Re Zeeman Discovery Responses 2¶
| Field | Value |
|---|---|
| Category | Discovery > Written Discovery |
| Confidence | high |
| Reason | Email discussing interrogatory responses and requests for production drafts |
| Original File | re-zeeman-discovery-responses-2.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
also - Its Brookhaven, GA not Atlanta
On Thu, Mar 24, 2022 at 7:21 PM Sarah Zeeman <szeeman@gmail.com szeeman@gmail.com > wrote:
Is this ok for the 1st interrogatory draft or do I need to add more specific details?
-will be adding text messages, 4 more individuals + COB & DeKalb, etc
McClung said they can do it in 3 weeks what is the eta date for Mark?
Having a surveyor drive from Ellijay instead of smryna is a lot.
I would like to add the sewer easement & two corner pins are missing from COB construction, and the other 1 or 2 possibly have been altered - how will the surveyor handle?
On Thu, Mar 24, 2022 at 6:00 PM Sally L. Monico <SCook@mmatllaw.com <mailto: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
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