Subpoena Ski With Cover Letter Ocr¶

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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 3843 2695

SKI Mechanical, Inc. c/o Steve Kaminski, Registered Agent 12460 Crabapple Road, Suite 202-234 Alpharetta, GA 30004

Re:

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

Dear Mr. Kaminski:

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 fete Lisa K. Rose

Enclosures ce

David M. Atkinson (david.atkinson@swiftcurrie.com) Tania R. Tuttle (ttuttlke@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,

Vv.

)

) ) )

CIVIL ACTION FILE NO.

)

21CV9795

) SARAH ZEEMAN,

Respondent.

)

) ) )

SUBPOENA FOR THE PRODUCTION OF DOCUMENTARY EVIDENCE To:

| SKI Mechanical, Inc.

c/o Steve Kaminski, Registered Agent 12460 Crabapple Road, Suite 202-234

Alpharetta, GA 30004

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.

Des

4

iSa K. Rose

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 all estimates, proposals and invoices related to the installation of the HVAC units for the benefit of Sarah Zeeman at the real property located at 2740 Grove Street,

Atlanta, Georgia 30319 (the “Property”) in August, 2015.

2.

Copies of all correspondence by and between you and Sarah Zeeman regarding all services provided at the Property from January, 2015 through December, 2015.

3.

Copies of all field notes, correspondence regarding the services provided at the Property in August, 2015.

4.

Any and all photographs taken by you related to the services provided at the Property in August, 2015. yt

This

day of June, 2022. ROSE LITIGATION, LLC

~~

Lt

. Rose

CA

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) Lucy Aquino (lucy.aquino@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 This 3rd day of June, 2022. ROSE LITIGATION, LLC —

. 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

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

)

) )

Petitioner,

Vv

)

CIVIL ACTION FILE NO.

)

21CV9795

) SARAH ZEEMAN,

)

Respondent.

) ) )

CERTIFICATION OF AUTHENTICITY

COMES

NOW

,

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

I am an agent, employee, and/or representative of SKI Mechanical, Inc. 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 SKI Mechanical, Inc. or am otherwise qualified to attest to the matters set forth in this Certification.

This Certification is made regarding the documents produced by SKI Mechanical, Inc. (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 SKI Mechanical, Inc. I further certify that it is a regular business practice of SKI Mechanical, Inc. 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 , 2022.

NOTARY PUBLIC My Commission Expires:

[NOTARY SEAL]