Re Zeeman Discovery 27¶

+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 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 lead on requests pertaining to defense of case-in-chief and will defer to you to handle finalizing/crafting responses to requests dealing with Ms. Zeemans counterclaims.

    Also attached is Ms. Zeemans notes/additions to our initial draft of responses to interrogatories.  Ms. Zeeman has done a nice job organizing the responses and the documents responsive to each RPD in the dropbox link.  We will be using Ms. Zeemans most recent draft as our master copy.

    I look forward to hearing from you once youve had a chance to review.

    Thanks.

    Sally Monico
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