Re Zeeman Discovery 21¶

Ive got our portion very nearly done. I will circulate as early as possible in the morning.

All docs have been consolidated in Dropbox.

Eric B. Coleman Partner Winter Capriola Zenner LLC One Ameris Center 3490 Piedmont Rd NE Suite 800 Atlanta, Georgia 30305 dir tele 404.844.5663 mobile 678.975.0703 www.wczlaw.com

On Mar 31, 2022, at 5:26 PM, Sally L. Monico <SCook@mmatllaw.com> wrote:

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Hi Sarah,

I am waiting for Eric and Richs revisions/additions to the prepared responses.  Once I have those I will put everything together and clean up the official responses for your final review.

Sally Monico
11625 Rainwater Drive | Ste. 125 | Alpharetta, Georgia 30009
Direct:  404.365.4506

Main: 404.266.9171

smonico@mmatllaw.com <mailto:smonico@mmatllaw.com>  *PLEASE NOTE MY NEW EMAIL ADDRESS

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From: Sarah Zeeman <szeeman@gmail.com> 
Sent: Thursday, March 31, 2022 5:17 PM
To: Sally L. Monico <SCook@mmatllaw.com>
Cc: Tania Tuttle <ttuttle@mmatllaw.com>; Lucy Aquino <Lucy.Aquino@swiftcurrie.com>; Richard J. Capriola <rcapriola@wczlaw.com>; Eric B. Coleman <ecoleman@wczlaw.com>; Joanie J. Williams <jwilliams@wczlaw.com>
Subject: Re: Zeeman Discovery

Hi all, Is there a time I should block out tomorrow?

On Wed, Mar 30, 2022 at 1:17 PM Sally L. Monico <SCook@mmatllaw.com <mailto:SCook@mmatllaw.com> > wrote:

    Sarah, I am still waiting to hear from Chastain regarding final quote (with notation of sewer easement and issues outlined in your prior email) and dates for field work.  As Tania noted in the previous emails they are not the quickest but in our opinion they are the best when it comes to disputed matters which may require expert testimony.  I will be sure to let you know as soon as they provide me with proposed dates.  Your patience is appreciated.

    Sally Monico
    11625 Rainwater Drive | Ste. 125 | Alpharetta, Georgia 30009
    Direct:  404.365.4506

    Main: 404.266.9171

    smonico@mmatllaw.com <mailto:smonico@mmatllaw.com>  *PLEASE NOTE MY NEW EMAIL ADDRESS

    CONFIDENTIALITY NOTICE
    No attorney-client relationship exists by virtue of this communication in absence of an engagement letter or fee contract. In addition, unless you are in the To: or CC: line of this email, you are not an intended recipient. The information accompanying this email transmission may contain confidential or legally privileged information meant for ONLY the intended recipient. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution or reliance upon the contents of this email is strictly prohibited. If you receive this email in error, please delete this email and notify the sender immediately.

    From: Sarah Zeeman <szeeman@gmail.com <mailto:szeeman@gmail.com> > 
    Sent: Wednesday, March 30, 2022 1:03 PM
    To: Sally L. Monico <SCook@mmatllaw.com <mailto:SCook@mmatllaw.com> >
    Subject: Re: Zeeman Discovery

    Hi

    Is the survey scheduled?

    I need to make sure I block off my calendar  so work  meetings do get scheduled in there

    On Wed, Mar 30, 2022 at 1:00 PM Sarah Zeeman <szeeman@gmail.com <mailto:szeeman@gmail.com> > wrote:

        +200 more photos are in process to be added in Dropbox

        On Wed, Mar 30, 2022 at 12:59 PM Sarah Zeeman <szeeman@gmail.com <mailto:szeeman@gmail.com> > wrote:

            Hi all - still working on uploading everything. Dropbox = not a fan of video,

            @rich Ill be dropping by with the rest of the files/videotext messages hopefully this afternoon

            On Wed, Mar 30, 2022 at 12:57 PM Sally L. Monico <SCook@mmatllaw.com <mailto:SCook@mmatllaw.com> > wrote:

                Eric,

                Thanks for your call.  As we discussed, attached are our initial drafts of the responses to interrogatories and requests for production.  You will note our comments in the margins regarding which requests pertain to the defense of the case-in-chief vs. the counterclaims.  We will take le