Subpoena For Depo Production Of Docs From Lee Webb Ocr¶

FILED 8/7/2023 6:56 PM CLERK OF SUPERIOR COURT DEKALB COUNTY GEORGIA

IN THE SUPERIOR COURT OF DEKALB COUNTY STATE OF GEORGIA

JONATHAN SWEATMAN, Petitioner,

V.

CIVIL ACTION FILE NO. 21CV9795

SARAH ZEEMAN,

Respondent / Counterclaim Petitioner. V.

JONATHAN SWEATMAN, Counterclaim Respondent.

SUBPOENA FOR DEPOSITION AND FOR PRODUCTION OF DOCUMENTS DIRECTED TO LEE WEBB TO:

LEE WEBB Shields Engineering Group, Inc. 409 John Wesley Dobbs Ave, Suite F Atlanta, GA 30312

GREETINGS:

Pursuant to O.C.G.A. § 9-11-30(b)(6), § 9-11-45 and § 24-10-22, YOU ARE HEREBY COMMANDED that laying all other business aside, you appear and produce the documents

identified on Exhibit “A” attached hereto at Banks & Riedel, Attorneys at Law at 1301 Shiloh Rd NW. Ste 1610. Kennesaw, GA 30144, on Thursday, August 31, 2023 at 10:00 a.m., before an authorized court reporter, and be sworn as a witness in the above-styled case for the purpose of giving a deposition on oral examination.

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If you have any questions about this Subpoena, please call Timothy L. Mitchell, attorney for the Defendant. HEREIN FAIL NOT UNDER PENALTY OF THE LAW.

This 7th day of August, 2023.

CRUSER, MITCHELL, NOVITZ, SANCHEZ, GASTON & ZIMET, LLP ~

TIMOTHY L. MITCHELL Georgia Bar No. 460744 CHELSEA T. COOKE

Meridian II, Suite 2000

Georgia Bar No. 209502

275 Scientific Drive

Attorneys for Counterclaim Defendant

Peachtree Corners, GA 30092

Johnathan Sweatman

(404) 881-2622 | (404) 881-2630 — fax tmitchell@cmlawfirm.com ccooke @cmlawfirm.com

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EXHIBIT A

DEFINITIONS As used in the Requests for Production of Documents herein, the following terms shall have the scope and meaning indicated: 1.

“YOU,” “YOUR, “YOURS” means Deponent Lee Webb.

2.

“ANYONE ACTING ON YOUR BEHALF” shall refer to any PERSON acting as

YOUR agent, representative, or fiduciary, including YOUR attorneys.

3,

“ZEEMAN” shall mean and refer to Respondent SARAH ZEEMAN, including her agents,

attorneys, employees, or other representatives.

4.

“DOCUMENT?” shall be construed in the broadest possible sense and means as allowed

under the Georgia Rules of Civil Procedure, and includes all writings (as defined in O.C.G.A. § 24-10-1001), recordings, and photographs as well as all drawings, graphs, charts, phonorecords,

emails, computer records, computer disks, hard drives, originals (as defined by O.C.G.A. § 24-101003) and shall include without limitation, any recordation of any intelligence or information, whether handwritten, typed, printed or otherwise magnetically, optically, visually or aurally stored or reproduced, including but not limited to letters, correspondence, memoranda, telegrams, notes, reports, compilations, data, notebooks, work papers, graphs, charts, blueprints, books, pamphlets, brochures,

circulars,

manuals,

instructions,

ledgers,

drawings,

photographs,

diaries,

sales

literature, advertising literature, agreements, minutes of meetings, punch cards, magnetic tape or wire,

other

machine

producible

records

including

films,

videotapes,

DVDs

and

sound

reproductions, printout sheets, electronic records such as electronic mail, facsimiles, summaries or records of telephone conversations, personal conversations or interviews, and any and all other writings, typings, printings, drafts, copies and/or mechanical, magnetic, optic, or photographic

reproductions or recordations thereof in the possession, custody or control of Propounding Party or known to Propounding Party, whether or not prepared by Propounding Party. A draft or nonidentical copy is a separate document within the meaning of this term.

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5.

“RELATE” and/or “REFER” shall be deemed to be a demand for any DOCUMENTS

reflecting, referring to, embodying, continuing, constituting, identifying, stating, dealing with, evidencing or in any relevant to the describe subject matter of the category of documents or things requested, or any portion thereof.

6.

“CURRENT ACTION” or “COMPLAINT” shall be deemed to mean the action

captioned Jonathan Sweatman vy. Sarah Zeeman; DeKalb County Superior Court Case No. 21CV9795.

7.

“COMMUNICATION” means and includes an and all written, oral, telephonic or other

inquiries, statements, discussion, conversations, negotiations, agreements, understandings, meetings, letters, notes, email, text messages, digital recordings, advertisements and interviews, and any and all documents (as hereinafter defined) related thereto. REQUESTS FOR PRODUCTION OF DOCUMENTS REQUEST FOR PRODUCTION NO. 1. YOUR entire file related to any and all of YOUR work as an expert witness in the CURRENT ACTION.

REQUEST FOR PRODUCTION NO. 2. YOUR current curriculum vitae or resume.

REQUEST FOR PRODUCTION NO. 3. YOUR current fee schedule.

REQUEST FOR PRODUCTION NO. 4. Any and all billing records for work YOU performed or will perform related to this CURRENT ACTION.

REQUEST FOR PRODUCTION NO. 5. Any DOCUMENTS related to any additional or future work that YOU may perform as an expert witness in the CURRENT ACTION. REQUEST FOR PRODUCTION NO. 6.

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Any and all exhibits or charts YOU intend to use as an illustration, summary, or

demonstrative evidence in this CURRENT ACTION. REQUEST FOR PRODUCTION NO. 7. Any and all DOCUMENTS YOU reviewed, consulted, considered in forming any opinion in the CURRENT ACTION.

REQUEST FOR PRODUCTION NO. 8. Any and all COMMUNICATIONS between YOU and any other PERSON(s) related to this CURRENT ACTION.

REQUEST FOR PRODUCTION NO. 9. Any and all treatises, articles, or publications of any kind, which YOU consulted in rendering any opinion that YOU will express in this matter.

REQUEST FOR PRODUCTION NO. 10. Any and all treatises, articles, or publications of any kind, which YOU have authored, coauthored or edited. REQUEST FOR PRODUCTION NO. 11. Any and all DOCUMENTS whatsoever related to any summaries provided to YOU by

any PERSON(s) related to this CURRENT ACTION. REQUEST FOR PRODUCTION NO. 12. Any and all contracts or agreements between YOU and Sarah Zeeman or her counsel concerning the services performed in this CURRENT ACTION. REQUEST FOR PRODUCTION NO. 13.

Any and all emails between YOU and SARAH ZEEMAN ’s counsel regarding the CURRENT ACTION.

REQUEST FOR PRODUCTION NO. 14. Any and all DOCUMENTS related to the substance of any opinion YOU intend to provide in this CURRENT ACTION.

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REQUEST FOR PRODUCTION NO. 15. Any and all records related to the properties located at 2746 Grove Street, Atlanta, GA 30319 and 2740 Grove Street, Atlanta, GA 30319. REQUEST FOR PRODUCTION NO. 16. Any and all documents related to Sarah Zeeman or Jonathan Sweatman.

Respectfully submitted, this 7th day of August, 2023.

CRUSER, MITCHELL, NOVITZ, SANCHEZ, GASTON & ZIMET, LLP

Meridian II, Suite 2000

TIMOTHY L. MITCHELL Georgia Bar No. 460744 CHELSEA T. COOKE Georgia Bar No. 209502

275 Scientific Drive

Attorneys for Counterclaim Defendant

Peachtree Corners, GA 30092

Jonathan Sweatman

(404) 881-2622 | (404) 881-2630 — fax ccooke@cmlawfirm.com

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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.

§

§ CERTIFICATE OF SERVICE I HEREBY CERTIPY that I have this day electronically filed the within and foregoing

SUBPOENA FOR DEPOSITION AND FOR PRODUCTION OF DOCUMENTS DIRECTED TO LEE WEBB by filing same with the Clerk of Court using the PeachCourt efiling system which will automatically send e-mail notification of such filing to the following attorneys of record: Lisa K. Rose, Esq,

Jeff Banks, Esq.

Rose Litigation, LLC

Banks & Riedel, PC

4880 Lower Roswell Road, Suite 165-522

970 Walnut Street

Marietta, GA 30068

Macon, GA 31201

Lisa@roselitigation.lawyer

jeffsbanks@hotmail.com

Attorney for Petitioner Sweatman

banksnriedel@hotmail.com Attorneys for Respondent Zeeman

Brett Ledermeier, Esq. 11625 Rainwater Drive, Suite

Noah Cadwell, Esq. 125

David M. Atkinson, Esq.

Alpharetta, GA 30009

Swift, Currie, McGhee & Hiers, LLP

bledermeier@mmatllaw.com

1355 Peachtree Street, NE, Suite 300

Attorneys for Counterclaim Petition Zeeman

Atlanta, GA 30309 noah.caldwell(@swiftcurrie.com david.atkinson@swiftcurrie.com Attorneys for Respondent Zeeman

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Respectfully submitted, this 7th day of August, 2023.

CRUSER, MITCHELL, NOVITZ, SANCHEZ, GASTON & ZIMET, LLP

TIMOTHY L. MITCHELL Georgia Bar No. 460744 CHELSEA T. COOKE Meridian II, Suite 2000

Georgia Bar No. 209502

275 Scientific Drive

Attorneys for Counterclaim Defendant

Peachtree Corners, GA 30092

Jonathan Sweatman

(404) 881-2622 | (404) 881-2630 — fax ccooke @cmlawfirm.com

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