I will follow up with Stewart. I think they are going to want to see the final survey first but I believe that should be done shortly. The actual title issues here are minimal, if any. The problem is that Ms. Zeeman has refused all attempts to fix the title issues when the title claim was first made so I think Stewart is going to want to make sure Ms. Zeeman is open to resolution. As long as she is open to compromise and resolution, I believe Stewart would be up for mediation first. And I have no objection to Phil.

From: Joseph G. Emanuel joseph.emanuel@swiftcurrie.com Sent: Tuesday, June 14, 2022 10:03 AM To: Richard J. Capriola rcapriola@wczlaw.com; Tania Tuttle ttuttle@mmatllaw.com; Brett Ledermeier bledermeier@mmatllaw.com Cc: Eric B. Coleman ecoleman@wczlaw.com; Joanna D. Conyers Joanna.conyers@swiftcurrie.com; Joanie J. Williams jwilliams@wczlaw.com; David Atkinson David.Atkinson@swiftcurrie.com Subject: RE: Discovery Closing in about 5 weeks

All: Plaintiffs Responses to our written discovery are due on July 8th and discovery is currently scheduled to close on July 13th. Sarahs deposition is currently scheduled for the 7th and we can notice the Sweatmans depositions for July 11-13. My understanding is that all counsel has availability on the 11-13th.

However, Lisa suggested, and I agree, that, if possible, it would be worthwhile to attempt mediation prior to incurring the expense of party depositions which, are likely to have the effect of further deteriorating the relationship between these neighbors. Therefore, she is speaking with her clients about consenting to an extension of discovery in order to allow time to conduct mediation.

I am new to the case, and I know that some of these issues have been discussed previously. If our client agrees to pursue mediation is there any disagreement among counsel as to the above-suggested plan as a matter of strategy? And do yall have strong feelings about Lisas suggested mediator Phil Bettis?

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

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From: Richard J. Capriola <rcapriola@wczlaw.com rcapriola@wczlaw.com > Sent: Wednesday, June 8, 2022 12:47 PM To: Joseph G. Emanuel <joseph.emanuel@swiftcurrie.com joseph.emanuel@swiftcurrie.com >; Tania Tuttle <ttuttle@mmatllaw.com ttuttle@mmatllaw.com > Cc: Eric B. Coleman <ecoleman@wczlaw.com ecoleman@wczlaw.com >; Joanna D. Conyers <Joanna.conyers@swiftcurrie.com Joanna.conyers@swiftcurrie.com >; Brett Ledermeier <bledermeier@mmatllaw.com bledermeier@mmatllaw.com >; Joanie J. Williams <jwilliams@wczlaw.com jwilliams@wczlaw.com >; David Atkinson <David.Atkinson@swiftcurrie.com David.Atkinson@swiftcurrie.com > Subject: RE: Discovery Closing in about 5 weeks

32 Looks good.¶

If you can hand serve the discovery today, then they must respond by July 8th. That only leaves July 11-13 for depositions. I am open July 11-13.

When you talk to Sarah, please let her know about her deposition on July 7th and the subpoenas served on Ski and Chastain.

Tania just wanted to be sure Chastain is not the surveyor that was hired by your firm to do the most recent survey. If it is, we need to protect its survey as work product.

http://www.wczlaw.net/

Rich Capriola

Winter Capriola Zenner, LLC

One Ameris Center 3490 Piedmont Road NE, Suite 800 Atlanta, GA 30305 www.wczlaw.com http://www.wczlaw.com/

rcapriola@wczlaw.com rcapriola@wczlaw.com

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