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Re Zeeman Discovery 37

Field Value
Category Discovery > Written Discovery
Confidence high
Reason Email discussing ROGs and RPDs (Requests for Production) responses and objections before finalization
Original File re-zeeman-discovery-37.msg
File Type MSG

Email

Header Value
From ecoleman@wczlaw.com
To Sally L. Monico; Sarah Zeeman
Subject RE: Zeeman Discovery
Date Zeeman Discovery
Email Body

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

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

CAUTION: This email originated from outside the organization. Do not click links or open attachments unless you recognize the sender and know the content is safe.

All, see attached final drafts of ROGS and RPDS for your review.

Please review the track changes and comments. Eric and I have discussed objections he will add to RPD responses.

Sarah, I did my best to keep most of your voice/narrative responses but did remove certain portions which were non-responsive to the individual requests. I also revised to make some of the terms used consistent throughout.

Please review and let me know if we have your approval to finalize and produce to counsel for Sweatman.

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

Main: 404.266.9171

smonico@mmatllaw.com 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 Sent: Friday, April 1, 2022 3:06 PM To: Sally L. Monico SCook@mmatllaw.com Cc: Eric B. Coleman ecoleman@wczlaw.com; Tania Tuttle ttuttle@mmatllaw.com; Lucy Aquino Lucy.Aquino@swiftcurrie.com; Richard J. Capriola rcapriola@wczlaw.com; Joanie J. Williams jwilliams@wczlaw.com Subject: Re: Zeeman Discovery

Lights should be july 16

The Sweatmans shined lights into windows of Zeemans property on multiple occurrences including, but not limited to December 26, 2020; July 16, 2021[SZ1] ; and September 30, 2021, as


[SZ1]July 16

also - remove - all 3 recordings.

It's only in one or 2 of Linda's recordings

In addition, Sweatman will produce three audio recordings from Linda Abaray at

On Fri, Apr 1, 2022 at 2:37 PM Sarah Zeeman <szeeman@gmail.com szeeman@gmail.com > wrote:

yes -june 25

https://prnt.sc/bWvOa7ejU3Qr

https://www.dropbox.com/s/uibjotxogk4yqem/Sarah%20Zeeman%20Demand%20letter_communication%20Sweatman.pdf?dl=0

On Fri, Apr 1, 2022 at 2:32 PM Sarah Zeeman <szeeman@gmail.com <mailto:szeeman@gmail.com> > wrote:

    I'm incorrect again - sorry - I got a certified letter in from them about the fence june 2021, let me see if any others

    On Fri, Apr 1, 2022 at 2:29 PM Sarah Zeeman <szeeman@gmail.com <mailto:szeeman@gmail.com> > wrote:

        did not hear from them again about just the fence part until August 2021

        On Fri, Apr 1, 2022 at 2:24 PM Sarah Zeeman <szeeman@gmail.com <mailto:szeeman@gmail.com> > wrote:

            additional Fence -convos in march 2021 - I couldn't remember exactly but this clears it up some -  I went ahead and did apply during this time frame but didn't submit all the items yet for the permit as it wasn't fully decided on the vendor/design but wanted to get the process started moving with COB.

            After this email, exchange I did not hear from them until August 2021

            On Fri, Apr 1, 2022 at 1:45 PM Sally L. Monico <SCook@mmatllaw.com <mailto:SCook@mmatllaw.com> > wrote:

                Got it, I will run with this draft and circulate a final copy shortly.

                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

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