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Case 1:08-cv-01971-WSD

Document 9-6

Filed 07/11/2008

Page 1 of 2

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BANK O F AMERI C A P L AZA 600 P EA L H T REE S TREE T, N .E . S UI TE 5200 A TLANTA , GEORGIA 30308 .2218 www .troutmsnsanders .com TELEPHONE : 404-885-3000 FACSIMILE : 404-888-3900

B rian P . W att br i s n . w ari@t ro utma n s a nders. c o m

D irect D ial : 404-885-3203 D irect F ax : 404-962-6767

February 27, 2008

VIA E-MAIL TO JANET ~[1}1FIEAVENLYGLASS.C4M AND FIRST CLASS U.S. MAIL

Mr. James B . Stegeman, pro se Ms . Janet McDonald, pro se 821 Sheppard Road

Stone Mountain, GA 30083 RE :

Janet McDonald and James Stegeman v . Georgia Power Co ., et al. DeKalb County Superior Court, Case No . 07CV11398-6

Dear Mr . Stegeman and Ms . McDonald: This letter will confirm our conversation on Tuesday, February 26, 2008, so if I misstate anything, please let me know so that we can clear up any confusion . First of all, thank you for speaking with me yesterday regarding your responses to Defendant Georgia Power Company's First interrogatories to Plaintiffs Janet McDonald and James Stegeman an d Defendant Georgia Power Company's First Request for Production of Documents to Plaintiffs Janet McDonald and James Stegeman . I appreciate your time and willingness to reach a solution to the document production issues we've encountered . In our telephone conversation, you confirmed that the documents enclosed with your letter dated February 22, 2008, are all of the documents in your possession responsive to Georgia Power's Interrogatory Number 15 . With regards to the "1937 Georgia Railway and Power Company Map," you indicated that the document is approximately 18" x 24" and that because of its size you had encountered difficulty in finding a business that could reproduce the map . I suggested a FedEx Kinko's Copy Center, or, alternatively, that you produce your document to us and we could handle the copying and return the map to you afterwards . You indicated that you would check with Kinko's and we agreed to speak again by the end of the week . You also agreed to produce a copy of the 1937 Easement Agreement, referenced in your responses to Georgia Power's Interrogatories and Requests for Production of Documents . As for the photographs from 2004 and 2007, you agreed to produce a CD containing the photographs in digital format along with the production of the 1937 Easement Agreement .

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Case 1:08-cv-01971-WSD

Document 9-6

Filed 07/11/2008

Page 2 of 2

i, TROUTMAN SANDERS LLP A T T O R N E Y S A T LAW p .LI M 1 T ED LIABILITY

PARTNERSH I P

Mr. James Stegeman Ms. Janet McDonald February 27, 2008 Page 2 of 2

We also discussed the video recording of the August 2007 incident referenced in your Complaint, as well as any other video recordings responsive to Georgia Power's discovery requests . You stated that the video cassette is not a standard VHS, but rather a Hi8 cassette . I suggested that in your communications with Kinko's you inquire as to whether they can provide a copy of the cassette in DVD format . If a DVD copy is not available, I requested either a copy of the Fig cassette car a transferr of the video to VHS . You indicated that you would confer with Kinko's and let me know of their copying capabilities in this regard . Finally, we discussed scheduling each of Plaintiff's depositions to take place in March . You indicated that the briefing schedule imposed by the 11th Circuit in your appeal from an unrelated Federal lawsuit created time constraints that caused you some concern . You indicated that you would check your respective schedules and get back to me . I look forward to speaking with you again soon . Please do not hesitate to contact me with any questions or concerns that you might have . Respectfully,

Brian P . Watt


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