Re Impt Update Trial Zeeman S023 0328015 21 5¶

Field	Value
Category	Correspondence > Attorney-to-Attorney
Confidence	high
Reason	Email from Brett Ledermeier to Marimar discussing trial preparation, settlement strategy, and pending motions
Original File	`re-impt-update-trial-zeeman-s023-0328015-21-5.msg`
File Type	MSG

Email¶

Header	Value
From	/O=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=1F4918A5604845759F64CD78928B4DF1-BRETT LEDER
To	Marimar Soltero; Tania Tuttle
Subject	RE: IMPT UPDATE - TRIAL - Zeeman S023-0328015-21
Date	IMPT UPDATE - TRIAL - Zeeman S023-0328015-21

Email Body

Marimar,

I hope all is well! We were removed from the January calendar due to a full knee dislocation I was lucky to endure (sarcasm implied), but we have spent substantial time with private counsel to prepare for trial. There are extensive documents to go through to prep exhibits and the depositions of both parties distinguished from their discovery responses. That being said, most of the heavy work is done and the insured's private counsel is compiling additional documents that are outside of our retention.

I am currently waiting on a call back from private counsel to review the jury instructions and case strategy. I just pulled the Judge's calendars and they only go through the first week of March. Presumably we will be calendared for March or April, but I don't have any set dates yet. I've also continued to discuss potential settlement with private counsel and the insured; proposing a counteroffer is in our best interest in case it comes up in front of a jury - we don't want to appear unwilling to resolve the matter - despite it, most likely, not being admissible.

There are numerous pretrial motions pending, but the Judge hasn't indicated whether or not they will be ruled on from the bench at trial or prior to the trial date. Presumably, the Judge will rule on the document objections (e.g. Plaintiff tax returns, financial records, etc.), but these are 80% outside of our retention so private counsel is taking the lead.

As soon as I know more, I will let you know. I'm happy to further discuss if you'd prefer to set up a call.

Brett Michael-Schiff Ledermeier Senior Associate, Real Estate Litigation

11625 Rainwater Drive | Ste 125 | Alpharetta, Ga 30009 Direct: 404.365.4564

Main: 770.200.7000

bledermeier@mmatllaw.com bledermeier@mmatllaw.com

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From: Marimar Soltero Marimar.Soltero@stewart.com Sent: Tuesday, February 20, 2024 8:52 AM To: Tania Tuttle ttuttle@mmatllaw.com Cc: Brett Ledermeier bledermeier@mmatllaw.com; Darcy A. DeFruscio ddefruscio@mmatllaw.com Subject: RE: IMPT UPDATE - TRIAL - Zeeman S023-0328015-21

Good Morning Brett,

Any updates on trial?

I hope you have a great day,

Marimar Soltero

Claims Counsel

Stewart Title Guaranty Company

3402 W. Cypress St.

Tampa, FL 33607

O (813) 371-6694 | F (813) 315-7288

stewart.com http://www.stewart.com/ | marimar.soltero@stewart.com marimar.soltero@stewart.com |

STEWART INFORMATION SERVICES CORPORATION (NYSE: STC)

This e-mail may contain confidential and privileged material for the sole use of the intended recipient(s). Any review, use, distribution or disclosure by others is strictly prohibited. If you are not the intended recipient, please contact the sender by reply e-mail and delete all copies of this message.

From: Marimar Soltero <Marimar.Soltero@stewart.com Marimar.Soltero@stewart.com > Sent: Thursday, December 28, 2023 3:44 PM To: Tania Tuttle <ttuttle@mmatllaw.com ttuttle@mmatllaw.com > Cc: Brett Ledermeier <bledermeier@mmatllaw.com bledermeier@mmatllaw.com >; Darcy A. DeFruscio <ddefruscio@mmatllaw.com ddefruscio@mmatllaw.com > Subject: RE: IMPT UPDATE - TRIAL - Zeeman S023-0328015-21

Hi Tania,

Tomorrow at 1 pm works for me.