IN

THE

SUPERIOR

COURT

STATE

CIVIL

JONATHAN

OF

ACTION

OF

DEKALB

COUNTY

GEHORGIA

FILE

NO:

21CV9795

SWEATMAN,

Plaintiff, Vv.

SARAH

ZEEMAN,

Respondent /Counterclaim Petitioner, V.

JONATHAN

SWEATMAN,

Counterclaim

Deposition

taken

on

behalf

Respondent, counsel,

31201,

and

remotely,

at

all on

notice

and

Walnut

other

ZEEMAN,

and

counsel

Street,

parties

Tuesday,

JULIA

Plaintiff/Counterclaim

to

witness 970

SARAH

the

pursuant

with

appearing

of

of

Respondent.

July

agreement for

witness

Macon,

11th,

2023,

at

the

hour

of

1:21

p.m.

and

concluding

at

the

hour

of

5:31

p.m.

of

reported

by

Barbara

remotely

Registered Georgia

Professional

Georgia

appearing

commencing

day,

of

Reporter,

J.

the

same

Memory,

Certified

Reporter.

7

CERTIFIED TRANSCRIPT

(GY) AdvancedONE is now ple XITAS LEGAL

JONATHAN

SARAH

SWEATMAN

JULIA

v

SARAH

ZEEMAN,

ZEEMAN

Pages

Page 1 2

2

APPEARANCES

Page 1

Appearing remotely on behalf of Jonathan

2

3

Sweatman:

3

4

TIMOTHY

L.

MITCHELL,

CHELSEA T. 5

6

7

Cruser,

Meridian

275

COOKE,

ESQUIRE Novitz,

Suite

4 Sanchez

2000

&

Zimet,

LLP

Scientific Drive

Peachtree

Corners,

Georgia

404.881.2622

30092

OF

4

EXAMINATIONS

Page

SARAH

JULIA ZEEMAN .

.

Ms. .

5

Examination

6

Examination By Mr.

By

7

Cooke

Mitchell

108

7

tmitchell@cmlawfirm.com

8

INDEX

ESQUIRE

Mitchell, II,

2..5

07/11/2023

3

-

oe

ccooke@cmlawfirm.com

9

) Appearing

on

behalf

of

Sarah

Zeeman:

10

10 JEFF

BANKS,

11

Banks

12

Macon,

970

&

ESQUIRE

Riedel,

Walnut

11

PC

Street

Georgia

12

31201

13

478.254.3230

13

banksnriedel@gmail.com

14

Appearing remotely on behalf of Sarah Zeeman:

15

14

15 16

17

BRETT

LEDERMEIER,

McLain 11625

&

Rainwater

Alpharetta,

16

ESQUIRE

Merritt,

PC

17

Drive,

Suite

125

Georgia 30009

18

404.365.4566

18

19

bledermeier@mmatllaw.com

19

20

20

NOAH CALDWELL,

ESQUIRE

Swift,

Currie,

McGhee

Peachtree

Street,

1355

Georgia

O41 &

Hiers, NE,

LLP

Suite

21

Atlanta,

22

noah.caldwell@swiftcurrie.com

300

22

30309

404.888.6203

23 24

23

24

FF

25

25

Page 1

FIRM

DISCLOSURE

OF

NO

CONTRACT

Page 1

2

(Witness

2

3

I,

4

pursuant

5

Regulations

Barbara

to

J.

Memory,

do

hereby

10.B

of

the

Rules

Board

of

Court

Article of

Judicial

the

6

the

7

Reporting,

8

Legal/Lexitas to provide

Council

Inc.

was

9

services

for

this

10

contract

that

is

11

15-14-37(a)

12

deposition.

13

There

and

of

Georgia,

contacted

by

court

deposition

that

and

4

taking

no

between

g

all

under the

9

Act,

and there

is

of

this

provide

Inc. nor

17

attorney

18

action,

19

this

action,

20

this

action.

at

Any

23

have

agency

law

party

and

or

in

relationship,

this

having agent

uses

including

action,

a

party

financial

for

an

Inc.

or

any

has a any

to

this

interest

cross-examinations

11

purpose

attorney

at

law

in

all

financial usual

disclosed

and

7

arrangements

and

customary

offered to

TO

25

all

beyond

allowed

for

Civil Practice

and

under

and

any

other

the Act.

We want to —- and I think we talked about

14

want

15

all objections except

for those that

16

go

question.

18

to

to

this

the

form

And then

discussed

19

MR.

earlier.

reiterate.

of

I

Object

the

have

just

-- waiving

you-all

already

signature? BANKS:

We

—-

Okay.

we

want

to

sign.

21

MS.

COOKE:

rates

22

MR.

BANKS:

parties.

23

objections

24

question and responsiveness of the

25

answer,

go,

But

to

right?

the

as

far

as

form of

the

ITAS’

w te X G@ AdvancedONe is no LEGAL

and

taken

13

17

in

counsel

discovery

10

20

Reporting's

been

Reporting,

reporting

principal

Memory

no

0.C.G.A.

person with whom Memory Reporting, and

Memory

today.

of

proper

My

be

deposition

notice,

taking

to

the

agreement

(b)

contract

be

to

reporting

by

deposition

will

taken

12 is

your

This

I'll

pursuant

16

22

5

Zeeman.

and

6

15

21

of

Ms.

7

services

or

Cooke

Memory

by

the

Hi,

Chelsea

name

AdvancedONE

prohibited for

COOKE:

is

3

Reporting

sworn.)

MS.

disclose

14

24

3

5

JONATHAN

SARAH

SWEATMAN

JULIA

v

SARAH

ZEEMAN,

Pages

ZEEMAN

Page

1 2

3

MS.

COOKE:

MR.

CALDWELL:

waive them,

4

MS.

6

Yes.

COOKE:¶

Page

1

And —- and not to

8

would not be considered verbal.

2

but to reserve them.

5

6..9

07/11/2023

And so I want to start by affirming

3

that you are no longer seeking a claim of

Okay.

4

emotional distress -—-

5

MR. BY MS.

BANKS:

That's correct.

6

6

COOKE:

7

7

8

8

Okay.

9

9

MR.

10

10

on the record.

11

11

12

12

13

13

complaint to reflect you no longer

14

14

are seeking that.

15

15

MR.

BANKS:

That's

16

16

MS.

COOKE:

Okay,

Q.

-- as you previously were.

And I also want to —-

BANKS:

MS.

We're waiving that

COOKE:

Okay.

And I want to

confirm that you plan to amend your

17

17

18

18

19

19

record that we do currently have a motion to

20

20

compel that's pending in which we requested

21

21

certain documentation.

22

22

received those documents,

23

23

ahead and reserve the right to redepose you and

24

24

question you regarding those documents when we

25

25

do receive them.

Page

BY MS.

correct. perfect.

COOKE:

Q.

And,

also,

I just want to have on the

To date we have not so we do want to go

7

Page

1

SARAH JULIA ZEEMAN,

1

2

having been produced and first duly sworn,

2

that bridge when we come to it,

3

testified as follows:

3.

think it's

EXAMINATION

4

same thing that y'all haven't given

5

us.

4 5

BY MS.

6

Q.

COOKE:

And then I am here on behalf of

6

Jonathan Sweatman and I'm going to ask you

7

7

\Mr.¶

8

some questions today.

9

I just ask if at any point you don't

10

understand my question,

11

can reiterate that for you.

12 13.

you let me know and I

too.

I

Well,

we'll

just damages,

COOKE:

cross

but

I

which is the

All right.

But

8

different -- we do currently have

9

that motion to compel.

11

that's fine,

MS.

BANKS:

just

in the different —- as far as the

10

If you have to go to the restroom or take a break at any time,

MR.

MR.

BANKS:

understand.

I —I—I

I'm like —- I'm sorry.

12

I keep talking over you.

13

rude of me.

14

just ask that you let me know and that we

14

15

finish the question that we're currently on

15

to anything today,

16

before we take any breaks.

16

you need to question it,

17

cross that bridge when we come to it.

17

And do you understand that you're

18

under oath and that you have to tell the truth

18

19

as if you were in front of a judge and jury

19

20

= today?

21

A.

Yes.

Q.

Okay.

22

And then the only other thing

23.

I ask is as far as responses,

that you give

24

only verbal responses,

25

versus any head shaking or any movements that

such as "yes" or "no"

Yeah,

That's very

MS.

COOKE:

but,

Okay.

obviously,

if

then we can

I

just want

to note that we're objecting to the

20

fact that it's not reopened for us to

21

do that line of questioning and just

22

that there is a difference —-

23

difference of opinion when it comes

24

to that.

25

MR.

(G(O) AdvancedONE is now LEGAL

I'm not going to consent

LEDERMEIER:

To clarify,

pLEXITAS

the

9

JONATHAN

SARAH

SWEATMAN

JULIA

v

ZEEMAN,

SARAH

Page

1

Motion to Compel,

Pages

ZEEMAN

10..13

07/11/2023 10

were there

Page

1

MS.

COOKE:

All right.

Well,

2

documents in there that related to

2

would like to start with just so —-

3.

the emotional distress claim?

3

like you said,

A couple of the —- I

4

follow-up question if they would

5

think maybe two of the documents that

5

affect her at all.

6

were listed,

6

would set the precedent for asking

7

amount of remaining.

7

what exactly they are so that we can

8

a couple of them related to the

8

ask that follow-up.

9

emotional distress,

9

4

10

11 12

MS.

MR.

COOKE:

but there were a good But there were

yes.

LEDERMETER:

Okay.

So those

would be moot at this point? MS.

COOKE:

Well,

as soon as we

If y'all that's fine,

13

but

14

15

thus far.

15

16

that complaint to be amended,

17

go ahead and waive those.

18

would like to reserve that until we

19

actually have

20

MR.

22

23

we can

them in the complaint. In our —- our

MS.

COOKE:

Yes.

I

16

THE WITNESS:

17

MR.

MR.

LEDERMEIER:

25

MS.

COOKE:

Okay.

she —-

LEDERMEIER:

2

Jeff,

3

one count. MS.

COOKE:

Okay.

5

MR.

BANKS:

Okay.

I'll —- I'll

8

MS.

COOKE:

Okay.

9

MR.

BANKS:

That will be easier

All right.

than rewriting the whole complaint.

Q.

COOKE:

Okay.

COOKE:

Ms.

Zeeman,

are you currently taking

any medications today?

I'm sorry.

I

No.

Okay.

Have you ever given a

deposition before?

8

A.

No.

9

Q.

Did you review any documents to

10

prepare for your deposition today?

11

A.

Yes.

12

Q.

What were those documents?

13

A,

Documents provided to me by my

14

lawyer.

Yes.

15

And what medications are those?

16

MR.

17

I'm going to

Are you currently taking any

Q.

Q.

Well,

Q.

A.

A.

Q.¶

Okay.

And as far as the documents --

=and I'm not asking about any conversations that += you had with your lawyer pertaining to the

18

object to her — I would object that

18

documents.

19

she doesn't have to disclose any of

19

were those documents?

20

her medical history.

20

A.

What are those documents?

21

to ask whether or not anything she's

21

Q.

Yes,

22

taking would affect her ability to

22

23

answer truthfully or conduct the

23

24

deposition,

24

that

25

would object.

25

the lawsuit claim,

But

if you want

you can ask that.

But I

But the documents themselves,

ma'am.

what

That you reviewed to

prepare for your deposition today. A.

(G(O) AdvancedONE is now LEG