Re Zeeman Discovery 38¶

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 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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        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 <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 3:06 PM
        To: Sally L. Monico <SCook@mmatllaw.com <mailto:SCook@mmatllaw.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

        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 <mailto:szeeman@gmail.com> > wrote: