Re 2Nd Notice Spring Maintenance Visit¶

Sarah, per your request and as a f/u to Tania's email below, email to Lisa Rose, copying your private counsel and Lucy, attached. You are not copied as including you would constitute a waiver of attorney client privilege.

We are supposed to have a call with Eric Coleman, Rich's partner, copied here, to discuss discovery document production tomorrow at 1:00 PM. However, we will postpone pending your conversation with Rich.

Please have Rich or Eric reach out to us to coordinate next steps regarding discovery once you have had a chance to discuss.

We will not take any further action until we hear from Rich and Eric.

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 that I will be on maternity leave starting April 15, 2022. For assistance please contact Darcy DeFruscio in our offices (ddefruscio@mmatllaw.com ddefruscio@mmatllaw.com ) and she will connect you with the individual assigned to your matter.

If you are in need of immediate assistance or in the event of emergency please contact Tania Tuttle (ttuttle@mmatllaw.com ttuttle@mmatllaw.com ).

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From: Sarah Zeeman szeeman@gmail.com Sent: Thursday, April 14, 2022 7:34 PM To: Tania Tuttle ttuttle@mmatllaw.com Cc: Brett Ledermeier bledermeier@mmatllaw.com; Sally L. Monico SCook@mmatllaw.com Subject: Re: 2nd Notice! Spring - Maintenance Visit

1. Thank you. I will confirm with Rick tomorrow if it's best to have the hvac service postponed etc. this is why I requested a copy of the email(if possible to have ) so I could add onto it asking Rick etc.

2. What is the next step now that the discovery questions were submitted/logged?

On Thu, Apr 14, 2022 at 7:13 PM Tania Tuttle <ttuttle@mmatllaw.com ttuttle@mmatllaw.com > wrote:

Sarah - the chances of HVAC professionals not accidently stepping onto the property of the Sweatmans is beyond slim in my opinion. Its just too narrow an area and even if they say they could, with tempers so high, I would never advise you to do that if you didn't want to provide a heads up to protect you and your HVAC people.  You may just want to postpone the service and we can send an email stating to ignore our prior correspondence as to the same.  I don't want to see this blow up and cause you more potential damages and fees.  If Lisa came back with any questions or concerns, I would tell you to call it off regardless.

However, if you want them to come - which is totally fine - this was the way it should be handled. Sally and I discussed prior to her reaching out.  I have had two decades of experience handling these types of matters and am not going to take any steps that put any of your claims at issue, whether covered or not.  It has absolutely no effect whatsoever on any claims or counterclaims. It is pure courtesy and done to avoid expansion of litigation and additional trespass claims in such a hotly contested matter.  Lets say, for example, the reverse happens and the Sweatmans crossed into your property without any sort of warning to us or okay by you (your property, not disputed property), you would likely have concerns and would call your attorneys and/or the cops.  The Sweatmans could do the same - and drag your HVAC guys in if they really wanted to be difficult.  I have a case with a fight in which this is exactly what happened because the other side (HOA) gave no heads up about entering my clients property to cut down a tree that fell on what they deemed HOA property.  He walked all around my clients' property without notice.  It was likely innocent because it was the only way the trees were being cut down, but entering without any heads up, knowing there was a current dispute between parties, resulted in cops being called and additional claims being added to the lawsuit.  Hope this makes sense.

As for the survey, please note that if the surveyor believes he will need to access your neighbors property (not the disputed property but property that is the Sweatman's undisputed property) it is also standard for us to give counsel the heads up as to t