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Re Sweatman V Zeeman 40

Field Value
Category Correspondence > Attorney-to-Attorney
Confidence high
Reason Email exchange between opposing counsel regarding discovery disputes and deposition scheduling
Original File re-sweatman-v-zeeman-40.msg
File Type MSG

Email

Header Value
From /O=EXCHANGELABS/OU=EXCHANGE ADMINISTRATIVE GROUP (FYDIBOHF23SPDLT)/CN=RECIPIENTS/CN=1F4918A5604845759F64CD78928B4DF1-BRETT LEDER
To Timothy L. Mitchell; Lisa Rose
Subject RE: SWEATMAN V ZEEMAN
Date SWEATMAN V ZEEMAN
Email Body

It was my understanding that you were filing the Motion to Compel next week. I have a call scheduled with Jeff and Ms. Zeeman on Thursday to discuss are you ok holding off until Friday? As for the notice of deposition, I did not receive a copy. What day did you notice? Ideally, we coordinate both of our clients on the same day.

Brett Michael-Schiff Ledermeier 11625 Rainwater Drive | Ste 125 | Alpharetta, Ga 30009 Direct: 404.365.4564

Main: 770.200.7000

bledermeier@mmatllaw.com bledermeier@mmatllaw.com

CONFIDENTIALITY NOTICE No attorney-client relationship exists by virtue of this communication in absence of an engagement letter or fee contract. In addition, unless you are in the To: or CC: line of this email, you are not an intended recipient. The information accompanying this email transmission may contain confidential or legally privileged information meant for ONLY the intended recipient. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution or reliance upon the contents of this email is strictly prohibited. If you receive this email in error, please delete this email and notify the sender immediately.

From: Timothy L. Mitchell tmitchell@cmlawfirm.com Sent: Tuesday, June 13, 2023 6:38 PM To: Brett Ledermeier bledermeier@mmatllaw.com; Lisa Rose lisa@roselitigation.lawyer Cc: Jeff Banks jeffsbanks@hotmail.com; Sarah Riedel banksnriedel@hotmail.com; Chelsea Cooke ccooke@cmlawfirm.com Subject: RE: SWEATMAN V ZEEMAN Importance: High

Brett:

        We already noticed Ms. Zeemans deposition after not receiving any response from you or Jeff on finalizing a specific date.  I believe the 21st should work.  That said, we still do not have the supplemental documents from Ms. Zeeman and no explanation for why they would not be produced.  Have you discussed producing these with Jeff?  We have emailed several times on this issue and prepared a motion to compel we planned on filing tomorrow. Thank you.

Timothy L. Mitchell C: (810) 348-1942

From: Brett Ledermeier <bledermeier@mmatllaw.com bledermeier@mmatllaw.com > Sent: Tuesday, June 13, 2023 4:45 PM To: Timothy L. Mitchell <tmitchell@cmlawfirm.com tmitchell@cmlawfirm.com >; Lisa Rose <lisa@roselitigation.lawyer lisa@roselitigation.lawyer > Cc: Jeff Banks <jeffsbanks@hotmail.com jeffsbanks@hotmail.com >; Sarah Riedel <banksnriedel@hotmail.com banksnriedel@hotmail.com >; Chelsea Cooke <ccooke@cmlawfirm.com ccooke@cmlawfirm.com > Subject: RE: SWEATMAN V ZEEMAN

All,

If we could keep all emails with all counsel copied, I would appreciate it. Are we planning on doing joint depositions of both parties? What are the current proposed dates? I saw that the engineer is available next week, June 21st in the afternoon. Does this work with all parties? Should we try to get deposition dates for both parties once the engineer report is back? Ideally, the engineer report puts us all in a position to review Lisas outlined settlement proposal and potentially resolve this without further expansion.

Brett Michael-Schiff Ledermeier 11625 Rainwater Drive | Ste 125 | Alpharetta, Ga 30009 Direct: 404.365.4564

Main: 770.200.7000

bledermeier@mmatllaw.com bledermeier@mmatllaw.com

CONFIDENTIALITY NOTICE No attorney-client relationship exists by virtue of this communication in absence of an engagement letter or fee contract. In addition, unless you are in the To: or CC: line of this email, you are not an intended recipient. The information accompanying this email transmission may contain confidential or legally privileged information meant for ONLY the intended recipient. If you are not the intended recipient, you are hereby notified that any disclosure, copying, distribution or reliance upon the contents of this email is strictly prohibited. If you receive this email in error, please delete this email and notify the sender immediately.

From: Timothy L. Mitchell <tmitchell@cmlawfirm.com tmitchell@cmlawfirm.com > Sent: Friday, June 9, 2023 9:54 AM To: Brett Ledermeier <bledermeier@mmatllaw.com bledermeier@mmatllaw.com >; Lisa Rose <lisa@roselitigation.lawyer lisa@roselitigation.lawyer > Cc: Jeff Banks <jeffsbanks@hotmail.com jeffsbanks@hotmail.com >; Sarah Riedel <banksnriedel@hotmail.com banksnriedel@hotmail.com >; Chelsea Cooke <ccooke@cmlawfirm.com ccooke@cmlawfirm.com > Subject: RE: SWEATMAN V ZEEMAN

All:

        Good morning.  We have not heard back from anyone regarding finalizing Ms. Zeemans deposition or setting the inspection, and did not receive any supplement of the outstanding responsive records by yesterdays deadline.  Please be advised we are moving ahead with noticing Ms. Zeemans deposition and will be

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