Re Zeeman Discovery 32¶

also just making sure on this one that this is ok.-

i said they can take down the fence and could be on the property to remove the fence-... but i did not give them the ok to come on my property to build a fence on my property as shown by the guy with the shovel

1. Workers trespassed and were shoveling cement on August 7th , 2021 video clip @ 16 seconds produced by Zeeman in response to Request for Production 12.

On Fri, Apr 1, 2022 at 5:05 PM Sarah Zeeman <szeeman@gmail.com szeeman@gmail.com > wrote:

i hired the boundary lawyer right after the ultimatum- not before, does that matter?

In early May 2021, Zeeman told Sweatman the land was hers through adverse possession and she hired a lawyer to represent her in the boundary line dispute. On August 7, 2021, Sweatman gave Zeeman an ultimatum

On Fri, Apr 1, 2022 at 4:57 PM Sally L. Monico <SCook@mmatllaw.com <mailto:SCook@mmatllaw.com> > wrote:

    Changes made.  Finals attached.

    Sarah with your agreement/approval I will resolve all comments and finalize for submission.

    Thanks.

    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 <mailto:szeeman@gmail.com> > 
    Sent: Friday, April 1, 2022 4:51 PM
    To: Eric B. Coleman <ecoleman@wczlaw.com <mailto:ecoleman@wczlaw.com> >
    Cc: Sally L. Monico <SCook@mmatllaw.com <mailto:SCook@mmatllaw.com> >; Tania Tuttle <ttuttle@mmatllaw.com <mailto:ttuttle@mmatllaw.com> >; Lucy Aquino <Lucy.Aquino@swiftcurrie.com <mailto:Lucy.Aquino@swiftcurrie.com> >; Richard J. Capriola <rcapriola@wczlaw.com <mailto:rcapriola@wczlaw.com> >; Joanie J. Williams <jwilliams@wczlaw.com <mailto:jwilliams@wczlaw.com> >
    Subject: Re: Zeeman Discovery

    RESPONSE TO INTERROGATORY NO. 5:

    Therefore, all windows were replaced in the same windowpane sills from original construction except the four windows in the breakfast nook area maintained the same sill outline of the four windows, and together they became a single flat window for a less obstructed view of the backyard including the ability to open at the bottom, all within the same sill frame.                       By way of further answer, Zeeman refers Petitioner to the non-privileged and relevant documents

    *   The breakfast nook area with the 4 windows that became 1 large flat window doesn't open at the bottom
    *   The garden window- the one he's suing over that one does open at the bottom

    On Fri, Apr 1, 2022 at 4:39 PM Sarah Zeeman <szeeman@gmail.com <mailto:szeeman@gmail.com> > wrote:

        also need to remove him thx

        RESPONSE TO INTERROGATORY NO. 3:

        3)    Dr. Doug Stuart. Neurologist at the MS Center of Atlanta.

        a)     MS Center of Atlanta

        b)    3200 Downwood Cir NW # 550, Atlanta, GA 30327

        c)     (404) 351-0205 <https://www.google.com/search?client=safari&rls=en&q=MS+Center+of+Atlanta&ie=UTF-8&oe=UTF-8>

        On Fri, Apr 1, 2022 at 4:34 PM Sarah Zeeman <szeeman@gmail.com <mailto:szeeman@gmail.com> > wrote:

            edits attached

            On Fri, Apr 1, 2022 at 4:06 PM Eric B. Coleman <ecoleman@wczlaw.com <mailto:ecoleman@wczlaw.com> > wrote:

                Ive added our objections and our portions related to the counterclaim.

                From: Sally L. Monico <SCook@mmatllaw.com <mailto:SCook@mmatllaw.com> > 
                Sent: Friday, April 01, 2022 3:39 PM
                To: Sarah Zeeman <szeeman@gmail.com <mailto:szeeman@gmail.com> >
                Cc: Eric B. Coleman <ecoleman@wczlaw.com <mailto:ecoleman@wczlaw.com> >; Tania Tuttle <ttuttle@mmatllaw.com <mailto:ttuttle@mmatllaw.com> >; Lucy Aquino <Lucy.Aquino@swiftcurrie.com <mailto:Lucy.Aquino@swiftcurrie.com> >; Richard J. Capriola <rcapriola@wczlaw.com <mailto:rcapriola@wczlaw.com> >; Joanie J. Williams <jwilliams@wczlaw.com <mailto:jwilliams@wczlaw.com> >
                Subject: RE: Zeeman Discovery

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