Re Jonathan Sweatman V. Sarah Zeeman V. Jonathan Sweatman Notice Of Deposition And Subpoena For Production Of Documents Directed To Lee Webb¶

Tim,

It was great speaking with you. As discussed, we have reviewed the settlement/counteroffer and propose a full and final resolution based our original settlement proposal (below for reference) with the addition of the water remediation by installing drainage pits, or similar, to the 3 downspouts located on the side our clients property adjacent to Mr. Sweatmans property. The fences were originally tied in and there is no need for the purchase of the fence Mr. Sweatman installed. If he truly wants the fence to be purchased, it would all need to be included in the $6,000.00 as that is the maximum authority. As for the new boundary line and legal description, we would prefer that our surveyor mark the line, but, if this is a sticking point, there is no material difference in who performs the survey. The surveyor shouldnt need to prepare new legal descriptions for both properties; they can less and except and AND the current legal descriptions to expedite this matter. Finally, we are happy to prepare the deeds and settlement agreement.

• The property line, and fence, will be moved back approximately 2 8 with the fence to be moved within 30 days of execution of the settlement agreement.
• Ms. Zeeman will have approval to tie-in to the fence.
• Acknowledgment that there is not currently any drainage and/or water being directed, aside from the natural flow, to Ms. Zeemans Property
• No admission of guilt
• Waiver of any and all claims, including a waiver as to any adverse possession claims), with a reservation of claims related to water-runoff in the event your client were to take action or conceal (e.g. piping, underground drainage) water re-direction on to Ms. Zeemans Property
• Non-disparagement provision
• Confidentiality provision
• Mutual dismissal with prejudice
• Each party covering their own legal fees
• In the event a party is required to file suit to enforce the settlement, reasonable attorneys fees and expenses to the prevailing party
• Water remediation/installation of drainage pits beneath the 3 downspouts adjacent to Sweatman Property
• Payment to Mr. Sweatman in the amount of $6,000.00

Please let me know if you have any questions or need anything else.

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

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From: Timothy L. Mitchell tmitchell@cmlawfirm.com Sent: Saturday, August 26, 2023 3:16 PM To: jeffsbanks@hotmail.com Cc: Lisa@roselitigation.lawyer; banksnriedel@gmail.com; noah.caldwell@swiftcurrie.com; david.atkinson@swiftcurrie.com; Chelsea Cooke ccooke@cmlawfirm.com; Brett Ledermeier bledermeier@mmatllaw.com Subject: Re: Jonathan Sweatman v. Sarah Zeeman v. Jonathan Sweatman -- Notice of Deposition and Subpoena for Production of Documents directed to Lee Webb

Jeff:

When we discussed the claim earlier this week you indicated you would have a response to our settlement offer by end of day yesterday. Please forward your experts file material prior to this weeks deposition. Thank you.

Timothy L. Mitchell

810-348-1942

Sent from my iPhone

On Aug 21, 2023, at 1:41 PM, Chelsea Cooke <ccooke@cmlawfirm.com <mailto:ccooke@cmlawfirm.com> > wrote:

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Good afternoon all,

I hope this email finds you well. Could you please send us your experts inspection report as soon as possible? We look forward to hearing from you.

Best Regards,

Chelsea Cooke
D: (404) 881-2634
O: (404) 881-2622

From: Marie Sanon <msanon@cmlawfirm.com <mailto:msanon@cmlawfirm.com> > 
Sent: Monday, August 21, 2023 12:15 PM
To: lisa@roselitigation.lawyer <mailto:lisa@roselitigation.lawyer> ; jeffsbanks@hotmail.com <mailto:jeffsbanks@hotmail.com> ; banksnriedel@gmail.com <mailto:banksnriedel@gmail.com> ; noah.caldwell@swiftcurrie.com <mailto:noah.caldwell@swiftcurrie.com> ; david.atkinson@swiftcurrie.com <mailto:david.atkinson@swiftcurrie.com> ; bledermeier@mmatllaw.com <mailto:bledermeier@mmatllaw.com> 
Cc: Chelsea Cooke <ccooke@cmlawfirm.com <mailto:ccooke@cmlawfirm.com> >; Timothy L. Mitchell <tmitchell@cmlawfirm.com <mailto:tmitchell@cmlawfirm.com> >
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