Re 2Nd Notice Spring Maintenance Visit 6¶

Eric, thanks for the call.

Tania and Brett, I spoke with Eric about discovery issues. Basically our options for document production are to manually prepare or to use ediscovery platform. Eric is aware of our limited retention and that we will need approval from Stewart before we move forward with dividing up the work load.

Can you all set up a time for a call with Eric to discuss way to handle?

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: Eric B. Coleman ecoleman@wczlaw.com Sent: Friday, April 15, 2022 12:58 PM To: Sarah Zeeman szeeman@gmail.com; Sally L. Monico SCook@mmatllaw.com Cc: Tania Tuttle ttuttle@mmatllaw.com; Brett Ledermeier bledermeier@mmatllaw.com; Richard J. Capriola rcapriola@wczlaw.com Subject: RE: 2nd Notice! Spring - Maintenance Visit

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 szeeman@gmail.com > Sent: Friday, April 15, 2022 8:02 AM To: Sally L. Monico <SCook@mmatllaw.com SCook@mmatllaw.com > Cc: Tania Tuttle <ttuttle@mmatllaw.com ttuttle@mmatllaw.com >; Brett Ledermeier <bledermeier@mmatllaw.com bledermeier@mmatllaw.com >; Eric B. Coleman <ecoleman@wczlaw.com ecoleman@wczlaw.com >; Richard J. Capriola <rcapriola@wczlaw.com 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 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 <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