Re 2Nd Notice Spring Maintenance Visit 1¶

@ Eric & Rich 1. Please advise either to move forward or postpone the yearly HVAC service

1. Discovery document concerns - 2 voice recordings

   a) Haight Davis engineer 3/17/22 - mentions his concerns about the former ATT box corner being elevated causing water pooling + other issues.

   b) 2740 Grove St recording 1/7/22 - (both have the same name & could get confused)

   Version 1 (44 min)  cut to end when COB left
   Version 2 (46 min) includes a 2 min personal conversation after COB left &  don't want it to be shared with Sweatman.,
   

On Thu, Apr 14, 2022 at 7:55 PM Sally L. Monico <SCook@mmatllaw.com SCook@mmatllaw.com > wrote:

Sarah, per your request and as a f/u to Tanias email below, email to Lisa Rose, copying your private counsel and Lucy, attached.  You are not copied as including you would constitute a waiver of attorney client privilege.

We are supposed to have a call with Eric Coleman, Richs partner, copied here, to discuss discovery document production tomorrow at 1:00 PM.  However, we will postpone pending your conversation with Rich.

Please have Rich or Eric reach out to us to coordinate next steps regarding discovery once you have had a chance to discuss.

We will not take any further action until we hear from Rich and Eric.

Sally Monico
11625 Rainwater Drive | Ste. 125 | Alpharetta, Georgia 30009
Direct:  404.365.4506

Main: 404.266.9171

smonico@mmatllaw.com <mailto:smonico@mmatllaw.com>

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If you are in need of immediate assistance or in the event of emergency please contact Tania Tuttle (ttuttle@mmatllaw.com <mailto:ttuttle@mmatllaw.com> ).

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From: Sarah Zeeman <szeeman@gmail.com <mailto:szeeman@gmail.com> > 
Sent: Thursday, April 14, 2022 7:34 PM
To: Tania Tuttle <ttuttle@mmatllaw.com <mailto:ttuttle@mmatllaw.com> >
Cc: Brett Ledermeier <bledermeier@mmatllaw.com <mailto:bledermeier@mmatllaw.com> >; Sally L. Monico <SCook@mmatllaw.com <mailto:SCook@mmatllaw.com> >
Subject: Re: 2nd Notice! Spring - Maintenance Visit

1. Thank you. I will confirm with Rick tomorrow if its best to have the hvac service postponed etc. this is why I requested a copy of the email(if possible to have ) so I could add onto it asking Rick etc.

2. What is the next step now that the discovery questions were submitted/logged?

On Thu, Apr 14, 2022 at 7:13 PM Tania Tuttle <ttuttle@mmatllaw.com <mailto:ttuttle@mmatllaw.com> > wrote:

    Sarah  the chances of HVAC professionals not accidently stepping onto the property of the Sweatmans is beyond slim in my opinion. Its just too narrow an area and even if they say they could, with tempers so high, I would never advise you to do that if you didnt want to provide a heads up to protect you and your HVAC people.  You may just want to postpone the service and we can send an email stating to ignore our prior correspondence as to the same.  I dont want to see this blow up and cause you more potential damages and fees.  If Lisa came back with any questions or concerns, I would tell you to call it off regardless.

    However, if you want them to come  which is totally fine - this was the way it should be handled. Sally and I discussed prior to her reaching out.  I have had two decades of experience handling these types of matters and am not going to take any steps that put any of your claims at issue, whether covered or not.  It has absolutely no effect whatsoever on any claims or counterclaims. It is pure courtesy and done to avoid expansion of litigation and additional trespass claims in such a hotly contested matter.  Lets say, for example, the reverse happens and the Sweatmans crossed into your property without any sort of warning to us or okay by you (your property, not disputed property), you would likely have concerns and would call your attorneys and/or the cops.  The Sweatmans could do the same  and drag your HVAC guys in if they really wanted to