Re Sweatman V. Zeeman Zeeman Discovery Responses Statutory Electronic Serviceeric B. Coleman Ecolemanwczlaw.Com 1¶
| Field | Value |
|---|---|
| Category | Discovery > Discovery Motions |
| Confidence | high |
| Reason | Attorney proposing protective order for medical records in discovery dispute |
| Original File | re-sweatman-v.-zeeman-zeeman-discovery-responses-statutory-electronic-serviceeric-b.-coleman-ecolemanwczlaw.com-1.msg |
| File Type | MSG |
Email¶
| Header | Value |
|---|---|
| From | ecoleman@wczlaw.com |
| To | Lisa Rose; Tania Tuttle; Richard J. Capriola; david.atkinson@swiftcurrie.com |
| Subject | RE: Sweatman v. Zeeman; Zeeman Discovery Responses - Statutory Electronic ServiceEric B. Coleman ecoleman@wczlaw.com |
| Date | Sweatman v. Zeeman; Zeeman Discovery Responses - Statutory Electronic ServiceEric B. Coleman ecoleman@wczlaw.com |
Email Body
Lisa:
Thank you for taking my call today. To reiterate our conversation, here is what we have agreed to resolve the concerns raised in your 6.4 letter:
- Ms. Zeeman will produce relevant medical records in accordance with your narrowed request. But before doing so, my client requests that a protective order be entered in this case that limits the use of her personal medical records to this case and prohibits any public unsealed filing of the same absent a court order. The records will be destroyed at the conclusion of this matter. My office will prepare that motion and proposed order.
- Ms. Zeeman will produce today, via the Dropbox link below, her responsive documents absent the medical records as discussed above. We both understood and agreed that to best of my knowledge, these have not yet been reviewed by my co-counsel in this matter. To that end, we have agreed that Ms. Zeeman shall have the right to claw back any objectional documents included in the link below.
- Ms. Zeeman will reproduce the documents that we are turning over today as soon as possible with Bates labels.
Please let me know if I am mistaken on any of the above.
Here is the link to the responsive material with the caveats set forth above:
https://www.dropbox.com/sh/w6dn58khxureebd/AAA8rVx8b-8cM4ZS46h4hWaWa?dl=0
Have nice weekend.
Eric B. Coleman http://www.wczlaw.net/attorneys/eric-coleman/
Attorney at Law
Partner
One Ameris Center
3490 Piedmont Road NE | Suite 800
Atlanta, Georgia 30305
direct: 404.844.5663
mobile: 678.975.0703
ecoleman@wczlaw.com ecoleman@wczlaw.com
www.wczlaw.com http://www.wczlaw.com/ | view my bio http://www.wczlaw.com/attorneys/eric-coleman/
http://www.linkedin.com/in/ebcolema
From: Lisa Rose lisa@roselitigation.lawyer Sent: Monday, May 09, 2022 4:04 PM To: Tania Tuttle ttuttle@mmatllaw.com; Richard J. Capriola rcapriola@wczlaw.com; david.atkinson@swiftcurrie.com Cc: Brett Ledermeier bledermeier@mmatllaw.com; Eric B. Coleman ecoleman@wczlaw.com; Joseph G. Emanuel joseph.emanuel@swiftcurrie.com Subject: RE: Sweatman v. Zeeman; Zeeman Discovery Responses - Statutory Electronic ServiceEric B. Coleman ecoleman@wczlaw.com
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Counsel,
Please see the attached correspondence.
-Lisa
Lisa Rose Rose Litigation, LLC
Mailing: 4880 Lower Roswell Rd. Ste 165-522 Marietta, GA 30068
Physical: 533 Johnson Ferry Road, Bld. D, Suite 400, Marietta, GA 30068 O: 678.806.8188
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From: Lisa Rose Sent: Tuesday, May 3, 2022 9:38 AM To: Tania Tuttle <ttuttle@mmatllaw.com ttuttle@mmatllaw.com >; Brett Ledermeier <bledermeier@mmatllaw.com bledermeier@mmatllaw.com >; Lucy Aquino <Lucy.Aquino@swiftcurrie.com Lucy.Aquino@swiftcurrie.com >; Richard J. Capriola <rcapriola@wczlaw.com rcapriola@wczlaw.com >; Eric B. Coleman <ecoleman@wczlaw.com ecoleman@wczlaw.com > Subject: RE: Sweatman v. Zeeman; Zeeman Discovery Responses - Statutory Electronic Service
Counsel:
Good morning. Last week I sent a request for permission for my client and his contractor to gain temporary access to your clients property in an effort to preserve and protect the fence. In addition to the preservation of the fence, painting and staining the fence will enhance the aesthetics of the fence for your client. In addition, I requested an update on the documents that were to be provided shortly after 4.1.22.
I have not heard back from anyone in response to both requests, other than Tanias email below. Please provide an update on both items.
I am available to discuss the parameters around th