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Re Zeeman Discovery Responses

Field Value
Category Discovery > Written Discovery
Confidence high
Reason Email discussing draft discovery responses and document production obligations
Original File re-zeeman-discovery-responses.msg
File Type MSG

Email

Header Value
From szeeman@gmail.com
To Sally L. Monico
Subject Re: Zeeman Discovery Responses
Date Zeeman Discovery Responses
Email Body

3.28.22 Draft attached. Things to note:

  1. Rich - will drop off hard drive w/ 1500+ images/video/emails/tickets/foia/ all requested documents by EOD or tomorrow.

I still owe:

  • 5 voice recording
  • texts
  • confirmation on a few dates,
  • add more documents to rpds

  • the remaining material from COB (ORRs)

  • Some Pictures- you may have to press "command I" then click on the Inspector part to where it is labeled TIFF to see the original creation date and meta date. White & brown dog pics, the dogs must be blurred out - they are live evidence to a DeKalb court case. (Im their foster through DCS)

  • The Former Att box corner area, the engineer said this could be an obstacle bc ATT left it at a higher elevation/bad drain - I included an ATT file with photos emails, etc. this is the opposite rear corner from Sweatman.

  • In the Dekalb ORRs the plans state for a much smaller HVAC was placed there in 1993. But the former owner replaced the units with Lennox ones that were bigger than the original builder units. I replaced those to the same size as the Lenoxx ones

  • I am 100% certain Sweatmans survey has been altered. Please have the survey scheduled asap.

On Thu, Mar 24, 2022 at 6:00 PM Sally L. Monico <SCook@mmatllaw.com SCook@mmatllaw.com > wrote:

All,

Attached please find our initial draft of the responses to interrogatories.  Note I am working on draft of responses to requests for production, but I wanted to pass this along so Sarah and Rich can start filling things in.

Sarah, I saw your email yesterday regarding scheduling survey.  I got an email from Mark yesterday with the scope of work as follows:

The scope of service for a boundary survey of this tract, under these circumstances, would include to show the property lines as well as the location of all improvements and any potential encroachments on the neighboring property.

Do you have any questions about the scope of the survey or is there anything additional you would like us to add to the work order?  If you are in agreement with the scope of work I will contact Mark about scheduling a date to come out to the property.

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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