Re 2Nd Notice Spring Maintenance Visit 3¶

Sally:

I just left you a VM. Just wrapped up a call with Sarah and I am ready to jump on a call with your team re next steps in discovery. Let me know what works.

Eric B. Coleman http://www.wczlaw.net/attorneys/eric-coleman/

Attorney at Law

Partner

direct: 404.844.5663

mobile: 678.975.0703

ecoleman@wczlaw.com ecoleman@wczlaw.net

From: Sarah Zeeman szeeman@gmail.com Sent: Friday, April 15, 2022 8:02 AM To: Sally L. Monico SCook@mmatllaw.com Cc: Tania Tuttle ttuttle@mmatllaw.com; Brett Ledermeier bledermeier@mmatllaw.com; Eric B. Coleman ecoleman@wczlaw.com; Richard J. Capriola rcapriola@wczlaw.com Subject: Re: 2nd Notice! Spring - Maintenance Visit

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@ Eric & Rich

1. Please advise either to move forward or postpone the yearly HVAC service

2. Discovery document concerns - 2 voice recordings

   a) Haight Davis engineer 3/17/22 - mentions his concerns about the former ATT box corner being elevated causing water pooling + other issues.

   b) 2740 Grove St recording 1/7/22 - (both have the same name & could get confused)

   Version 1 (44 min)  cut to end when COB left
   
   Version 2 (46 min) includes a 2 min personal conversation after COB left &  don't want it to be shared with Sweatman.,
   

On Thu, Apr 14, 2022 at 7:55 PM Sally L. Monico <SCook@mmatllaw.com SCook@mmatllaw.com > wrote:

Sarah, per your request and as a f/u to Tanias 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, Richs 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 <mailto: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 <mailto: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 <mailto:ttuttle@mmatllaw.com> ).

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

1. Thank you. I will confirm with Rick tomorrow if its 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 <mailto: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 didnt 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 dont want to see this blow up and cause you more potential damages and fees.  If Lisa came bac