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Re Zeeman Motion To Quash Subpoena For Review 2

Field Value
Category Correspondence > Attorney-to-Attorney
Confidence high
Reason Email exchange between opposing counsel confirming deposition status and motion to quash subpoena
Original File re-zeeman-motion-to-quash-subpoena-for-review-2.msg
File Type MSG

Email

Header Value
From joseph.emanuel@swiftcurrie.com
To Brett Ledermeier; Richard J. Capriola; Tania Tuttle; Eric B. Coleman; David Atkinson
Subject RE: Zeeman - Motion to Quash Subpoena for Review
Date Zeeman - Motion to Quash Subpoena for Review
Email Body

Confirmed.

Joe Emanuel http://joseph.emanuel@swiftcurrie.com/

404.888.6231

NOTICE: This email message and all attachments may contain legally privileged and confidential information intended solely for the addressee. If you are not an intended recipient, your receipt of this email and its attachments is the result of an inadvertent disclosure or unauthorized transmittal. Sender reserves and asserts all rights to confidentiality, including all privileges that may apply. Pursuant to those rights and privileges, you are hereby notified that you may not read, copy, distribute or otherwise use this message or its attachments. If you have received this message in error, please notify the sender by email and delete all copies of the message and the attachments immediately. NO DUTIES ARE INTENDED OR CREATED BY THIS COMMUNICATION. If you do not have a signed fee contract or engagement letter with this firm, this firm does NOT represent you as your attorney.??

From: Brett Ledermeier bledermeier@mmatllaw.com Sent: Wednesday, June 29, 2022 7:32 PM To: Joseph G. Emanuel joseph.emanuel@swiftcurrie.com; Richard J. Capriola rcapriola@wczlaw.com; Tania Tuttle ttuttle@mmatllaw.com; Eric B. Coleman ecoleman@wczlaw.com; David Atkinson David.Atkinson@swiftcurrie.com Cc: Darcy A. DeFruscio ddefruscio@mmatllaw.com Subject: RE: Zeeman - Motion to Quash Subpoena for Review

Thanks Joe! Just to confirm then, the deposition next week will no longer take place?

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: Joseph G. Emanuel <joseph.emanuel@swiftcurrie.com joseph.emanuel@swiftcurrie.com > Sent: Wednesday, June 29, 2022 5:59 PM To: Richard J. Capriola <rcapriola@wczlaw.com rcapriola@wczlaw.com >; Tania Tuttle <ttuttle@mmatllaw.com ttuttle@mmatllaw.com >; Eric B. Coleman <ecoleman@wczlaw.com ecoleman@wczlaw.com >; David Atkinson <David.Atkinson@swiftcurrie.com David.Atkinson@swiftcurrie.com > Cc: Brett Ledermeier <bledermeier@mmatllaw.com bledermeier@mmatllaw.com >; Darcy A. DeFruscio <ddefruscio@mmatllaw.com ddefruscio@mmatllaw.com > Subject: RE: Zeeman - Motion to Quash Subpoena for Review

Lisa Rose has agreed to a Consent Motion staying discovery pending mediation, followed by a 90 day extension to the discovery period. The stay would be in effect immediately and no depositions will be conducted prior to mediation. However, she will still be serving responses to my written discovery, subject only to a 3 week extension, prior to mediation.

The mediator and available dates are still TBA. Plaintiff has not agreed to any of the mediators we have suggested to date, and Sarah will not agree to Phil Bettis. Lisa told me that she thinks the mediator should have judicial experience and I mentioned Judge Forsling at miles with whom Ive had great success (including in stormwater runoff cases).

Ill draft and circulate the proposed consent motion.

Joe Emanuel http://joseph.emanuel@swiftcurrie.com/

404.888.6231

NOTICE: This email message and all attachments may contain legally privileged and confidential information intended solely for the addressee. If you are not an intended recipient, your receipt of this email and its attachments is the result of an inadvertent disclosure or unauthorized transmittal. Sender reserves and asserts all rights to confidentiality, including all privileges that may apply. Pursuant to those rights and privileges, you are hereby notified that you may not read, copy, distribute or otherwise use this message or its attachments. If you have received this message in error, please notify the sender by email and delete all copies of the message and the attachments immediately. NO DUTIES ARE INTENDED OR CREATED BY THIS COMMUNICATION. If you do not have a signed fee contract or engagement letter with this firm, this firm does NOT represent you as your attorney.??

From: Richard J. Capriola <rcapriola@wczlaw.com rcapriola@wczlaw.com > Sent: Fr

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