Professional Documents
Culture Documents
STATE OF GEORGIA
CHRISTOPHER MOSES ]
Plaintiff, ] Civil Action File
v. ]
] No.05-1-8395-35
TRATON CORP., et al. ] JURY TRIAL DEMANDED
Defendants. ]
Moses"), by and through its attorneys SAM HAN, P.C., hereby serves this PLAINTIFF'S FIRST
upon MARK CALHOUN, 2566 Lakefield Way, Marietta, Georgia 30064. Please submit your
responsive documents to Mr. Moses' attorney, Sam S. Han, Ph.D., SAM HAN, P.C., 330
"Chris Moses," "Mr. Moses," or "Chris L. Moses" are intended to and shall embrace and include
Plaintiff Christopher L. Moses and all attorneys, accountants, agents, servants, employees,
and all others who are in possession of or who may have obtained information for or on behalf of
NOTE B: As used herein, the terms "you" or "your" are intended to and shall
embrace and include Defendant MARK CALHOUN and all attorneys, accountants, agents,
MARK CALHOUN, and all others who are in possession of or who may have obtained
NOTE C: As used herein, the term "person" is intended to and shall embrace and
include all natural persons and any type of entity whatsoever, including, but not limited to,
NOTE D: As used herein the term "document" includes all letters, telephone records
opinions, treaties, textbooks, records memoranda, notes, notebooks, work sheets, x-rays,
diaries, computer printouts, information stored on computers but of which no printout presently
exists, and all other written, recorded, photographic or graphic items and all records of
custody or control, further including without limitation any items which are included in the
definition of "document" as that term is used or meant in O.C.G.A. § 9-11-34, including copies
or reproductions of all the foregoing items upon which notations and writing have been made
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NOTE E: All documents that are normally stored in electronic format (e.g., email
messages (e.g., ".msg" for email messages stored using Microsoft Outlook), spreadsheets (e.g.,
".xls" for spreadsheets stored using Microsoft Excel), word processing files (e.g., ".doc" for files
stored using Microsoft Word), Internet forms (e.g., ".html," ".php," etc. for Internet files), etc.)
are requested to be produced in their respective native electronic formats, as they are normally
kept in the ordinary course of business. As used herein the term "native electronic format" means
responses if you or your attorneys obtain further information between the time the answers are
NOTE G: As used herein, the phrase "your allegations" shall mean the allegations that you
made in your hand-written note on the back of page 1 of Defendants' Brief in Opposition to Plaintiff's
Motion for Summary Judgment and in Support of Defendants' Cross Motion for Summary Judgment,
NOTE H: Unless a specific request states otherwise, the time frame applicable to these
requests is from and including October 13, 1996 to the present (i.e., the past ten (10) years).
REQUESTS
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1. Produce all documents and tangible things that show the location of your mailbox.
2. Produce all documents and tangible things that evidence your qualifications to determine
3. Produce all documents and tangible things that evidence your qualifications to determine
4. Produce all documents and tangible things that support your allegation that your mailbox
5. Produce all documents and tangible things that support your allegation that the right-of-
6. Produce all documents and tangible things that support your allegation that placing a
7. Produce all documents and tangible things that support your allegation that placing a
document on your mailbox, which is located wholly within the right-of-way in front of
8. Produce all documents and tangible things that evidence your property interest in the
9. Produce all documents and tangible things that evidence your possessory interest in the
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Respectfully submitted September 11, 2006.
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THE SUPERIOR COURT FOR THE COUNTY OF COBB
STATE OF GEORGIA
CHRISTOPHER MOSES ]
Plaintiff, ] Civil Action File
v. ] JURY TRIAL DEMANDED
TRATON CORP., et al. ] No.05-1-8395-35
Defendants. ]
CERTIFICATE OF SERVICE
This is to certify that on this day I served the within and foregoing PLAINTIFF'S FIRST
Mark Calhoun
2566 Lakefield Way
Marietta, Georgia 30064
and
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EXHIBIT
A