Re Zeeman Motion To Quash Subpoena For Review 1¶

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

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From: Joseph G. Emanuel joseph.emanuel@swiftcurrie.com Sent: Wednesday, June 29, 2022 5:59 PM To: Richard J. Capriola rcapriola@wczlaw.com; Tania Tuttle ttuttle@mmatllaw.com; Eric B. Coleman ecoleman@wczlaw.com; David Atkinson David.Atkinson@swiftcurrie.com Cc: Brett Ledermeier bledermeier@mmatllaw.com; Darcy A. DeFruscio 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/

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From: Richard J. Capriola <rcapriola@wczlaw.com rcapriola@wczlaw.com > Sent: Friday, June 24, 2022 7:40 AM To: 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 >; Joseph G. Emanuel <joseph.emanuel@swiftcurrie.com joseph.emanuel@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

Looks good.

Where are we with the stay/extension of discovery and mediation?

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Rich Capriola

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