Motion,Ex Parte: RODRIGUEZZARCO VS AG CONSTRUCTION LLC et al

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                                IN THE STATE COURT OF GWINNETT COUNTY
                               STATE OF GEORGIA


 ERMILO RODRIGUEZ-ZARCO,

                            Plaintiff,
                                                        CIVIL ACTION
 vs.                                                    FILE NO. 24-C-00821-S3

 AG CONSTRUCTION LLC,
 ABC CORPORATION,
 DAGOBERTO LOPEZ, and
 MARTIN LOPEZ

                            Defendants.


   MOTION TO COMPEL CLAYTON PROPERTIES GROUP, INC. D/B/A CHAFIN
                          BUILDERS


       COMES NOW, Plaintiff, with this his Motion to Compel Clayton Properties Group, Inc.

d/b/a Chafin Builders (“Chafin Builders”) pursuant to O.C.G.A. § 9-11-26, O.C.G.A. § 9-11-37,

O.C.G.A. § 9-11-34, O.C.G.A. § 24-13-26, and Uniform Superior Court Rule 6.4 and showing

this Honorable Court as follows:

                                    STATEMENT OF FACTS

       Subject Incident

       This is a premises liability action for personal injuries sustained by Plaintiff Ermilo

Rodriguez-Zarco as a result of a fall occurring on May 9, 2022. The subject incident occurred at

a new house that was under construction by Chafin Builders in the Lancaster subdivision in

Flowery Branch, Georgia. Chafin Builders utilized various subcontractors and independent

contractors to complete construction of the house, including Defendant AG Construction LLC.

Prior to the subject incident, an attic access ladder was installed in the ceiling on the second floor

of the house. On the date of the subject incident, Plaintiff went to the house to install insulation in

the attic. As he was climbing up the attic access ladder, it detached from the ceiling, causing

Plaintiff and the ladder to fall to the floor. As a result of the subject incident, Plaintiff suffered

severe and permanent injuries requiring extensive treatment, including two surgeries for his right

ankle.

         Request for Production of Documents to Non-Party Clayton Properties Group, Inc. d/b/a

         Chafin Builders

         Plaintiff served a Request for Production of Documents to Non-Party Clayton Properties

Group, Inc. d/b/a Chafin Builders on May 15, 2024. See Plaintiff’s Request for Production of

Documents to Non-Party Clayton Properties Group, Inc. d/b/a Chafin Builders, attached hereto

as Exhibit A. In addition to mailing a copy of the request to the business office for Chafin

Builders, Plaintiff’s counsel also mailed a copy to Haley & Haley Law Group, LLC, as

Registered Agent for CBuild Holdings, LLC, which shares the same mailing address as Chafin

Builders. See Georgia Secretary of State Business Search, attached hereto as Exhibit B. To

date, Plaintiff has not received any responsive documents from Chafin Builders.

         Attempts to Confer in Good Faith

         On September 20, 2024, Plaintiff’s counsel called Haley & Haley Law Group, LLC

regarding the request. Plaintiff’s counsel sent a follow-up e-mail documenting the conversation

and requesting a call from John Haley. See September 20, 2024 E-Mail, attached hereto as

Exhibit C. An additional e-mail was sent that same day containing a copy of the non-party

request, attached hereto as Exhibit D. Plaintiff’s counsel followed up with Haley & Haley

Law Group, LLC again on October 7, 2024. See October 7, 2024 E-Mails, attached hereto as

Exhibit E. To date, no response has been received.



                                                  2

                     ARGUMENT AND CITATION OF AUTHORITY

       “A party, upon reasonable notice to other parties and all persons affected thereby, may

apply for an order compelling discovery.” O.C.G.A. § 9-11-37(a). “A party may obtain

discovery of the existence and contents of any insurance agreement under which any person

carrying on an insurance business may be liable to satisfy part or all of a judgment which may be

entered in the action or to indemnify or reimburse for payments made to satisfy the judgment.”

O.C.G.A. § 9-11-26(b)(2). A party may serve a request for production of documents to a non-

party. See O.C.G.A. § 9-11-34(a) and O.C.G.A. § 9-11-34(c). A party can file a motion to

compel pursuant to O.C.G.A. § 9-11-37(a) against a non-party upon a showing of good cause.

See O.C.G.A. § 9-11-34(c)(1). Additionally, courts have the power to enforce subpoenas. See

O.C.G.A. § 24-13-26.

       Plaintiff is entitled to discover documentation from Chafin Builders regarding any

contracts and/or service agreements it entered into with Defendant AG Construction LLC, as

well as any documentation in its possession regarding the subject incident pursuant to O.C.G.A.

§ 9-11-26(b)(2). This information/documentation could shed light on the relationship between

Chafin Builders and Defendants and may impact the jury’s determination of liability and/or

apportionment of fault between the Defendants. Accordingly, this information is discoverable

from Chafin Builders. Plaintiff appropriately served his Request for Production of Documents to

non-party Chafin Builders. Plaintiff has attempted several times to follow-up with Chafin

Builders to arrange for production of this documentation without the need for court intervention

but has not received a response in the form of production of the requested documents.

Accordingly, Plaintiff is seeking an order compelling production of these documents from

Chafin Builders.



                                                3

      This 21st day of November, 2024.


                                           Respectfully Submitted,

                                           FRIED GOLDBERG LLC


                                         By: Adam P. Smith
                                            MICHAEL L. GOLDBERG
                                            Georgia Bar No. 299472
                                            ADAM P. SMITH
                                            Georgia Bar No. 899334
                                            Attorneys for Plaintiff
Three Alliance Center
3550 Lenox Road, Ste. 1500
Atlanta, Georgia 30326-4302
(404) 591-1800 (office)
(404) 591-1801 (fax)
Email: Michael@friedgoldberg.com
Email: Adam@friedgoldberg.com




                                              4

                                    CERTIFICATE OF SERVICE

       I hereby certify that a true and correct copy of the foregoing Motion to Compel Clayton

Properties Group, Inc. d/b/a Chafin Builders has this day been served upon all counsel of record

via electronic filing thereon to:

                                          Steven M. Schatz
                                       Robert J. Kozloski, III
                               Swift, Currie, McGhee & Hiers, LLP
                               1420 Peachtree Street, N.E., Suite 800
                                      Atlanta, Georgia 30309
                                   steve.schatz@swiftcurrie.com
                                 robert.kozloski@swiftcurrie.com

       Dated on this 21st day of November, 2024.


                                              FRIED GOLDBERG LLC

                                              By: Adam P. Smith
                                                 ADAM P. SMITH
                                                 Georgia Bar No.: 899334




                                                 5

EXHIBIT A

                                                                                     Joseph A. Fried
                                                                                Michael L. Goldberg
Adam P. Smith                                                                   Bradford W. Thomas
Direct Dial: 404.591.1839                                                              Brian T. Mohs
Adam@FriedGoldberg.com                                                            Nathan A. Gaffney
                                                                                 Briant G. Mildenhall
May 15, 2024                                                                       Drew C. Timmons
                                                                                      Adam P. Smith
                                                                                   Daniel J. Kingsley
Via Facsimile: (770) 831-0845
Clayton Properties Group, Inc. d/b/a Chafin Builders
Attn: Legal Department
5230 Belle Wood Court, Suite A
Buford, Georgia 30518

       Re:     Ermilo Rodriguez-Zarco vs. AG Construction LLC, et al.
               State Court of Gwinnett County; Civil Action File No.: 24-C-00821-S3

Dear Sir or Madam:

Our firm represents Ermilo Rodriguez-Zarco in the above-referenced civil action. Enclosed you will
find a Request for Production of Documents which is served on you as provided by Georgia law,
specifically O.C.G.A. § 9-11-34(c), and which seeks to obtain information regarding certain records
that may be in your possession concerning this case.

We are happy to pay for any reasonable copying expenses associated with this request. We look
forward to receiving your response to this request in a timely manner. Should you have any
questions, please do not hesitate to give me a call at the number listed above.

Sincerely,

Fried Goldberg LLC




Adam P. Smith


APS/mbl
Enclosures
cc:   All Parties of Record (w/ encl)


                                                                 Three Alliance Center
FriedGoldberg.com
                                                          3550 Lenox Road Northeast
404.591.1800
                                                                            Suite 1500
Fax: 404.591.1801
                                                         Atlanta, Georgia 30326-4302

                      IN THE STATE COURT OF GWINNETT COUNTY
                                 STATE OF GEORGIA


 ERMILO RODRIGUEZ-ZARCO,

                             Plaintiff,
                                                        CIVIL ACTION
 vs.                                                    FILE NO. 24-C-00821-S3

 AG CONSTRUCTION LLC,
 ABC CORPORATION,
 DAGOBERTO LOPEZ, and
 MARTIN LOPEZ

                             Defendants.


  PLAINTIFF'S REQUEST FOR PRODUCTION OF DOCUMENTS TO NON-PARTY

To:      Clayton Properties Group, Inc. d/b/a Chafin Builders
         Attn: Legal Department
         5230 Belle Wood Court, Suite A
         Buford, Georgia 30518

         Within thirty (30) days after service hereof you are hereby requested, pursuant to O.C.G.A.

§ 9-11-34(c), to produce for inspection and copying at the offices of Fried Goldberg LLC, 3550

Lenox Road, N.E., Suite 1500, Atlanta, Georgia 30326, certified copies of the following

documents:

      1. Any and all Master Service Agreement(s) between Clayton Properties Group, Inc. d/b/a
         Chafin Builders and AG Construction LLC that were in effect in 2022;

      2. Any and all purchase order(s), contract(s), memo(s), e-mail(s), and/or any other
         documents regarding services to be provided and/or work to be performed by AG
         Construction LLC at any homes located within the Lancaster subdivision in Flowery
         Branch, Georgia in April or May of 2022, including but not limited to the house that was
         then known as “Lot 90,” which is located on Kempton Court within the Lancaster
         subdivision;

      3. Any and all documents regarding services that were provided and/or work that was
         performed by AG Construction LLC at any homes located within the Lancaster
         subdivision in Flowery Branch, Georgia in April or May of 2022, including but not

       limited to the house that was then known as “Lot 90,” which is located on Kempton
       Court within the Lancaster subdivision;

   4. Any and all documents, including but not limited to photographs, video recordings, audio
      recordings, witness statements, correspondence, e-mails, and/or memos, regarding the
      incident on May 9, 2022 in which Ermilo Rodriguez-Zarco was injured when an attic
      access ladder detached from the ceiling at a home located within the Lancaster
      subdivision in Flowery Branch, Georgia; and

   5. Any and all documents regarding or containing information about people who were
      present on the property (whether inside or outside of the house) on the date of the
      incident on May 9, 2022 in which Ermilo Rodriguez-Zarco was injured when an attic
      access ladder detached from the ceiling at a home located within the Lancaster
      subdivision in Flowery Branch, Georgia.

       In lieu of your appearance, you may comply with this request by mailing certified copies

of the requested documents. The reasonable cost of reproduction will be paid by Plaintiff's

counsel. A response and certification are attached which should be executed and returned.


       Dated on May 15, 2024.

                                               FRIED GOLDBERG LLC




                                               By:
                                                     MICHAEL L. GOLDBERG
                                                     Georgia Bar No. 299472
                                                     ADAM P. SMITH
                                                     Georgia Bar No. 899334
                                                     Attorneys for Plaintiff
3550 Lenox Road, N.E.
Suite 1500
Atlanta, Georgia 30326
(404) 591-1800 (phone)
(404) 591-1801 (fax)
Michael@friedgoldberg.com
Adam@friedgoldberg.com




                                               2

                                CERTIFICATE OF SERVICE

       I hereby certify that I have this day served a copy of the within and foregoing Request for

Production of Documents to Non-Party via electronic service and/or mailing to the following:

                                       Stephen M. Schatz
                                     Robert J. Kozloski, III
                             Swift, Currie, McGhee & Hiers, LLP
                             1420 Peachtree Street, N.E., Suite 800
                                    Atlanta, Georgia 30309
                                 steve.schatz@swiftcurrie.com
                               robert.kozloski@swiftcurrie.com

                                      Dagoberto Lopez
                                     6333 Horizon Drive
                                Flowery Branch, Georgia 30542

                                        Martin Lopez
                                     6333 Horizon Drive
                                Flowery Branch, Georgia 30542

       Dated on May 15, 2024.

                                                FRIED GOLDBERG LLC




                                                By:
                                                      MICHAEL L. GOLDBERG
                                                      Georgia Bar No. 299472
                                                      ADAM P. SMITH
                                                      Georgia Bar No. 899334
                                                      Attorneys for Plaintiff
3550 Lenox Road, N.E.
Suite 1500
Atlanta, Georgia 30326
(404) 591-1800 (phone)
(404) 591-1801 (fax)
Michael@friedgoldberg.com
Adam@friedgoldberg.com




                                                3

                             RESPONSE OF NON-PARTY TO
                       REQUEST FOR PRODUCTION OF DOCUMENTS

       COMES NOW Clayton Properties Group, Inc. d/b/a Chafin Builders and responds to

Plaintiff's Request for Production of Documents to Non-Party served pursuant to O.C.G.A. § 9-

11-34(c) as follows:

       Please indicate the appropriate response below:

       [ ]     Copies of the requested materials have been attached.

       [ ]     The materials requested will be produced at the designated address.

       [ ]     The materials requested do not exist.

                                                AFFIDAVIT

       Personally came before me, the undersigned officer, duly authorized to administer oaths,

                                 , who upon being duly sworn, states that (s)he is the custodian of

these records and that the copies attached hereto are true and correct copies of the requested

                records of                                   and that said records were kept in the normal

course of business of Clayton Properties Group, Inc. d/b/a Chafin Builders.

       Dated this                 day of                                       , 20     .



                                                            Records Custodian
STATE OF _________________
COUNTY OF

       The foregoing instrument was acknowledged before me this                day of             , 20

by                                         .


                        Signature of Notary Public


                        Print, type or stamp commissioned name of Notary Public
                        Personally known to me        OR Produced Identification

EXHIBIT B

5/30/24, 2:40 PM                                                              GEORGIA




                       GEORGIA                                                                   GEORGIA SECRETARY OF STATE

                       CORPORATIONS DIVISION                                         BRAD RAFFENSPERGER

                                                                                                                            HOME (/)
       BUSINESS SEARCH

        BUSINESS INFORMATION
                      Business Name: CBUILD Holdings, LLC                          Control Number: 09013878
                                        Domestic Limited
                       Business Type:                                               Business Status: Active/Compliance
                                        Liability Company
                    Business Purpose: NONE
                                    5230 BELLE WOOD
                                    COURT, SUITE A,                            Date of Formation /
          Principal Office Address:                                                                2/25/2009
                                    BUFORD, GA, 30518,                          Registration Date:
                                    USA
                                                                          Last Annual Registration
                   State of Formation: Georgia                                                     2024
                                                                                             Year:



        REGISTERED AGENT INFORMATION
          Registered Agent Name: HALEY & HALEY LAW GROUP, LLC
                    Physical Address: 4484 Commerce Drive, Suite A, Buford, GA, 30518, USA
                             County: Gwinnett


                                                     Filing History        Name History
         Back
                                                         Return to Business Search




     Office of the Georgia Secretary of State Attn: 2 MLK, Jr. Dr. Suite 313, Floyd West Tower Atlanta, GA 30334-1530,
                      Phone: (404) 656-2817 Toll-free: (844) 753-7825, WEBSITE: https://sos.ga.gov/
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EXHIBIT C

From:           Adam Smith
To:             info@haleyandhaley.com
Cc:             Madison Lever
Subject:        Non party request to Chafin
Date:           Friday, September 20, 2024 10:13:08 AM


Dea,

Thank you for taking my call. Per our discussion, I have CCed my paralegal
Madison. Madison will send over a copy of the nonparty request we sent to Chafin back in
May. If you could please have Mr. Haley give me a call about this at his earliest convenience,
I would greatly appreciate it. We have not yet received any response to this request and I'd like
to get this resolved in the fastest and easiest way possible for all involved.

Thanks,


- Adam

Direct:   (404) 591-1839
Cell: (404) 561-1181

EXHIBIT D

From:                 Madison Lever
To:                   Adam Smith; info@haleyandhaley.com
Subject:              RE: Non party request to Chafin
Date:                 Friday, September 20, 2024 10:17:00 AM
Attachments:          NPRPD to Chafin.pdf
                      image002.png
                      image003.png
                      image004.png
                      image005.png



Good Morning,

Please see attached.

Thank you,




 Madison B. Lever                                    Direct: 404.856.3675
 Paralegal                                           Office: 404.591.1800
                                                  Toll Free: 877.591.1801
 madison@friedgoldberg.com                              Fax: 404.591.1801
    3550 Lenox Road, N.E. | Suite 1500 | Atlanta, Georgia 30326-4302




NOTICE: The information transmitted in this e-mail is intended only for the person(s) to which it is addressed and may contain confidential, proprietary, and/or privileged material.  Any review, re-transmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or
entities other than the intended recipient is prohibited.  If you received this in error, please contact the sender and delete the material from all computers. Nothing in this e-mail should be relied upon as legal or tax advice and nothing herein shall be construed to create an attorney-client relationship where none
otherwise exists.


From: Adam Smith 
Sent: Friday, September 20, 2024 10:13 AM
To: info@haleyandhaley.com
Cc: Madison Lever 
Subject: Non party request to Chafin


Dea,

Thank you for taking my call. Per our discussion, I have CCed my paralegal Madison. Madison will send over a copy of the nonparty request we sent to Chafin back in May. If you could please have Mr. Haley give me a call
about this at his earliest convenience, I would greatly appreciate it. We have not yet received any response to this request and I'd like to get this resolved in the fastest and easiest way possible for all involved.

Thanks,


- Adam

Direct:   (404) 591-1839
Cell:   (404) 561-1181

EXHIBIT E

From:                  Adam Smith
To:                    Madison Lever; info@haleyandhaley.com
Subject:               RE: Non party request to Chafin
Date:                  Monday, October 7, 2024 10:57:49 AM
Attachments:           image002.png
                       image003.png
                       image004.png
                       image005.png
                       NPRPD to Chafin.pdf
Importance:            High



I need someone to call me on this by close of business or I am going to have to file a motion to compel a response and seek sanctions for attorney fees and costs.

Thanks,

- Adam

Direct:   (404) 591-1839
Cell:       (404) 561-1181



                     Adam P. Smith
                     Trial Attorney
photo                    404.591.1839        404.561.1181        www.FriedGoldberg.com

                         adam@FriedGoldberg.com

                         3550 Lenox Road Northeast | Suite 1500 | Atlanta, Georgia 30326-4302




NOTICE: The information transmitted in this e-mail is intended only for the person(S) to which it is addressed and may contain confidential, proprietary, and/or privileged material. Any review, re-transmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or entities other
than the intended recipient is prohibited. If you received this in error, please contact the sender and delete the material from all computers. Nothing in this e-mail should be relied upon as legal or tax advice and nothing herein shall be construed to create an attorney- client relationship where none otherwise exists.




From: Madison Lever 
Sent: Friday, September 20, 2024 10:18 AM
To: Adam Smith ; info@haleyandhaley.com
Subject: RE: Non party request to Chafin


Good Morning,

Please see attached.

Thank you,




 Madison B. Lever                                      Direct: 404.856.3675
 Paralegal                                             Office: 404.591.1800
                                                    Toll Free: 877.591.1801
 madison@friedgoldberg.com                                Fax: 404.591.1801
    3550 Lenox Road, N.E. | Suite 1500 | Atlanta, Georgia 30326-4302




NOTICE: The information transmitted in this e-mail is intended only for the person(s) to which it is addressed and may contain confidential, proprietary, and/or privileged material.  Any review, re-transmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or
entities other than the intended recipient is prohibited.  If you received this in error, please contact the sender and delete the material from all computers. Nothing in this e-mail should be relied upon as legal or tax advice and nothing herein shall be construed to create an attorney-client relationship where none
otherwise exists.


From: Adam Smith 
Sent: Friday, September 20, 2024 10:13 AM
To: info@haleyandhaley.com
Cc: Madison Lever 
Subject: Non party request to Chafin


Dea,

Thank you for taking my call. Per our discussion, I have CCed my paralegal Madison. Madison will send over a copy of the nonparty request we sent to Chafin back in May. If you could please have Mr. Haley give me a call
about this at his earliest convenience, I would greatly appreciate it. We have not yet received any response to this request and I'd like to get this resolved in the fastest and easiest way possible for all involved.

Thanks,


- Adam

Direct:   (404) 591-1839
Cell:   (404) 561-1181

From:                  Adam Smith
To:                    jan@haleyandhaley.com.
Cc:                    Madison Lever
Subject:               FW: Non party request to Chafin
Date:                  Monday, October 7, 2024 10:59:56 AM
Attachments:           image002.png
                       image003.png
                       image004.png
                       image005.png
                       NPRPD to Chafin.pdf
Importance:            High



Jan,

Please see below/attached.   I have not received any response to this, and I need someone to call me ASAP. If you are not the appropriate person to handle this, please forward it to someone who can respond and ask them to call me by
COB today.

Thanks,

- Adam

Direct:   (404) 591-1839
Cell:       (404) 561-1181



                     Adam P. Smith
                     Trial Attorney
photo                    404.591.1839        404.561.1181        www.FriedGoldberg.com

                         adam@FriedGoldberg.com

                         3550 Lenox Road Northeast | Suite 1500 | Atlanta, Georgia 30326-4302




NOTICE: The information transmitted in this e-mail is intended only for the person(S) to which it is addressed and may contain confidential, proprietary, and/or privileged material. Any review, re-transmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or entities other
than the intended recipient is prohibited. If you received this in error, please contact the sender and delete the material from all computers. Nothing in this e-mail should be relied upon as legal or tax advice and nothing herein shall be construed to create an attorney- client relationship where none otherwise exists.




From: Adam Smith 
Sent: Monday, October 7, 2024 10:57 AM
To: Madison Lever ; info@haleyandhaley.com
Subject: RE: Non party request to Chafin
Importance: High


I need someone to call me on this by close of business or I am going to have to file a motion to compel a response and seek sanctions for attorney fees and costs.

Thanks,

- Adam

Direct:   (404) 591-1839
Cell:       (404) 561-1181



From: Madison Lever 
Sent: Friday, September 20, 2024 10:18 AM
To: Adam Smith ; info@haleyandhaley.com
Subject: RE: Non party request to Chafin


Good Morning,

Please see attached.

Thank you,




 Madison B. Lever                                      Direct: 404.856.3675
 Paralegal                                             Office: 404.591.1800
                                                    Toll Free: 877.591.1801
 madison@friedgoldberg.com                                Fax: 404.591.1801
    3550 Lenox Road, N.E. | Suite 1500 | Atlanta, Georgia 30326-4302




NOTICE: The information transmitted in this e-mail is intended only for the person(s) to which it is addressed and may contain confidential, proprietary, and/or privileged material.  Any review, re-transmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or
entities other than the intended recipient is prohibited.  If you received this in error, please contact the sender and delete the material from all computers. Nothing in this e-mail should be relied upon as legal or tax advice and nothing herein shall be construed to create an attorney-client relationship where none
otherwise exists.


From: Adam Smith 
Sent: Friday, September 20, 2024 10:13 AM
To: info@haleyandhaley.com
Cc: Madison Lever 
Subject: Non party request to Chafin


Dea,

Thank you for taking my call. Per our discussion, I have CCed my paralegal Madison. Madison will send over a copy of the nonparty request we sent to Chafin back in May. If you could please have Mr. Haley give me a call
about this at his earliest convenience, I would greatly appreciate it. We have not yet received any response to this request and I'd like to get this resolved in the fastest and easiest way possible for all involved.

Thanks,


- Adam

Direct:   (404) 591-1839
Cell:   (404) 561-1181

From:                  Adam Smith
To:                    dea@haleyandhaley.com
Cc:                    Madison Lever
Subject:               FW: Non party request to Chafin
Date:                  Monday, October 7, 2024 11:04:22 AM
Attachments:           image002.png
                       image003.png
                       image004.png
                       image005.png
                       NPRPD to Chafin.pdf
Importance:            High



Dea,

Please see below/attached.   I have not received any response to this, and I need someone to call me ASAP. If you are not the appropriate person to handle this, please forward it to someone who can respond and ask them to call me by
COB today. If I do not hear back, I am going to have to file a motion to compel a response and seek sanctions for attorney fees and costs.

Thanks,

- Adam

Direct:   (404) 591-1839
Cell:       (404) 561-1181



                     Adam P. Smith
                     Trial Attorney
photo                    404.591.1839        404.561.1181        www.FriedGoldberg.com

                         adam@FriedGoldberg.com

                         3550 Lenox Road Northeast | Suite 1500 | Atlanta, Georgia 30326-4302




NOTICE: The information transmitted in this e-mail is intended only for the person(S) to which it is addressed and may contain confidential, proprietary, and/or privileged material. Any review, re-transmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or entities other
than the intended recipient is prohibited. If you received this in error, please contact the sender and delete the material from all computers. Nothing in this e-mail should be relied upon as legal or tax advice and nothing herein shall be construed to create an attorney- client relationship where none otherwise exists.




From: Adam Smith
Sent: Monday, October 7, 2024 11:01 AM
To: 'jan@haleyandhaley.com' 
Cc: Madison Lever 
Subject: FW: Non party request to Chafin
Importance: High


Jan,

Please see below/attached.   I have not received any response to this, and I need someone to call me ASAP. If you are not the appropriate person to handle this, please forward it to someone who can respond and ask them to call me by
COB today.

Thanks,

- Adam

Direct:   (404) 591-1839
Cell:       (404) 561-1181



From: Adam Smith 
Sent: Monday, October 7, 2024 10:57 AM
To: Madison Lever ; info@haleyandhaley.com
Subject: RE: Non party request to Chafin
Importance: High


I need someone to call me on this by close of business or I am going to have to file a motion to compel a response and seek sanctions for attorney fees and costs.

Thanks,

- Adam

Direct:   (404) 591-1839
Cell:       (404) 561-1181



From: Madison Lever 
Sent: Friday, September 20, 2024 10:18 AM
To: Adam Smith ; info@haleyandhaley.com
Subject: RE: Non party request to Chafin


Good Morning,

Please see attached.

Thank you,




 Madison B. Lever                                      Direct: 404.856.3675
 Paralegal                                             Office: 404.591.1800
                                                    Toll Free: 877.591.1801
 madison@friedgoldberg.com                                Fax: 404.591.1801
    3550 Lenox Road, N.E. | Suite 1500 | Atlanta, Georgia 30326-4302




NOTICE: The information transmitted in this e-mail is intended only for the person(s) to which it is addressed and may contain confidential, proprietary, and/or privileged material.  Any review, re-transmission, dissemination or other use of, or taking of any action in reliance upon this information by persons or
entities other than the intended recipient is prohibited.  If you received this in error, please contact the sender and delete the material from all computers. Nothing in this e-mail should be relied upon as legal or tax advice and nothing herein shall be construed to create an attorney-client relationship where none
otherwise exists.


From: Adam Smith 
Sent: Friday, September 20, 2024 10:13 AM
To: info@haleyandhaley.com

Cc: Madison Lever 
Subject: Non party request to Chafin


Dea,

Thank you for taking my call. Per our discussion, I have CCed my paralegal Madison. Madison will send over a copy of the nonparty request we sent to Chafin back in May. If you could please have Mr. Haley give me a call
about this at his earliest convenience, I would greatly appreciate it. We have not yet received any response to this request and I'd like to get this resolved in the fastest and easiest way possible for all involved.

Thanks,


- Adam

Direct:   (404) 591-1839
Cell:   (404) 561-1181