Defs Supp Resp To Pltfs Request To Supplemental Disc Ocr¶

FILED 10/30/2023 11:26 AM CLERK OF SUPERIOR COURT DEKALB COUNTY GEORGIA

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

§

Plaintiff,

§

Vv.

§

SARAH ZEEMAN,

§

Defendant.

§

8

CIVIL ACTION NO. 21CV9795

§

RULE 5.2 CERTIFICATE OF SERVICE

COMES NOW, Plaintiff in the above-styled action, and files this Certificate in compliance with Uniform Superior Court Rule 5.2. I hereby certify that I have served a copy of the

within and foregoing Plaintiff's Supplemental Plaintiff’s discovery requests Inteogatories and First Request for Production of Documents by service electronically through the Odyssey electronic filing system and by email:

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

Lisa @roselitigation.lawyer Attorney for Petitioner Sweatman Brett Ledermeier, Esq. 11625 Rainwater Drive,

Suite 125 Alpharetta, GA 30009

Attorneys for Counterclaim Petition Zeeman

TIMOTHY L. MITCHELL CHELSEA T. COOKE Meridian I,

Suite 2000 Attorneys for Plaintiff / Counterclaim Defendant 275 Scientific Drive

Peachtree Corners, GA 30092

tmitchell@cmlawfirm.com ccooke@cmlawfirm.com

Respectfully submitted this 30" day of October 2023

/s/ Jeff Banks Jeff Banks

Attorney for Defendants

GA Bar 005445

Banks and Riedel, P.C.

P.O. Box 2719 Kennesaw, Georgia 30156

(678) 797-6364 phone (678) 797-6365 facsimile

IN THE SUPERIOR COURT OF DEKALB COUNTY STATE OF GEORGIA

JONATHAN SWEATMAN,

§

Plaintiff,

§

V.

§

SARAH ZEEMAN,

§

Defendant.

§

§

CIVIL ACTION NO. 21CV9795

§

DEFENDANT’S SUPPLEMENTAL RESPONSES TO PLAINTIFF’S REQUEST TO SUPPLEMENT DISCOVERY. COMES NOW, Plaintiff and supplements her discovery responses:

1. An itemization of each and every damage Defendant [Zeeman] is

claiming in Defendant’s Counterclaim and all invoices, receipts, proof of payment in support of same.

See attached estimate from Chapman Services. . Copies of any and all documents evidencing Defendant’s alleged damages as alleged in the Counterclaim.

See attached estimate from Chapman Services.

. Copies of any and all estimates, contracts, and/or proposals prepared

by anon _ partyto remediate any purported damage to Defendant’s property as it relates to the allegations raised in the Complaint or Counterclaim.

See attached estimate from Chapman Services.

4. Copies of Defendant’s medical records that relate to Defendant’s medical condition at issue, including but not limited to the allegation

contained in Count 5, paragraph 52 of Defendant’s Counterclaim, “Zeeman has suffered emotional distress, personal injuries, discomfort, and annoyance, and otherwise been damaged by

Sweatman’s invasion ofher privacy in an amount to be determined at trial.”

The Defendant and abandoned and dismissed her claim for intentional infliction of emotional distress, and personal injuries. There are no responsive documents to discomfort and annoyance.

1. Copies of all reports created by each expert that is expected to testify on behalf of Defendant.

There are no responsive documents. 6. Copies of all reports created by each witness that is expected to testify on behalf of Defendant.

There are no responsive documents. 7. Copies of any and all documents showing communications by and between Defendant and any professional surveyor regarding the Property and copies of surveys and/or draft surveys prepared on behalf of Defendant.

There are no responsive documents.

1. Copies ofany and all documents showing communications by and between Defendant and any contractor to address or remediate any

alleged damaged caused by Petitioner to Defendant’s Property. There are no responsive documents.

9. Copies ofany and all documents related to Defendant’s purchase of the two heating ventilation and air conditioning (“HVAC”) units currently located on a portion of her property. There are no responsive documents.

Respectfully submitted this 30" day of October 2023

/s/ Jeff Banks Jeff Banks Attorney for Defendants

GA Bar 005445

Banks and Riedel, P.C.

P.O. Box 2719 Kennesaw, Georgia 30156

(678) 797-6364 phone (678) 797-6365 facsimile