Zeeman Mediation Discovery Update 2740 Grove Street Ne Atlanta Ga Our File Number S023 0328015 21¶

Amy: The insured private counsel emailed about two things:

1. He wants us to draft discovery and him to add in anything regarding the counterclaims
2. He wants us to attend mediation

We have not gotten the survey back yet. As for discovery, there really is not much from a title perspective I would draft. I guess just standard generic trial prep questions. As for mediation, I am all for mediation in most cases but I am not sure how much mediation is going to be as to the title issues. That being said, at least we are on a path towards resolution rather than continued litigation.

Let me know your thoughts on the two above. If you approve, we will move forward.

Thanks, Tania

Tania R. Tuttle Partner, Real Estate Litigation

11625 Rainwater Drive. | Ste 125 | Alpharetta, Ga 30009 Direct: 404.365.4575

Cell: 404.661.3453

ttuttle@mmatllaw.com ttuttle@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: Amy Azza Amy.Azza@stewart.com Sent: Thursday, January 13, 2022 1:36 PM To: Sally L. Monico SCook@mmatllaw.com Cc: Tania Tuttle ttuttle@mmatllaw.com Subject: RE: retention letter 2740 Grove Street NE, Atlanta, GA our file number S023-0328015-21 ANSWER DUE DEC. 20

Thank you Sally!

Amy N. Azza

Claims Counsel

Stewart Title Guaranty Company 200 Fifth Avenue, Suite 301

Waltham, MA 02451

O (781) 697-3327 | F (781) 697-3335 stewart.com http://www.stewart.com/ | Amy.Azza@stewart.com Amy.Azza@stewart.com

From: Sally L. Monico <SCook@mmatllaw.com SCook@mmatllaw.com > Sent: Thursday, January 13, 2022 1:17 PM To: Amy Azza <Amy.Azza@stewart.com Amy.Azza@stewart.com > Cc: Tania Tuttle <ttuttle@mmatllaw.com ttuttle@mmatllaw.com > Subject: [External] RE: retention letter 2740 Grove Street NE, Atlanta, GA our file number S023-0328015-21 ANSWER DUE DEC. 20

Amy, attached is the draft answer in the Zeeman matter. Ms. Zeeman has retained private counsel, information below, to bring counterclaims on her behalf.

Richard J. Capriola

Erin Coleman

3490 Piedmont Rd NE, Suite 800

Atlanta, Georgia 30305

404.844.5700

404.844.5701 (fax)

rcapriola@wczlaw.com rcapriola@wczlaw.com

ecoleman@wczlaw.com ecoleman@wczlaw.com

The answer and counterclaims will be filed today.

As an aside, Ms. Zeeman called today and seemed very upset about the presentment of the encroachment agreement a few weeks ago. I thought this had been discussed and she had rejected the agreement but she feels strongly that we ambushed her with the document and may be reaching out about our involvement and representation. As a result she has asked that we not communicate with opposing counsel or co-counsel without her prior consent. I advised her that all issues regarding coverage and our representation should be brought to your attention.

Thanks please feel free to call with any questions.

Sally Monico 11625 Rainwater Drive | Ste. 125 | Alpharetta, Georgia 30009 Direct: 404.365.4506

Main: 404.266.9171

smonico@mmatllaw.com smonico@mmatllaw.com *PLEASE NOTE MY NEW EMAIL ADDRESS

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: Sally L. Monico Sent: Tuesday, January 4, 2022 2:18 PM To: Amy Azza <Amy.Azza@stewart.com Amy.Azza@stewart.com > Cc: Tania Tuttle <ttuttle@mmatllaw.com ttuttle@mmatllaw.com > Subject: RE: retention letter 2740 Grove Street NE, Atlanta, GA our file number S023-0328015-21 ANSWER DUE DEC. 20

Thanks Amy, will do.