32 Looks good.¶

If you can hand serve the discovery today, then they must respond by July 8th. That only leaves July 11-13 for depositions. I am open July 11-13.

When you talk to Sarah, please let her know about her deposition on July 7th and the subpoenas served on Ski and Chastain.

Tania just wanted to be sure Chastain is not the surveyor that was hired by your firm to do the most recent survey. If it is, we need to protect its survey as work product.

http://www.wczlaw.net/

Rich Capriola

Winter Capriola Zenner, LLC

One Ameris Center 3490 Piedmont Road NE, Suite 800 Atlanta, GA 30305 www.wczlaw.com http://www.wczlaw.com/

rcapriola@wczlaw.com rcapriola@wczlaw.com

View Bio https://wczlaw.com/attorneys/chadd-l-reynolds/

tel

dir tel

404.844.5700

404.844.5637

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From: Joseph G. Emanuel joseph.emanuel@swiftcurrie.com Sent: Wednesday, June 8, 2022 12:33 PM To: Richard J. Capriola rcapriola@wczlaw.com; Tania Tuttle ttuttle@mmatllaw.com Cc: Eric B. Coleman ecoleman@wczlaw.com; Joanna D. Conyers Joanna.conyers@swiftcurrie.com; Brett Ledermeier bledermeier@mmatllaw.com; Joanie J. Williams jwilliams@wczlaw.com; David Atkinson David.Atkinson@swiftcurrie.com Subject: RE: Discovery Closing in about 5 weeks

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OK. Please let me know, Rich and Tania, what dates work for yall with respect to these deposition notices. I will reach out to Sarah.

Also, Rich, I have incorporated the following as ROG No. 32. Just let me know if it does not properly reflect the information you are seeking.

32.

With respect to each and every drainage pipe, or similar and/or related infrastructure, which was buried upon or otherwise located at 2746 Grove Street prior to 2021, and which discharged onto or towards 2740 Grove Street, or towards the property line between 2746 Grove Street and 2740 Grove Street, please provide a full complete description of the following:

a. The dates on which, and all reasons why, it was installed; and, b. The dates on which, and all reasons why, it was removed or modified; and,

c. The person or entity that installed it; and, d. The source of water that traveled through it; and, e. The volume and velocity of water that traveled through it; and, f. The volume, velocity, location, and quality of water and all other substances which were emitted from it; and,
g. All photographs or video of it, and/or its installation, maintenance, modification, alteration, or removal; and, h. The identify of all persons with knowledge regarding its function, installation, maintenance, modification, alteration, or removal; and, i. All invoices, estimates, communications, permits, correspondence, plans, calculations, designs, and all documents or electronically stored information, related to, referencing, or reflecting its design, location, function, alteration, or removal in any way.

Joe Emanuel http://joseph.emanuel@swiftcurrie.com/

404.888.6231

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