Notice Of Depo Sarah Zeeman With Prod Doc Ocr¶

IN THE SUPERIOR COURT OF DEKALB COUNTY STATE OF GEORGIA

JONATHAN SWEATMAN,

)

) Plaintiff,

)

V.

)

CIVIL ACTION FILE NO.

)

21CV9795

) SARAH ZEEMAN,

)

) Defendant.

)

) PLAINTIFF JONATHAN SWEATMAN’S NOTICE OF DEPOSITION AND REQUEST

FOR PRODUCTION OF DOCUMENTS TO DEFENDANT SARAH ZEEMAN

TO:

Defendant Sarah Zeeman c/o Attorneys for Defendant Richard J. Capriola Eric B. Coleman

Winter Capriola Zenner, LLC 3490 Piedmont Road, NE, Suite 800 Atlanta, GA 30305

Please take notice that Plaintiff

Jonathan Sweatman (‘Plaintiff’), by and through his

attorneys, will proceed to take the deposition of Defendant Sarah Zeeman in the above-styled case, pursuant to O.C.G.A. §§ 9-11-26, 9-11-30, and 9-11-34, which will take place before an authorized court reporter, commencing at 9:30 a.m. on July 7, 2022, at the law office of Winter Capriola Zenner, LLC, 3490 Piedmont Road, NE, Suite 800, Atlanta, GA 30305, or at such other date, time,

and place as the parties may agree. Pursuant to O.C.G.A. § 9-11-34, Defendant is hereby requested to produce at said deposition the following requested documents:

.

An itemization of each and every damage Defendant is claiming in Defendant’s Counterclaim and all invoices, receipts, proof of payment in support of same. Copies of any and all documents evidencing Defendant’s alleged damages as alleged in the Counterclaim. Copies of any and all estimates, contracts, and/or proposals prepared by a non-party to remediate any purported damage to Defendant’s property as it relates to the allegations raised in the Complaint or Counterclaim. Copies of Defendant’s medical records that relate to Defendant’s medical condition at issue, including but not limited to the allegation contained in Count 5, paragraph 52 of Defendant’s Counterclaim, “Zeeman has suffered emotional distress, personal injuries, discomfort, and annoyance, and otherwise been damaged by Sweatman’s invasion of her privacy in an amount to be determined at trial.” Copies of all reports created by each expert that is expected to testify on behalf of Defendant.

Copies of all reports created by each witness that is expected to testify on behalf of Defendant.

Copies of any and all documents showing communications by and between Defendant and any professional surveyor regarding the Property and copies of surveys and/or draft surveys prepared on behalf of Defendant. Copies of any and all documents showing communications by and between Defendant and any contractor to address or remediate any alleged damaged caused by Petitioner to Defendant’s Property.

9.

Copies of any and all documents related to Defendant’s purchase of the two heating ventilation and air conditioning (“HVAC”) units currently located on a portion of her property.

Said deposition will continue from day to day until completed.

Said deposition will be

taken upon oral examination for all purposes allowed under the Georgia Civil Practice Act before an officer authorized by law to administer oaths and take depositions upon oral examinations as required by law.

This 3rd day of June, 2022.

ROSE LITIGATION, LLC

/s/ Lisa K. Rose Lisa K. Rose

Georgia Bar No. 614204 Attorney for Plaintiff 4880 Lower Roswell Road

Suite 165-522 Marietta, Georgia 30068 Telephone: (678) 806-8188 lisa@roselitigation. lawyer

CERTIFICATE OF SERVICE

I hereby certify that I have this day served the within and foregoing PETITIONER JONATHAN

SWEATMAN’S

NOTICE

OF

DEPOSITION

AND

REQUEST

FOR

PRODUCTION OF DOCUMENTS OF DEFENDANT ZEEMAN upon the counsel or parties

listed below by e-file electronic service, electronic transmission and first class mail addressed as follows: David M. Atkinson (david.atkinson@swiftcurrie.com)

Swift, Currie, McGhee & Hiers, LLP 1355 Peachtree Street, NE, Suite 300 Atlanta, GA 30309

Tania R. Tuttle (ttuttle@mmatllaw.com) Sarah C. Monico (smonico@mmatllaw.com) Brett M. Ledermeier (bledermeier@mmatllaw.com) McLain & Merritt PC 11625 Rainwater Drive, Suite 125 Alpharetta, GA 30009 Richard J. Capriola (rcapriola@wezlaw.com) Eric B. Coleman (ecoleman@wcezlaw.com)

Winter Capriola Zenner, LLC 3490 Piedmont Road, NE, Suite 800 Atlanta, GA 30305 This 3rd day of June, 2022. ROSE LITIGATION, LLC

/s/ Lisa K. Rose Lisa K. Rose

Georgia Bar No. 614204 Attorney for Plaintiff 4880 Lower Roswell Road Suite 165-522 Marietta, Georgia 30068 Telephone: (678) 806-8188 lisa@roselitigation. lawyer