Rpds To Zeeman.Docx¶

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

PETITIONER'S REQUESTS FOR PRODUCTION OF DOCUMENTS TO RESPONDENT SARAH ZEEMAN COMES NOW Petitioner Jonathan Sweatman ("Petitioner" or "Sweatman"), in the above styled lawsuit, and pursuant to O.C.G.A. § 9-11-34, hereby serves this his First Requests for Production of Documents to Respondent Sarah Zeeman ("Respondent" or "Zeeman"). Said Respondent is hereby requested to produce for inspection and copying the following requested documents within thirty three (33) days of date below, at the offices of counsel for Plaintiff, Lisa K. Rose, Rose Litigation, LLC, 4880 Lower Roswell Road, Suite 165, Roswell, Georgia 30068. The documents may be produced in person or by mail. DEFINITIONS AND INSTRUCTIONS A. When used herein, the terms "Respondent", "you," "your," or any synonym thereof are intended to and shall embrace and include, in addition to said Respondent, her assigns, employees, agents, officers, or representatives of said Respondent or any other person acting or purporting to act on behalf of said Respondent, who is in possession of or may have obtained information for or on behalf of said Respondent. 13. "Person" means any person and includes natural persons, private and public corporations, partnerships, associations, joint ventures, sole proprietorships, firms and any other business enterprise or entity of any description whatsoever.

"Document" means all written, printed, or recorded matter of any kind, wherever located, including the originals and all non-identical copies, whether different from original by reason of any notation made on such copies or otherwise, graphics or oral records or representations of any kind within Respondent's possession, custody, or control. "Communication" means any oral or written statement, dialogue, colloquy, email, fax, letter, memo, discussion or conversation and also any transfer of thoughts or ideas between persons by means of documents, and includes any transfer of data from one location to another by electronic or similar means. "Identify," "identification," "identify," "describe," "state," and "set forth" mean: 1. With reference to a natural person: State the full name; State the present home address and business address or the last known such addresses if present addresses are unknown; State the present home and business telephone number or the last such telephone numbers if present telephone numbers are unknown; and 2. With reference to a "person" other than a natural person ("entity"): State the form of organization, and in the case of a corporation, the state of incorporation if within the United States, or the country of incorporation if outside the United States; State the address of principal place of business; State the persons at the entity having personal knowledge of the matters with respect to which such entity is named. 3. With reference to a document: State the date, type of document (e.g., letter, memorandum), author, addresses and recipients, title and file or identifying marking, its present location or custodian, and all other means of identifying it with sufficient particularity to satisfy the requirement for its identification in a request for its production, pursuant to O.C.G.A. § 9-11-33; or alternatively annex to and incorporate by reference in the answers to these interrogatories a true and correct copy thereof; and If any such document was, but no longer is, in your possession or subject to your control, state the disposition that was made of it, by whom, the reason for such disposition and the date thereof. 4. With reference to a communication: (a) State the substance of the communication;

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State the identity of the persons between or among whom the communication was made; State the identity of all persons present when the communication took place; State the date and time when the communication was made and the manner in which it occurred (e.g., meeting, telephone conversation); and Whenever the conjunction "and" is used, it is also to be interpreted disjunctively, and conversely, when the disjunctive "or" is used it is also to be interpreted conjunctively. The present tense of a verb includes past tense and vice versa, use of the singular includes the plural and vice versa, and use of the masculine gender includes the feminine gender and vice versa. If any information, communication or document is withheld under claim of privilege, identify for each such item of information, communication, or document the person(s) with personal knowledge of the information withheld, the parties to any communication withheld, the author(s) and recipient(s) of any document withheld, each person to whom a copy (copies) of any such document was furnished, the date(s) and subject matter of any information, communication or document as to which a privilege is claimed, and the nature of the privilege claimed as well as the basis for such claim. All responses which refer back to previously stated responses or answers ("supra") shall explicitly designate the number and, if applicable, the subsection of each previous response or answer relied upon. The term "Petition" refers to the Verified Petition for Equitable Relief filed by Petitioner on November 12, 2021. The term "Counterclaim" refers to the Verified Answer and Counterclaim of Respondent Sarah Zeeman filed by Respondent on January 13, 2022. Any word not defined in this section shall have the same meaning as commonly used in the English language.

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REQUESTS FOR PRODUCTION OF DOCUMENTS The documents to be produced by Respondent are as follows: Request for Production No. 1 Copies of any and all documents utilized, consulted, or relied upon by Respondent in preparation of the Counterclaim. Request for Production No. 2 Copies of any and all documents which contain relevant information in support of any claim asserted by Respondent in this action, or which are relied upon to demonstrate or support facts relevant to this litigation. Request for Production No. 3 Copies of any and all documents which contain relevant information in support of any defense asserted by Respondent in this action, or which are relied upon to demonstrate or support facts relevant to this litigation. Request for Production No. 4 Copies of any and all documents referred to in Respondent's Counterclaim. Request for Production No. 5 Copies of any and all documents evidencing any communications by and between Petitioner and Respondent that relate to the subject matter of this litigation. Request for Production No. 6 Copies of any and all documents evidencing any communications by and between Respondent and any non-party that relate to the subject matter of this litigation. 4

Request for Production No. 7 All documents utilized, consulted or relied upon by you in preparation of your responses to Respondent's First Interrogatories to Respondent. Request for Production No. 8 Copies of any and all documents evidencing Respondent's alleged damages as alleged in the Counterclaim. Request for Production No. 9 Copies of any and all documents evidencing Petitioner's alleged trespass in Respondent's property. Request for Production No. 10 Copies of any and all documents evidencing an alleged overflow of water from Petitioner's Property onto Respondent's property that Respondent contends caused her damages. Request for Production No. 11 Copies of any and all estimates prepared by a non-party to remediate any purported damage to Respondent's property as it relates to the allegations raised in the Petition or Counterclaim. Request for Production. No. 12 Copies of any and all documents showing communications between Respondent and any non-party who examined the purported water entry on Respondent's property. Request for Production. No. 13 Copies of any and all documents showing communications by and between Respondent and the City of Brookhaven regarding the subject matter of the Petition and/or Counterclaims.

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Request for Production No. 14 Copies of any and all documents that demonstrate Respondent and/or Respondent's predecessors' possession of the strip of land defined in the Counterclaim as the "Disputed Area" Request for Production No. 15 Copies of any and all documents that demonstrate Respondent and/or Respondent's predecessors' use of the strip of land defined in the Counterclaim as the "Disputed Area.". Request for Production No. 16 Copies of all correspondence by and between Respondent and Petitioner regarding the removal of the prior fence and/or construction of the new fence. Request for Production No. 17 Copies of any and all documents demonstrating or quantifying any alleged damage to Respondent's Property caused by water entry allegedly caused by Petitioner. Request for Production No. 18 Copies of any and all documents evidencing any communications by and between Respondent and any non-party that relate to the subject matter of the Petition and/or Counterclaims. Request for Production No. 19 Any and all documents which demonstrate how Petitioner's actions or inactions harmed Respondent. Request for Production No. 20 Copies of all photographs and videos that relate to Respondent's alleged damages.

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Request for Production No. 21 Copies of all reports created by each expert that is expected to testify on behalf of Respondent. Request for Production No. 22 Copies of all reports created by each witness that is expected to testify on behalf of Respondent. Request for Production No. 23 Copies of any and all documents showing communications by and between Respondent and any professional surveyor regarding the Property. Request for Production No. 24 Copies of any and all documents showing communications by and between Respondent and any contractor to address or remediate any alleged damaged caused by Petitioner to Respondent's Property. Request for Production No. 25 Copies of any and all documents related to Respondent's purchase of the two heating ventilation and