Re Zeeman Motion To Quash Subpoena For Review 7¶

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 Sent: Friday, June 24, 2022 7:40 AM To: Tania Tuttle ttuttle@mmatllaw.com; Eric B. Coleman ecoleman@wczlaw.com; David Atkinson David.Atkinson@swiftcurrie.com; Joseph G. Emanuel joseph.emanuel@swiftcurrie.com Cc: Brett Ledermeier bledermeier@mmatllaw.com; Darcy A. DeFruscio 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

Winter Capriola Zenner, LLC

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From: Tania Tuttle <ttuttle@mmatllaw.com ttuttle@mmatllaw.com > Sent: Thursday, June 23, 2022 8:54 PM To: Richard J. Capriola <rcapriola@wczlaw.com rcapriola@wczlaw.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: Zeeman - Motion to Quash Subpoena for Review

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All: I know we are looking at staying discovery and moving forward with mediation but I thought we should probably just get a basic motion of record in regards to Chastain & Associates. Please see attached and let me know if you have any objection to me filing the same. I ju