Subpoena Chastain With Cover Letter Ocr¶

i,

4880 Lower Roswell Road, Suite 165-522 Marietta, GA 30068 www.roselitigation. lawyer

ROSE

| LITIGATION

lisa@roselitigation.lawyer 678-806-8188

June 3, 2022

VIA OVERNIGHT DELIVERY FEDERAL EXPRESS Tracking #7770 3859 2649 Chastain & Associates, P.C.

c/o Mark E. Chastain, President 288 North Main Street Ellijay, GA 30540 Re:

Jonathan Sweatman vy. Sarah Zeeman Superior Court of DeKalb County Civil Action File Number: 21CV9795

Dear Mark Chastain:

Please be advised that I represent the interests of Petitioner Jonathan Sweatman with respect to that certain lawsuit identified above. Enclosed please find a Subpoena for the Production

of Documentary Evidence to be used as evidence in said lawsuit. In lieu of producing the documents in person, you may produce the requested documents along with the executed attached Certificate of Authenticity to be completed by the custodian of

records who prepares the requested documents, all to be received by the undersigned on or before July 3, 2022.

Please call the undersigned at the office number listed above with any questions or concerns.

Sincerely,

Lisa oar Lisa K. Rose

Enclosures

ce:

David M. Atkinson (david.atkinson@swiftcurrie.com) Tania R. Tuttle (ttuttle@mmatllaw.com)

Sarah C. Monico (smonico@mmatllaw.com) Brett M. Ledermeier (bledermeier@mmatllaw.com) Richard J. Capriola (rcapriola@wezlaw.com) Eric B. Coleman (ecoleman@wezlaw.com)

IN THE SUPERIOR COURT OF DEKALB COUNTY

STATE OF GEORGIA JONATHAN SWEATMAN,

Petitioner, v.

)

)

) )

CIVIL ACTION FILE NO.

)

21CV9795

) SARAH ZEEMAN,

Respondent.

)

)

) )

SUBPOENA FOR THE PRODUCTION OF DOCUMENTARY EVIDENCE To:

Chastain & Associates, P.C. c/o Mark E. Chastain, President 288 North Main Street

Ellijay, GA 30540 Pursuant to the provisions of O.C.G.A. § 24-13-23, you are hereby required to produce documentary evidence as outlined in Exhibit A attached hereto, on or before July 3, 2022 in the case pending before the Superior Court of DeKalb County, Civil Action File Number 21CV9795,

to the offices of counsel for Petitioner, Lisa K. Rose, Rose Litigation, LLC, 4880 Lower Roswell Road, Suite 165-522, Marietta, GA 30068. The documents may be produced in person or by mail. Herein fail not, under penalty of law.

SW

isa K. Rose

V2 ne

Georgia Bar No. 614204 Attorney for Petitioner

ROSE LITIGATION, LLC 4880 Lower Roswell Road Suite 165-522

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

EXHIBIT A

SUPBOENA FOR PRODUCTION OF EVIDENCE

SUBPOENA FOR PRODUCTION OF DOCUMENTS The documents to be produced by you are as follows: 1.

Copies of any and all draft surveys prepared for Sarah Zeeman for the real property identified as 2740 Grove Street, Atlanta, Georgia 30319 (the “Property”).

2.

Copies of any and all surveys prepared for Sarah Zeeman for the Property.

3.

Copies of any and all written correspondence by and between you and Sarah Zeeman regarding the Property.

4.

Copies of any and all field notes prepared by you in the preparation of drafting a survey

for the Property. ye

This day of June, 2022. ROSE LITIGATION, LLC

/s/ Lisa K. Rose

Lisa K. Rose Georgia Bar No. 614204 Attorney for Petitioner 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 SUBPOENA FOR

THE PRODUCTION OF DOCUMENTARY EVIDENCE upon the counsel or parties listed below by e-file electronic service, electronic mail, and/or placing a copy of same in the United States Mail, in a properly stamped envelope with adequate postage thereon and 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@wezlaw.com) Winter Capriola Zenner, LLC 3490 Piedmont Road, NE, Suite 800 Atlanta, GA 30305 a

This 2% day of June, 2022. ROSE LITIGATION, LLC

Z

Georgia Bar No. 614204 Attorney for Petitioner

4880 Lower Roswell Road Suite 165-522

Marietta, Georgia 30068 Telephone: (678) 806-8188

lisa@roselitigation. lawyer

IN THE SUPERIOR COURT OF DEKALB COUNTY STATE OF GEORGIA JONATHAN SWEATMAN,

)

) )

Petitioner, v.

)

CIVIL ACTION FILE NO.

)

21CV9795

) SARAH ZEEMAN,

A)

Respondent.

)

) )

CERTIFICATION OF AUTHENTICITY

COMES

NOW

who, being first duly sworn, states under oath that the attached records are true, legible, correct, and complete.

Iam an agent, employee, and/or representative of Chastain & Associates, P.C. and my title is

I

am over the age of 18 and fully competent to sign this Certification. I am a custodian of the records for Chastain & Associates, P.C. or am otherwise qualified to attest to the matters set forth in this Certification. This Certification is made regarding the documents produced by Chastain & Associates, P.C. (the “Documents”) on

I hereby certify that the Documents were made at or near the time of the occurrence of the matters set forth in those Documents by (a) a person with knowledge of those matters, or (b) from

information transmitted by a person with knowledge of said matters set forth in those Documents.

I further certify that the Documents are kept in the course of the regularly conducted activity of Chastain & Associates, P.C.

I further certify that it is a regular business practice of Chastain & Associates, P.C. to create or maintain the Documents.

I further certify that said Documents with this certificate were delivered to Lisa K. Rose, Rose Litigation, LLC, attorneys for Petitioner, who sought production of these Documents. This

day of

, 2022.

AFFIANT

Sworn to and subscribed before me by this

day of

NOTARY PUBLIC My Commission Expires: [NOTARY SEAL]

2022,