Zeeman Rog Responses Final¶

IN THE SUPERIOR COURT OF DEKALB COUNTY STATE OF GEORGIA

DEFENDANT SARAH ZEEMAN’S RESPONSES TO PETITIONER’S FIRST INTERROGATORIES

COMES NOW, SARAH ZEEMAN (hereinafter, “Respondent” or “Zeeman”), by and through the undersigned counsel and preserving all defenses, and conditionally responds to Petitioner’s First Interrogatories to Zeeman (hereinafter, the “Request(s)” or the “Interrogatories”) as follows: PRELIMINARY STATEMENT The following responses are based upon information presently available to Respondent which she believes to be correct. Said responses are made without prejudice to Respondent’s right to utilize subsequently discovered facts. No incidental or implied admission of fact by Respondent is made by the responses below. The only admissions are expressed admissions. The fact that Respondent has answered any request, any interrogatory, or produced any document herein may not properly be taken as an admission that they accept or admit the existence of any fact set forth or assumed by such request, or that such response constitutes admissible evidence. The fact that Respondent has answered part or all of any interrogatory is not intended to and shall not be construed to be a waiver by Respondent of all or any part of any objection by Respondent to the admissibility of evidence at trial or the relevance of the response. The responses to Petitioner’s Requests may be supplemented by Respondent’s further investigation and acquisition of information which she does not either possess or recall at this time. However, any such further supplementation shall be made only in accordance with the Georgia Civil Practice Act. Respondent shows that, notwithstanding any of the “definition(s)” or preliminary instruction(s) contained within Petitioner’s Requests, Respondent will provide responses which are required pursuant to the Georgia Civil Practice Act. As to any of the “definition(s)” which precede Petitioner’s Requests and which seek information or documents which include trial preparation and/or privileged material(s) or communication(s), Respondent objects to such “definition(s).” The information supplied in these answers is not based solely upon the knowledge of the executing party, but includes knowledge of the party, its agent(s), its representative(s) and attorney(s), unless privileged. The word usage and sentence structure may be that of the attorney assisting in the preparation of the answers and, thus, do not necessarily purport to be the precise language of the executing party(ies). The objections asserted by Respondent below are asserted in good faith, based upon counsel’s evaluation of Respondent’s discovery obligations under the Georgia Civil Practice Act. Nevertheless, Respondent offers and stands ready to confer with the Petitioner, through counsel, in an effort to resolve or narrow, to the greatest extent possible, any dispute between the parties concerning Respondent’s objections. This preliminary statement is incorporated in each of the responses set forth below. RESPONDENT ZEEMAN’S GENERAL OBJECTIONS TO PETITIONER’S FIRST INTERROGATORIES

Respondent objects to these Requests to the extent they seek the discovery of information prepared in anticipation of litigation, protected by the work product privilege, attorney-client privilege, or which information is beyond the scope of permissible discovery under the Georgia Civil Practice Act. Respondent objects to the release of any information protected by the attorney-client privilege or the attorney work-product doctrine. Respondent construes these interrogatories to exclude documents, information and communications exchanged with counsel in this and other litigation, if any. Respondent objects to these Requests as they seek documents or information which is immaterial, irrelevant and not reasonably calculated to lead to the discovery of admissible evidence. Respondent objects to Petitioner’s Requests on the ground that they are repetitive. Respondent objects to these Requests on the ground that many terms utilized are without definition and are capable of numerous interpretations, that they would have Respondent speculate to her detriment as to the definition of said terms and, therefore, Respondent cannot properly respond. Respondent objects to the extent that these Requests are deemed to be continuing as going beyond the scope of the Georgia Civil Practice Act. Respondent will supplement her answers, if required, in accordance with O.C.G.A. § 9-11-26(e). Subject to, and without waiving the above and foregoing objections, Zeeman provides the following responses to Petitioner’s First Interrogatories:

RESPONDENT’S SPECIFIC OBJECTIONS AND RESPONSES TO PLAINTIFF’S FIRST INTERROGATORIES

Interrogatory No. 1

Identify all persons having knowledge of the claims made and/or defenses raised by you in this case and provide a brief summary of the knowledge of said persons and the last known address and telephone number for said persons. RESPONSE TO INTERROGATORY NO. 1: Zeeman objects to the disclosure of medical doctors, chiropractors, practitioners of the healing arts establishment, pharmacy, or any other medical facility or any other professional medical provider that may have knowledge of the issues in this case as a result of providing treatment to Zeeman on the basis that the same is irrelevant, highly confidential, and not subject to discovery. Zeeman’s medical history is highly personal and confidential information that is irrelevant to the facts and circumstances of this case. Zeeman also objects to this request to the extent that it would require disclosure of attorney-client privileged information. Reserving all general objections, Zeeman responds as follows: Sarah Zeeman – Respondent, may be contacted through counsel. Ms. Zeeman has knowledge of the property commonly known as 2740 Grove Street, Brookhaven, GA 30319 (hereinafter, the “Zeeman Property”), all improvements thereon, and Petitioner’s actions to relating to the Zeeman Property and his property located at 2746 Grove Street, Brookhaven, GA 30319 (hereinafter, the “Sweatman Property”). In addition to Respondent, Respondent identifies the following persons in response to Interrogatory No. 1: Jennifer Flores Address: 734 Steffi CT Lawrenceville, GA 30044 Statement of what they know: Emails received from FOIA # PRR-713-2021 shows City of Brookhaven (“COB”) employee and Code enforcement officer, Orlando Flores has been telling her about Jonathan Sweatman and the situation per his emails to her from his COB email account. Brea Figura (Friendship) Address: 4906 Tennessee Ave Chattanooga, TN 37409 Phone: 4045422265 Statement of what they know: Brea has been to the Properties and seen the original fence, has seen photos/videos and aware of the pending suit and the stress and harassment. Ryan Bergamini (Friendship) Address: 3763 Ashford Dunwoody Rd NE, Brookhaven, GA 30319 Phone: 8056376447 Statement of what they know: Ryan has been to the property seen pictures and is aware of the suit. Ryan previously lived at the Zeeman Property, he took the video and pictures of the 2018 flooding coming from Sweatmans’ original buried underground pipes from his roof. Ryan has seen the original fence and Sweatman’s newly constructed fence. Josh Comiter (Friendship) Address: 3005 Peachtree RD NE Atlanta, GA 30305 Phone: 5616324031 Statement of what they know: Josh has been to the property; he has seen photos/videos and aware of the suit and the stress and harassment. Josh is aware of the sleep disturbances. Josh has not seen the original fence, he’s only seen Sweatmans’ newly constructed fence. John Cyphers (Friendship) Address: 1261 Ashford Creek NE Brookhaven, GA 30319 Phone:4046978588 Statement of what they know: John has been to the Zeeman Property; he has seen the original fence. He has seen photos/videos and aware of the pending suit and the stress and harassment. John was at the property during Linda Abaray, Murray Nicol , and Eric Long’s scheduled in person visit to the site on 1/31/22. Linda Zeeman (Family) Address: 3469 Mill Creek Rd Brookhaven, GA 30319 Phone:4042552693 Statement of what they know: Linda has been to the Zeeman Property and seen the original fence and Sweatman’s constructed new fence. Linda helps Zeeman with the dogs and doesn’t like being recorded on Sweatmans cameras. She is concerned about the stress this is causing Zeeman. David Zeeman (Family) Address: 3469 Mill Creek Rd Brookhaven, GA 30319 Phone: 4042552693 Statement of what they know: He knows there is problem with the neighbor flooding the Zeeman Property yard and the boundary line and newly constructed fence. He is in a wheelchair so has not been to the back of the Zeeman Property to view the fence up close. He is concerned at the amount of stress this is causing Zeeman. Mackenzie Crabtree (Maiden name: Bethea Zeeman - nickname Bea) (Family) Address: 608 Oak Marsh Dr Mt Pleasant, SC 29464 Phone: 4044587401 Statement of what they know: Bea has seen the original fence. Bea has seen pictures /Videos and aware of the suit and the stress and harassment. Kristina Wiltsee (Friendship) Address: 4046970987 Phone: 188 Hunters Drive SE Milledgeville, GA 31061 Statement of what they know: Kristina has seen pictures and is aware of the suit and the stress and harassment. Jim McKinney (Friendship) Address: 151 Gold Leaf Trail Powder Springs, GA 30127 Phone: 4049060934 Statement of what they know: Jim has seen the original fence. He has seen photos/videos and is aware of the suit.
Jay (Friendship) Phone 404 8088949 Statement of what they know: Jay has seen photos/videos and aware of the suit. Dom Hamilton (Friendship) Address 287 Georgia Ave SE Atlanta, GA 30312 Phone 4045501197 Statement of what they know: Dom has seen the original fence. He has seen photos/videos and aware of the suit and the stress and harassment. Michelle Galvani (Friendship) 3565 Piedmont Rd NE Building 3 suite 715 Atlanta, GA Phone 44042