Re Zeeman Counterclaim 17¶

Good Afternoon All,

Our offices received the attached discovery requests in the mail yesterday. I am passing along in the event you all have not yet received copies.

A few questions:

1. Lisa Rose emailed everyone last week asking for a call to discuss this matter. Has anyone spoken to her?
2. How do you want to proceed in dividing/answering discovery?

At this stage I think it might be a good idea to set up a conference call with Sarah to discuss everything so that we can decide how to respond to Lisa and how to divide and conquer discovery.

Thanks and have a great weekend.

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

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: Sarah Zeeman szeeman@gmail.com Sent: Thursday, January 13, 2022 2:50 PM To: Sally L. Monico SCook@mmatllaw.com Cc: Richard J. Capriola rcapriola@wczlaw.com; Lucy Aquino Lucy.Aquino@swiftcurrie.com; Tania Tuttle ttuttle@mmatllaw.com; Eric B. Coleman ecoleman@wczlaw.com Subject: Re: Zeeman counterclaim

This is approved pending fixes to the addresses -

spoke to Sally - I'm ok with the mortgage not being fully listed correctly as Lucy said it hasn't been assigned.

On Thu, Jan 13, 2022 at 2:40 PM Sarah Zeeman <szeeman@gmail.com szeeman@gmail.com > wrote:

Mortgage ATL owner (Brian Berman) said it should be the servicer MERS and it should be assigned to whomever the mortgage company is now.

My payments are going to new rez, not mortgage atlanta.

On Thu, Jan 13, 2022 at 2:13 PM Sarah Zeeman <szeeman@gmail.com <mailto:szeeman@gmail.com> > wrote:

    Mortgage atl was the broker in 2015- I but a call into him to confirm etc,

    On Thu, Jan 13, 2022 at 2:05 PM Sally L. Monico <SCook@mmatllaw.com <mailto:SCook@mmatllaw.com> > wrote:

        Sarah, attached is the most recent recorded security deed on the property.  I just checked GSCCCA and it has not been assigned or cancelled.  NewRez is likely the servicer, but for purposes of the litigation and claims to your property the proper party, per the title records, is MERS as nominee for Mortgage Atlanta.

        Sally Monico
        11625 Rainwater Drive | Ste. 125 | Alpharetta, Georgia 30009
        Direct:  404.365.4506

        Main: 404.266.9171

        smonico@mmatllaw.com <mailto:smonico@mmatllaw.com>  *PLEASE NOTE MY NEW EMAIL ADDRESS

        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: Sarah Zeeman <szeeman@gmail.com <mailto:szeeman@gmail.com> > 
        Sent: Thursday, January 13, 2022 1:57 PM
        To: Richard J. Capriola <rcapriola@wczlaw.com <mailto:rcapriola@wczlaw.com> >
        Cc: Sally L. Monico <SCook@mmatllaw.com <mailto:SCook@mmatllaw.com> >; Lucy Aquino <Lucy.Aquino@swiftcurrie.com <mailto:Lucy.Aquino@swiftcurrie.com> >; Tania Tuttle <ttuttle@mmatllaw.com <mailto:ttuttle@mmatllaw.com> >; Eric B. Coleman <ecoleman@wczlaw.com <mailto:ecoleman@wczlaw.com> >
        Subject: Re: Zeeman counterclaim

        mortgage atlanta is not my current mortgage, let me find the correct one

        On Thu, Jan 13, 2022 at 1:51 PM Richard J. Capriola <rcapriola@wczlaw.com <mailto:rcapriola@wczlaw.com> > wrote:

            No edits from us and good to file.

             <http://www.wczlaw.net/>

Rich Capriola