Re Stgc 328015 Zeeman Update Request 2740 Grove Street Ne Brookhaven Ga 30319 7¶

Eric/Marimar,

I have been in Court the last few days (most of the last two weeks actually). Gaddy just emailed me and said I will have the formal written proposal in the morning. The estimated price was $5,8000.00 plus $1,000.00 for permitting requirements to change the tax maps. I will send the proposal as soon as it is received; admittedly I am not sure why they are taking so long to get me the written proposal, but I do know they have been quite busy. The ETA was 3-4 weeks for completion of the survey and, if I recall correctly, the survey would be performed within 2 weeks.

With regard to the depositions, the depositions were noticed by the insureds private counsel. Plaintiff noticed the insureds deposition which we originally thought was focused on water runoff and damages allegations. We did not receive the invoices for the depositions; we attended to make sure any title related topics were covered. I know that she paid for a deposition, but I do not know which one because we were not invoiced for them. I can submit the invoice she is requesting to be paid.

Please let me know if youd like me to request clarification on the depositions and invoices and submit the same. I will send the Gaddy proposal in the morning once its received.

Brett Michael-Schiff Ledermeier Senior Associate, Real Estate Litigation

Mailing: 850 Windy Hill Road | Unit 1762 | Smyrna, GA 30081

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: Eric Zeni Eric.Zeni@stewart.com Sent: Monday, August 19, 2024 5:12 PM To: Marimar Soltero Marimar.Soltero@stewart.com; Brett Ledermeier bledermeier@mmatllaw.com Cc: Tania Tuttle ttuttle@mmatllaw.com; Darcy A. DeFruscio ddefruscio@mmatllaw.com; Melissa Taylor Melissa.Taylor@stewart.com Subject: RE: STGC 328015-Zeeman / Update Request: 2740 Grove Street NE Brookhaven, GA 30319 Importance: High

Good evening:

I need an update as soon as possible regarding Ms Zeemans inquiry about the deposition fees. Is it true that she paid for her own deposition? Was she required to for some reason? Is there an outstanding bill for the neighbors deposition? Why does Zeeman think she needs to pay that?

Also, please advise as soon as possible the status of the survey and what the latest from the Gaddy Surveying firm is? Please have them give us an ETA and a price.

I would like to move this matter expeditiously to conclusion so that we can all close our files and resolve this for the insured.

Thank you,

ERIC ANTHONY ZENI, ESQ. Chief Claims Counsel / Vice President Stewart Title Insurance Company

Associate Chief Claims Counsel / Vice President

Stewart Title Guaranty Company

711 Westchester Avenue Suite 302 White Plains, New York 10604 O 914-993-9393 | D 914-993-4443 | F 914-206-4887 stewart.com http://www.stewart.com/ | eric.zeni@stewart.com eric.zeni@stewart.com

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From: Marimar Soltero Sent: Monday, August 19, 2024 4:36 PM To: 'Brett Ledermeier' <bledermeier@mmatllaw.com bledermeier@mmatllaw.com > Cc: 'Tania Tuttle' <ttuttle@mmatllaw.com ttuttle@mmatllaw.com >; 'Darcy A. DeFruscio' <ddefruscio@mmatllaw.com ddefruscio@mmatllaw.com > Subject: RE: STGC 328015-Zeeman / Update Request: 2740 Grove Street NE Brookhaven, GA 30319 Importance: High

Hi,

Is there an estimated timeline for the update that I can provide the Associate Chief Claims Counsel?

Thank you,

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