Affidavit Of Chelsea Cooke Esq Ocr¶

FILED 6/14/2023 6:46 PM CLERK OF SUPERIOR COURT DEKALB COUNTY GEORGIA

JAB IN THE SUPERIOR COURT OF DEKALB COUNTY STATE OF GEORGIA

JONATHAN SWEATMAN,

§

§

Petitioner,

§

§

v.

§

§

SARAH ZEEMAN,

§

§

CIVIL ACTION

Respondent / Counterclaim

§

FILE NO. 21CV9795

Petitioner.

§

§

Vv.

§

JONATHAN SWEATMAN, Counterclaim Respondent.

§

§

§

§

§ AFFIDAVIT OF CHELSEA T. COOKE, ESQ.

COMES NOW Chelsea T. Cooke., Georgia Bar Number 209502, counsel of record for

JONATHAN SWEATMAN, Plaintiff/Counterclaim Defendant in the above-styled Civil Action, and who, after being duly sworn, deposes and states under oath as follows: 1.

I give this Affidavit based upon my personal knowledge for use in the above-styled case and any other purposes provided by law. I am a member of the Georgia Bar duly licensed to practice law in the State of Georgia. I am counsel of record for Counterclaim Defendant Jonathan Sweatman in the above-styled case.

25

On May 5, 2023, I reached out to Zeeman’s counsel regarding the discovery deadline in

this case and Zeeman’s responses and requested that Zeeman provide a response by May 15, 2023. No response was provided (May 5, 2023, email from Chelsea Cooke to Jeff Banks and Brett Ledermeier, attached hereto as Exhibit A) 3. On May 16, 2023, I reached out to Zeeman’s counsel regarding the discovery deadline in

this case. (May 16, 2023, email from Chelsea Cooke to Jeff Banks and Brett Ledermeier, attached hereto as Exhibit A.) 4.

On May 19, 2023, May 23, 2023, and May 26, 2023, my office again reached out to Zeeman’s counsel regarding the discovery deadline in this case and attempted to set up a time to discuss this case with Zeeman’s counsel. (May 19, 2023, May 23, 2023, and May 26, 2023

emails from Chelsea Cooke to Zeeman’s counsel, attached hereto as Exhibit A.) 5. On June 1, 2023, I again reached out to Zeeman’s counsel to obtain the requested

documents and asked that Zeeman’s counsel provide the requested documents by June 8, 2023. (June 1, 2023 email from Chelsea Cooke to Zeeman’s counsel, attached hereto as Exhibit B.) 6. As of this date, however, Plaintiff has not responded to Defendant’s written discovery requests.

FURTHER AFFIANT SAYETH NOT

This the 14th day of June 2023.

Cholsog, Codboy

CHELSEA T. COOKE, ESQ.

Sworn to and subscribed before me this

[4#tday of ___ June.

2023.

: 0. Bexbs Age

Notdry Public

My Commission Expires:

From:

Timothy L. Mitchell

To:

Brett Ledermeier;

Ce:

Lisa Rose; Chelsea Cooke

Subject: Date: Attachments: Importance:

RE: Sweatman v Zeeman - CAFN: 21CV9795 - Settlement Offer Friday, May 26, 2023 11:48:29 AM image001.pnqg High

Brett:

| apologize for the continued follow up, but if we don’t hear back we will have to unilaterally set your client’s deposition. produced in connection with your client’s counterclaim.

Please let us know when we can expect these records.

| understand that there are still outstanding documents that have yet to be

Please give me a call to discuss. Thank you and have a great holiday weekend.

Timothy L. Mitchell C: (810) 348-1942

From: Timothy L. Mitchell Sent: Tuesday, May 23, 2023 9:14 AM

To: Brett Ledermeier bledermeier@mmatllaw.com; banksnriedel@hotmail.com

Cc: Lisa Rose lisa@roselitigation.lawyer; Chelsea Cooke ccooke@cmlawfirm.com Subject: RE: Sweatman v Zeeman - CAFN: 21CV9795 - Settlement Offer Importance: High

Brett:

Good morning. Please let me know when you or your cocousnel would be available for a call to discuss next steps in this case. Thank you.

ie Cruser, Mitchell, Novitz, Sanchez, Gaston & Zimet, LLP C: (810) 348-1942

: ; imitchell@cmlawfirm.com

<GRUSER MITCHELL” quill Mitchell, Novitz, Sanchez, Gaston & Zimet LLP California | Florida | Georgia | Indiana

New Jersey | New York | Pennsylvania | Washington www.cmlawfirm.com

This message and any attachments may contain information that is CONFIDENTIAL and/or legally protected under attorney work product, attorney-client communication, joint defense or another recognized privilege. If you are not one of the above-named recipients, your receipt of this message was inadvertent and you are not to read, copy, disseminate or otherwise use this message and attachments. If you have received this message in error, please immediately delete the message, attachments and any hard drive copies, and notify sender so that the error may be corrected. View our firm's COVID-19 polic

From: Chelsea Cooke ccooke@cmlawfirm.com Sent: Friday, May 19, 2023 12:01 PM

To: Brett Ledermeier bledermeier@mmatllaw.com; banksnriedel@hotmail.com

Ce: Timothy

L. Mitchell tmitchell@cmlawfirm.com; Lisa Rose <lisa@roselitigation. lawyer>

Subject: RE: Sweatman v Zeeman - CAFN: 21CV9795 - Settlement Offer Good afternoon,

Were you able to get some dates that Sarah Zeeman would be available for a deposition? Also, could you please let us know when a good time would be to get on a phone call to discuss this case with you all? We look forward to hearing from you. Best Regards, Chelsea Cooke D: (404) 881-2634 O: (404) 881-2622

From: Brett Ledermeier bledermeier@mmatllaw.com Sent: Tuesday, May 16, 2023 3:50 PM

To: Chelsea Cooke ccooke@cmlawfirm.com; banksnriedel@hotmailcom Ce: Timothy L. Mitchell tmitchell@cmlawfirm.com; Lisa Rose <lisa@roselitigation. lawyer> Subject: RE: Sweatman v Zeeman - CAFN: 21CV9795 - Settlement Offer Chelsea,

| apologize for any delay. As you know, Ms. Zeeman has several counsel involved each of which are limited in representation. | will reach out to Ms. Zeeman and her private counsel and let you know which dates are available.

As a separate matter, | will be out of the office Wednesday through Friday, but | will have access to my email should anything come up. Brett Michael-Schiff Ledermeier 11625 Rainwater Drive | Ste 125

|

Alpharetta, Ga 30009

Direct: 404.365.4564 Main: 770.200.7000 bledermeier@mmatllaw.com

McLaIn |MERRITT 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: Chelsea Cooke ccooke@cmlawfirm.com Sent: Tuesday, May 16, 2023 3:46 PM

To: Brett Ledermeier bledermeier@mmatllaw.com; banksnriedel@hotmail.com

Ce: Timothy L. Mitchell tmitchell@cmlawfirm.com; Lisa Rose <lisa@roselitigation Jawyer>

EXHIBIT A

Subject: RE: Sweatman v Zeeman - CAFN: 21CV9795 - Settlement Offer

Good afternoon, As of today, we have not received a response to our offer of settlement. Could you please provide us with dates that your client would be available to have her deposition taken?

Best Regards, Chelsea Cooke D: (404) 881-2634 O: (404) 881-2622

From: Chelsea Cooke Sent: Friday, May 5, 2023 2:11 PM

To: 'bledermeier@mmatllaw.com' bledermeier@mmatllaw.com; 'banksnriedel@ hotmail.com! banksnriedel@hotmail.com Ce: Timothy L. Mitchell tmitchell@cmlawfirm.com; Lisa Rose <lisa@roselitigation. Jawyer> Subject: Sweatman v Zeeman - CAFN: 21CV9795 - Settlement Offer

Good afternoon Brett and Jeff,

| hope this email finds you well. As you know, Mr. Sweatman, though our co-counsel Lisa Rose, presented an offer of settlement on January 31, 2023 for Ms. Zeeman’s consideration. To date, we have received no response to that offer. As you also know, we have a discovery deadline of July 14, 2023 in this case. Based on the amount of time in which Ms. Zeeman has had the offer and the upcoming discovery deadline, we ask that you respond to the offer no later than May 15, 2023. In the event that you do not respond to the offer by then, we will need to move forward with discovery in this case.

Please feel free to call if you would like to discuss. We look forward to hearing from you. Best Regards, Chelsea Cooke

Associate

Cruser, Mitchell, Novitz, Sanchez, Gaston & Zimet, LLP Atlanta Office

Meridian II, Suite 2000 | 275 Scientific Drive | Peachtree Corners, Georgia 30092 (404) 881-2634 direct (404) 881-2622 main line ccooke@cmlawfirm.com www. cmliawfirm.com

<Coie) CRUSER Mitchell, MITCHELL’ Novitz, Sanchez, Gaston & Zimet LLP

California | Florida | Georgia | Indiana | New Jersey | New York | Pennsylvania | Washington This message and any attachments may contain information that is CONFIDENTIAL and/or legally protected under attorney work product, attorney-client communication, joint defense or another recognized privilege.

If you are not one of the

above-named recipients, your receipt of this message was inadvertent and you are not to read, copy, disseminate or otherwise use this message and attachments. If you have received this message in error, please immediately delete the

message, attachments and any hard drive copies, and notify sender so that the error may be corrected. :

itm’s

COVID-19 poli

From:

Chelsea Cooke

To:

jeffsban

Cc:

Timothy L. Mitchell; Lisa Rose; Brett Ledermeier; banksnriedel@hotmail.com

hotmail.com

Subject:

Johnathan Sweatman v. Sarah Zeeman - Civil Action File No. 21A9795 - Sarah Zeeman"s supplemental discovery

Date:

Thursday, June 1, 2023 4:20:00 PM

Attachments:

6-22-22 - Email correspondence from Lisa Rose to Sarah Zeeman"s counsel.pdf

responses

6.4 to Zeeman.5.5.22 (04055187). pdf

Good afternoon Jeff,

It was a pleasure speaking with you. As stated, the deadline for discovery in this case is July 14, 2023. As we need to complete all depositions and site inspections prior to this deadline, we are following up to make sure we have all responsive documents from your client.