Re Zeeman Motion To Quash Subpoena For Review¶
| Field | Value |
|---|---|
| Category | Correspondence > Attorney-to-Attorney |
| Confidence | high |
| Reason | Opposing counsel confirming document production and discovery matters |
| Original File | re-zeeman-motion-to-quash-subpoena-for-review.msg |
| File Type | MSG |
Email¶
| Header | Value |
|---|---|
| From | lisa@roselitigation.lawyer |
| To | Joseph G. Emanuel; Eric B. Coleman; Tania Tuttle; Richard J. Capriola; Brett Ledermeier |
| Subject | RE: Zeeman - Motion to Quash Subpoena for Review |
| Date | Zeeman - Motion to Quash Subpoena for Review |
Email Body
Defense Counsel:
This email will confirm my telephone conversation earlier today with Eric, wherein he confirmed the production of the outstanding documents from Ms. Zeeman in advance of mediation and as identified in the previous 6.4 letter. I am still waiting for a proposed consent agreement regarding Defendants medical records. In addition, Defendant has not provided certain documents that were referenced in her written responses, to be provided and/or supplemented. More specifically, the documents outstanding are listed in the Document Request attached and incorporated to the Notice of Deposition of Defendant Zeeman. Please consider this written email pursuant to USCR 6.4. Please produce the outstanding documents within 2 weeks of this email.
Given Erics confirmation of the production of the outstanding documents in advance of mediation, I consent to the discovery motion. Prior to filing the proposed discovery motion, please correct my clients name, and then you have my permission to sign and file.
In the interim, we need to agree upon a mediator. I will review the proposed names and respond under separate cover.
Sincerely,
Lisa Rose
Lisa Rose Rose Litigation, LLC
Mailing: 4880 Lower Roswell Rd. Ste 165-522 Marietta, GA 30068
Physical: 533 Johnson Ferry Road, Bld. D, Suite 400, Marietta, GA 30068 O: 678.806.8188
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From: Joseph G. Emanuel joseph.emanuel@swiftcurrie.com Sent: Tuesday, July 5, 2022 12:07 PM To: Brett Ledermeier bledermeier@mmatllaw.com; Richard J. Capriola rcapriola@wczlaw.com; Tania Tuttle ttuttle@mmatllaw.com; Eric B. Coleman ecoleman@wczlaw.com; Lisa Rose lisa@roselitigation.lawyer Cc: Darcy A. DeFruscio ddefruscio@mmatllaw.com; David Atkinson David.Atkinson@swiftcurrie.com Subject: RE: Zeeman - Motion to Quash Subpoena for Review
Lisa and Defense Counsel: Well sign and file the agreed-upon discovery Motion upon your approval. Draft is attached.
This will not affect Plaintiffs duty to provide outstanding responses to written discovery prior to mediation, though we did provide a 3 week extension.
We still need to select a neutral and schedule a mediation date. In my last call with Lisa, I suggested Judge Forsling at Miles.
Joe Emanuel http://joseph.emanuel@swiftcurrie.com/
404.888.6231
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