Respondents 2Nd Rogs To Petitioner Ocr¶

IN THE SUPERIOR COURT OF DEKALB COUNTY STATE OF GEORGIA

JONATHAN SWEATMAN,

|

Civil Action File No: 21CV9795

Petitioner, V.

SARAH ZEEMAN,

Respondent.

RESPONDENT'S SECOND INTERROGATORIES TO PETITIONER Respondent Sarah Zeeman (hereinafter “Respondent”) hereby submits the following Second Interrogatories to Petitioner, for response within thirty (30) days after service. Responses

should be provided to Respondent’s counsel at the office of Winter Capriola Zenner, LLC, 3490 Piedmont Road, N.E., Suite 800, Atlanta, Georgia 30305. DEFINITIONS

l.

“Respondent” refers to Sarah Zeeman.

Ds

“You,” “your,” or “Petitioner” refers to Jonathan Sweatman and anyone acting on your

behalf, now or in the past.

2,

Any reference to an organization, including without limitation a corporation, includes its

officers, employees, agents and other representatives.

4.

“Document” shall be interpreted to the broadest extent, and shall specifically include,

without limitation, every original (and every copy of any original, or copy which differs in any way from any original) of all written, printed, typed, recorded, transcribed, photostatic, or graphic matter, however produced or reproduced, and other data compilations from which information can be obtained or translated, if necessary, through detection devices into reasonably

usable form. The definition of “Document” specifically includes, without limitation, all emails, text messages, and other electronic documents, in any format, including all metadata from such

electronic documents.

5.

“Identify,” “identification,” or “identity” has the following meanings: a.

when used in reference to a natural person it means to state the person's full name,

title, employer and job description (if applicable) and the person's residential address

and business address or, if present addresses are unknown, the last known residence and business address;

b.

when used in reference to a Document it means to state the type of Document (e.g., letter, memorandum, telegram, tape recording, telex, chart, etc.) or some other means

of identifying it, its author and originator, its day or dates, its present location or

custodian, and a summary of its contents. If any such Document is no longer in your possession or subject to your control, state what disposition was made of it;

c.

when used in reference to a communication it means to state the full name of the

persons who participated in or were present during the communication, and a brief description of the communication; and

d. when used in reference to a business entity it means to state the business's full name, principal place of business, address, and primary contact person.

6.

“Person” includes natural persons and all private or governmental organizations and their

representatives.

fs

“And” and “or” as used herein are both conjunctive and disjunctive.

8.

“Your Property” shall mean the real property and house located at 2746 Grove Street, NE,

Brookhaven, GA 30319.

D,

“Respondent’s Property” shall mean the real property located at 2740 Grove Street, NE,

Brookhaven, GA 30319.

10.

The term “describe” shall mean to give a full, frank, and accurate discussion of whatever

is the subject of the inquiry. With respect to communications, “describe” means to identify the

person(s) who made the communication, the person(s) to whom the communication was directed, the date of the communication, the substance of the communication and the method of communication (i.e., whether by telephone, letter, in person, or through some other means).

11.

The term “date” shall mean the approximate date if the party answering does not know

the exact date or period.

lz

As used herein, the term “communication” includes without limitation, verbal statements,

documents, email, electronic data, or any other kind of exchange of work, thoughts, ideas or Documents between persons or entities by any means, including communications made via any kind of “Document,” as defined above.

13.

The phrases “relate to,” “related to,” or “relating to,” and the terms “relate” or “relating,”

shall be interpreted in their broadest sense, and shall mean and include anything which contains, supports, evidences, describes, discusses, mentions, or references. 14.

The term “including” means “including without limitation.” INTERROGATORIES 1.

Please describe all elevation differences and any differences in the rate or volume of water flowing off Your Property in the past 5 years.

CERTIFICATE OF SERVICE

This is to certify that I have this day served a true and correct copy of the foregoing upon

Counsel via email and by depositing a copy of same in the United States Mail with adequate postage thereon, properly addressed as follows:

Lisa K. Rose, Esq. Rose Litigation, LLC 4880 Lower Roswell Road Suite 165-522 Marietta, GA 30068 lisa@roselitigation.lawyer

Attorney for Petitioner

David M. Atkinson, Esq. Joseph G. Emanual, Esq. Swift, Currie, McGhee & Hiers, LLP 1355 Peachtree Street, NE Suite 300 Atlanta, GA 30309

david.atkinson@swiftcurrie.com

joseph.emanuel@swiftcurrie.com Attorneys for Respondent

Tania R. Tuttle, Esq. Sarah C. Monico, Esq.

Brett M. Ledermeier, Esq. McClain & Merritt, PC 11625 Rainwater Drive Suite 125

Alpharetta, GA 30009

ttuttle@mmatllaw.com smonico@mmatllaw.com bledermeier@mmatllaw.com

Attorneys for Respondent

Respectfully submitted this 9" day of June, 2022. WINTER CAPRIOLA ZENNER, LLC

By: /s/ Richard J. Capriola Richard J. Capriola, Esq. Georgia Bar No. 108880 Eric B. Coleman

Georgia Bar No. 107648

Counterclaim Attorneys for Respondent 3490 Piedmont Road, NE, Suite 800 Atlanta, GA 30305

(404) 844-5700/(404) 844-5701 (fax)

rcapriola@wezlaw.com ecoleman@wezlaw.com