassment. Ryan Bergamini (Friendship) Address: 3763 Ashford Dunwoody Rd NE, Brookhaven, GA Phone: 8056376447 Statement of what they know: Previously lived at the property, took the video of the 2018 flooding coming from sweatmans original underground pipes. Has been to the property seen pictures and is aware of the suit Josh Comiter (Friendship) Address: 3005 Peachtree RD NE Phone: 5616324031 Statement of what they know: Been to the property, has seen photos and aware of the suit and the harassment. John Cyphers (Friendship) Address: 1261 Ashford Creek NE Brookhaven, GA 30319 Phone:4046978588 Statement of what they know: Been to the property, has seen photos and aware of the suit and the harassment. Was at the property during Linda, Murray, Eric, visit to the site - + recording Linda Zeeman (Family) Address: 3469 Mill Creek Rd Brookhaven, GA 30319 Phone:4042552693 Statement of what they know: Been to the property has visually seen the fence, doesn’t understand how he can build it on my home that I’ve lived in for so long and I said should get a good lawyer. Helps with pups. She is concerned about the stress this is causing me David Zeeman (Family) Address: 3469 Mill Creek Rd Brookhaven, GA 30319 Phone: 4042552693 Statement of what they know: He knows there is problem with the neighbor flooding my yard and the boundary line. He doesn’t know the details just the general situations, He is in a wheelchair so has not been to the property. He is concerned stress this is causing me. Mackenzie Crabtree (Family) Address: 608 Oak Marsh Dr Mt Pleasant, SC 29464 Phone: 4044587401 Statement of what they know: Has seen pictures and is aware of the suit

Kristina Wiltsee (Friendship) Address: 4046970987 Phone: 188 Hunters Drive SE Milledgeville, GA 31061 Statement of what they know: Aware of the suit and the harassment.

Jim McKinney (Friendship) Address: 151 Gold Leaf Trail Powder Springs GA 30127 Phone: 4049060934 Statement of what they know: hHs seen photos and aware of the suit

Jay ( Friendship) Phone 404 8088949 Statement of what they know: has seen photos and aware of the suit

Dom Hamilton (Friendship) Address 287 Georgia Ave SE Atlanta, GA 30312 Phone 4045501197 Statement of what they know: has seen photos and aware of the suit and the harassment.

Michelle Galvani (Friendship) 3565 Piedmont Rd NE Building 3 suite 715 Atlanta, GA Phone 44042170282 Statement of what they know: was looking for a lawyer referral from her -has seen photos and aware of the suit and the harassment.

Jay (John) Boggs (Friendship) Address: 364 Park Ave SE Atlanta, GA 30312 Phone 4042170282 Statement of what they know: has seen photos and aware of fence being torn down and the harassment.

Michael Dickerson (Friendship) Address 4756 Highside Way Smyrna, GA 30082 Phone: 5176674003 Statement of what they know: Been to the property, was at the home during Eric’s xx date visit. He has seen photos and aware of the suit. He had a dr appt right afterwards I was driving him to that is why he came to my home prior to his dr appt. Has seen pictures knows about the suit

Janet Allison (Friendship) Address: P.O.Box 908209 Atlanta, GA 30359 Phone: 4042746635 Statement of what they know: Been to the property, has seen photos and aware of the suit and the harassment.

Dr Bach (Friendship) Address: 1679 Bagpipe Place Conley, GA 30288 Phone: 4708159462 Statement of what they know: Been to the property has seen photos and aware of the suit and the harassment.

Mary Katherine Patrones (Friendship) Address: 1717 N Decatur Rd NE Phone: 4046600224 Statement of what they know: Been to the property has seen photos and aware of the suit and the harassment.

Brooke (Friendship) Address: 1000 Ashwood Pkwy Apt 1102 Atlanta, GA 30338 Phone: 6783724353 Statement of what they know: Been to the property has seen photos and aware of the suit and the harassment.

Terrell Carstens (Friendship) Address: 2444 Ostanaula Dr. NE Atlanta, GA 30319 Phone: 4043170411 Statement of what they know: Been to the property, was present during orlando’s code visit 9/4/21 has seen photos and documents and aware of the suit and the harassment.

Sharon Edwards (Friendship) Address: 125 Maison Place NW Atlanta, GA 30327 Phone: 6789938847 Statement of what they know: Been to the property has seen photos and aware of the suit and the harassment.

Michele Wood (Friendship) Address: 351 Peachtree hills ave ne #320 Atlanta GA Phone: 4048033936 Statement of what they know: has seen photos and aware of the suit and the harassment. Officer Carlai Moore carlai.moore@brookhavenga.gov 2665 Buford Hwy NE, Atlanta, GA 30324 Met her in the Target parking lot before going to the station to show the front door camera, showed her picture and told her the situation as the front door camera was really frighting me. She gave me her card so I didn’t go to the station afterwards. I went home and emailed her as she mentioned to do. Olivia Kaufman (Friendship) Address26 NE Prescott St 97211 Phone: 4043260868 Statement of what they know: has seen photos and aware of the suit and the harassment.

Ashley Reid (Friendship) 345 Dickson St, Fayetteville 30214 Phone:9172501035 Statement of what they know: has seen photos and aware of the suit and the harassment.

Lila Bruno (Friendship) Address: 114 Jeffrey Place Smyrna, GA 30081 Phone: 4042760203 Statement of what they know: :has seen photos and aware of the suit and the harassment.

Ollie Strickland (Friendship) Address: 9319 Lucian Ct Navarre, FL 32566 Phone: 4044354489 Statement of what they know : Seen photos and aware of the suit and the harassment.

Shan Morris (Friendship) Address 3565 Piedmont Rd NE building 3 suit 715 Atlanta, GA Phone: 4048227426 Statement of what they know: was looking for a lawyer referral from his – he has seen photos and aware of the suit and the harassment – Stacey Mcgahee (Friendship) Address: 2782 Durham Drive Brookhaven, GA 30319 Phone: 4045203185 Statement of what they know: has seen photos and aware of the suit and the harassment.

Clarence Savage(Friendship) 3846 Riverbank Dr SW Lilburn, GA 30047 Phone: 6788005782 Statement of what they know: sent the jungle gym hvac photo Dr Eric (Doctor) 1165 Brookhaven Ave Building 1100 Suite B Atlanta, GA 30319 4044808412 photos and aware of the suit Dr Doug Stuart (Doctor) Address: 3200 Downwood Cir NW # 550 Atlanta, GS 30327 Phone: 4043510205 Statement of what they know: photos and aware of the suit Dr Cody McClatchy (Doctor) Address 3280 Howell Mill Rd NW # 150 Atlanta, GA 30327 Phone: 4043517467 Statement of what they know: photos and aware of the suit Perry Julien (Doctor) Address: 5600 Roswell Road, Suite M-190 Atlanta, GA 30342 Phone: 4042559131 Statement of what they know: Treated my foot for stepping on the wood nail, cant remember if I told him about the suit Melissa Moss (Friendship) Address: 136 Crest Brook Dr. Holly Springs, GA 30115 Phone: 4048950937 Statement of what they know: photos and aware of the suit Lauren Godfrey (Friendship) Address: 1548 Old Hunters Trace Marietta, GA 30062 Phone: 4042296173 Statement of what they know: photos and aware of the suit Jonathan Barash (Friendship) Address: 825 Highland Ln NE Atlanta, GA 30306 Phone: 4043147041 Asked him looking for a lawyer – on Dec 2 his response:

Huga Mialon Friendship) 3037 East Ramble Lane Decatur, GA 30033 4044088333 Statement of what they know: saw photos and stop work orders photos – but not aware of the suit Lauren Moss (Friendship) ( Deceased 9/10/21) Deceased N/A Been to property, wasn’t aware of suit, saw pictures, during the construction – was there for emotional support though the experience

frank@haight-davis.com, maureen@haight-davis.com 473 Cricket Ridge Ct, Lawrenceville, GA 30044  (770) 979-6650 Been to the site – engineer for suit

John Chapman Address 1650 Redi Rd. Suite 100 Cumming, GS 30040 404-421-7260  Seen property in the past, and current photos. aware of the suit as I called to schedule an estimate rehab quote after report from engineer and estimate