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Re Plat Bk 96 Page 14

Field Value
Category Correspondence > Attorney-to-Attorney
Confidence high
Reason Attorney Sally Monico providing legal analysis to opposing counsel Lucy Aquino regarding plat and encroachment defense strategy
Original File re-plat-bk-96-page-14.msg
File Type MSG

Email

Header Value
From /O=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=F820945A63984C5084823FED479950CC-SALLY L. CO
To Lucy Aquino; Sarah Zeeman
Subject RE: plat bk 96 page 14
Date plat bk 96 page 14
Email Body

Full copy attached.

Sarah, the notes are of no real consequence as the recorded plat does not show the encroachments at issue in the litigation. As I mentioned in my prior email the metes and bounds description of your property in the 2021 survey are consistent with the recorded plat, and the 1994 survey provided to you at closing (within the margin of error). Our best defense to the claims raised by is that the encroachments have existed in the same place for the necessary statutory period, which is the position we have taken in our answer.

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 MY NEW EMAIL ADDRESS

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From: Lucy Aquino Lucy.Aquino@swiftcurrie.com Sent: Tuesday, March 8, 2022 5:53 PM To: Sarah Zeeman szeeman@gmail.com; Sally L. Monico SCook@mmatllaw.com Subject: RE: plat bk 96 page 14

Sarah,

Is there any way to scan this or maybe get a better picture? It came through very blurry on my end.

Thanks,

Lucy Aquino http://Lucy.Aquino@swiftcurrie.com/

404.888.6202

NOTICE: This email message and all attachments may contain legally privileged and confidential information intended solely for the addressee. If you are not an intended recipient, your receipt of this email and its attachments is the result of an inadvertent disclosure or unauthorized transmittal. Sender reserves and asserts all rights to confidentiality, including all privileges that may apply. Pursuant to those rights and privileges, you are hereby notified that you may not read, copy, distribute or otherwise use this message or its attachments. If you have received this message in error, please notify the sender by email and delete all copies of the message and the attachments immediately. NO DUTIES ARE INTENDED OR CREATED BY THIS COMMUNICATION. If you do not have a signed fee contract or engagement letter with this firm, this firm does NOT represent you as your attorney.?

From: Sarah Zeeman <szeeman@gmail.com szeeman@gmail.com > Sent: Tuesday, March 8, 2022 5:49 PM To: Lucy Aquino <Lucy.Aquino@swiftcurrie.com Lucy.Aquino@swiftcurrie.com >; Sally L. Monico <SCook@mmatllaw.com SCook@mmatllaw.com > Subject: plat bk 96 page 14

This is from the plat bk 96 page 14 I got from the courthouse

Does either one help me?

A) The letter "I" on the 1st picture references the 6-foot cedar fence screening the entire property line-

B) #3 & #4 in the general notes about the 10 ft drainage easement between all lots and perimeter boundary lines?

Smokeball Reference: 5ab3d264-03bd-4ce8-b9f1-2c8a9bf470a8/2037e0d5-d3d7-43c0-bb09-c66e150bdaa0.

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