“Good afternoon:
Please see the attached correspondence.
Thank you,
Leesa Guarnotta”
2022-10-24 Letter to Scenes from the Atlanta Forest re Non-Party RPD
“…REQUEST FOR PRODUCTION OF DOCUMENTS: Please produce the following documents at the offices of Blackhall’s counsel, John O’Shea
Sullivan, Burr & Forman LLP, 171 Seventeenth Street, N.W., Suite 1100, Atlanta, Georgia 30363,
within thirty (30) days of service of these Requests, or at such other time and place as is mutually
agreed upon by counsel:
1. All communications with Plaintiffs (or any of them) regarding ICP, the Land Swap,
the Complaint, Blackhall, and/or Ryan Millsap.
2. All internal communications regarding ICP, the Land Swap, the Complaint,
Blackhall, and/or Ryan Millsap.
3. All communications with the Blank Foundation regarding ICP, the Land Swap, the
Complaint, Blackhall, and/or Ryan Millsap.
4. All communications with TPL regarding ICP, the Land Swap, the Complaint,
Blackhall, and/or Ryan Millsap.
5. All communications with DeKalb County, or anyone employed by DeKalb County,
regarding ICP, the Land Swap, the Complaint, Blackhall, and/or Ryan Millsap.
6. All communications with any third party regarding ICP, the Land Swap, the
Complaint, Blackhall, and/or Ryan Millsap.
7. All communications, internal or otherwise, regarding any protest of or
meeting/gathering relating to the Land Swap.
8. All documents reflecting any payment, donation, or transfer of money from you to
Plaintiffs, or their attorneys, regarding the Land Swap or the Complaint.
9. All photographs or videos you have of any protest of or meeting/gathering relating
to the Land Swap.
10. All photographs or videos you have of Plaintiffs, or any of them, on the Blackhall
Property from October 13, 2020 to the present.
11. All reports, appraisals, evaluations, etc. which constitute, relate to, or contain
information about the Blackhall Property.
12. All reports, appraisals, evaluations, etc. which constitute, relate to, or contain
information about the DeKalb Property.
13. All documents which relate to or contain information about your communications
with persons who donate money or in kind gifts to you…”
Submitted over email