Re Zeeman Discovery 36¶

Hi Sarah,

I am waiting for Eric and Rich's revisions/additions to the prepared responses. Once I have those I will put everything together and clean up the official responses for your final review.

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, March 31, 2022 5:17 PM To: Sally L. Monico SCook@mmatllaw.com Cc: Tania Tuttle ttuttle@mmatllaw.com; Lucy Aquino Lucy.Aquino@swiftcurrie.com; Richard J. Capriola rcapriola@wczlaw.com; Eric B. Coleman ecoleman@wczlaw.com; Joanie J. Williams jwilliams@wczlaw.com Subject: Re: Zeeman Discovery

Hi all, Is there a time I should block out tomorrow?

On Wed, Mar 30, 2022 at 1:17 PM Sally L. Monico <SCook@mmatllaw.com SCook@mmatllaw.com > wrote:

Sarah, I am still waiting to hear from Chastain regarding final quote (with notation of sewer easement and issues outlined in your prior email) and dates for field work.  As Tania noted in the previous emails they are not the quickest but in our opinion they are the best when it comes to disputed matters which may require expert testimony.  I will be sure to let you know as soon as they provide me with proposed dates.  Your patience is appreciated.

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: Wednesday, March 30, 2022 1:03 PM
To: Sally L. Monico <SCook@mmatllaw.com <mailto:SCook@mmatllaw.com> >
Subject: Re: Zeeman Discovery

Hi

Is the survey scheduled?

I need to make sure I block off my calendar  so work  meetings do get scheduled in there

On Wed, Mar 30, 2022 at 1:00 PM Sarah Zeeman <szeeman@gmail.com <mailto:szeeman@gmail.com> > wrote:

    +200 more photos are in process to be added in Dropbox

    On Wed, Mar 30, 2022 at 12:59 PM Sarah Zeeman <szeeman@gmail.com <mailto:szeeman@gmail.com> > wrote:

        Hi all - still working on uploading everything. Dropbox = not a fan of video,

        @rich I'll be dropping by with the rest of the files/videotext messages hopefully this afternoon

        On Wed, Mar 30, 2022 at 12:57 PM Sally L. Monico <SCook@mmatllaw.com <mailto:SCook@mmatllaw.com> > wrote:

            Eric,

            Thanks for your call.  As we discussed, attached are our initial drafts of the responses to interrogatories and requests for production.  You will note our comments in the margins regarding which requests pertain to the defense of the case-in-chief vs. the counterclaims.  We will take lead on requests pertaining to defense of case-in-chief and will defer to you to handle finalizing/crafting responses to requests dealing with Ms. Zeeman's counterclaims.

            Also attached is Ms. Zeeman's notes/additions to our initial draft of responses to interrogatories.  Ms. Zeeman has done a nice job organizing the responses and the documents responsive to each RPD in the dropbox link.  We will be using Ms. Zeeman's most recent draft as our master copy.

            I look forward to hearing from you once you've had a chance to review.

            Thanks.

            Sally Monico
            11625 Rainwater Drive | Ste. 125 |