Respondents 2Nd Rpd 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 REQUEST

FOR PRODUCTION OF DOCUMENTS TO PETITIONER

Respondent Sarah Zeeman (hereinafter “Respondent”) hereby submit the following

Second Request for Production of Documents to Petitioner, for response within thirty (30) days

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

1.

“Respondent” refers to Sarah Zeeman.

De

“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.

7.

“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.

9.

“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.

12.

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.” PRODUCTION OF ELECTRONICALLY STORED INFORMATION

All electronically stored information (“ESI”) produced in response to these requests must be

produced with full metadata intact together with an image, in a database format. The following shall govern the manner in which ESI documents, including . TIFF images of paper documents, are to be produced:

a.

ESI Documents and emails shall be produced in .TIFF image format with a .DAT and .LFP

file, such that the documents will load into the document management software,

CloudNineTM, The produced .DAT file shall include the following populated fields, to the

extent that such information exists in the original ESI document or email: b.

All imaged (.tiff) documents shall be produced with a .DAT, .and. LFP file. Documents

shall have full text extracted or OCR for redacted documents.

é,

Detailed technical specifications for the production of ESI are attached as Exhibit A — ESI

PRODUCTION PROTOCAL. Please direct any questions or concerns regarding the requested format to the undersigned prior to delivery of the production. REQUESTS FOR PRODUCTION l.

Please produce all documents showing the change in elevation of any portion of Your Property during the past five (5) years. 2.

Please produce any documents, plans and approvals regarding the set of stairs that currently are located within the DeKalb County Sanitary Sewer Easement on Your Property. 3.

Please produce any and all documents showing the calculation of the impervious surface

area on Your Property before and/or after the installation of any additional impervious surfaces on Your Property in the past five (5) years. 4.

Please produce any documents related to the amount or calculation of impervious surface area on Your Property as it relates to any stairs installed or replaced in your backyard since January 1, 2021.

=f

With respect to the buried cement unearthed in the back yard of Your Property in the area

shown on Exhibit “1”, please describe the date it was buried, what function it served and the date it was excavated. 6.

Please produce any documents showing the location of any improvements on Your

Property in relation to the DeKalb Sanitary Sewer Easement for the past 5 years.

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

By: /s/ Richard J. Capriola Richard J. Capriola

Georgia Bar No. 108880 Eric B. Coleman

Georgia Bar No. 107648

Counterclaim Attorneys for Respondent One Ameris Center

3490 Piedmont Road, NE, Suite 800 Atlanta, GA 30305

(404) 844-5700 (phone) (404) 844-5701 (fax) rcapriola@wezlaw.com ecoleman@wcezlaw.com