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POSTON PROPERTIES, INC., JURY TRIAL DEMANDED CoeR¢ Pices C6 Oct 13 THE SUPERIOR COURT FOR THE COUNTY 0 STATE OF GEORGIA ¢ c9_ Ve CHRISTOPHER MOSES 1 srt ke ae j 7 Plaintiff, ] Civil Action File Vv. ] J TRATON CORP., ] No,_O6-\-B344|—25— RICK FOSTER, ] DALE BERCHER, i WILLIAM POSTON, ] MILLBURN POSTON, ] NELLIE POSTON, ] CHRISTOPHER POSTON, i CLIFF POSTON, | SUSAN HECK, ] TAMMY CALHOUN, } REBECCA BRYANT, J and J 1 ] 1 Defendants, COMPLAIN Christopher Moses respectfully shows the honorable Court the following: 1, Traton (ie., Traton Corp. or its affiliates or agents or employees) has repeatedly caused damage to real property belonging to Christopher Moses ("Mr. Moses") 2. Mr. Moses repeatedly requested that Traton cease damaging his property. 3. However, Traton flagrantly and purposefully disregarded Mr. Moses' requests, and continued to damage Mr. Moses' property. 4, Traton has admitted that it has never attempted to fix the damage to Mr. Moses’ property. 5. Iman attempt to amicably resolve this issue, Mr. Moses repeatedly contacted ‘Traton. 6. However, Traton refused to respond to Mr. Moses’ communications. 7. Asa result, Mr. Moses reported Traton to the Better Business Bureau ("BBB"). 8. In response to Mr. Moses’ reporting Traton to the BBB, Traton responded through its attorneys. 9, Inthat response, Traton expressly refused to fix the property that it damaged. 10, Assuch, Mr. Moses was forced to seek recourse through the Georgia Courts. 11. _ In filing the complaint, Mr. Moses sought to prevent Traton Corp. from continuing their trespass onto Mr. Moses’ property. The Conti ig Tresp: 12, Unfortunately, despite Traton’'s awareness of this pending litigation, Traton continued to flaunt its utter disregard for Mr. Moses’ property rights. 13. Specifically, despite Mr. Moses’ repeated requests for Traton to stop entering onto his property, and despite the pending litigation against Traton Corp. for trespass, Traton continued its trespass onto Mr. Moses’ property. 14, Astoundingly, Traton flaunted its violation of Mr. Moses’ property rights by taking pictures of its employee or agent standing on the damaged property. 15. Even more outrageous than walking all over Mr. Moses’ yard to take pictures, Traton ran over the damaged portions of Mr. Moses’ yard with a lawn mower, in an effort to minimize the damaged appearance to the lawn. 16. Inother words, despite knowing that the damaged portion of the lawn was the subject matter of this pending dispute, Traton tampered with that evidence in an effort to mask the actual damage to the lawn. 17. Allof this was done without asking whether Traton could come onto Mr. Moses’ property. 18. _Allof this was done despite Mr. Moses' repeated requests for Traton to stay off of Mr. Moses! property, and all during the pendency of this litigation. PARTIES 19, Plaintiff incorporates the above-recited allegations as if expressly set forth here in their entireties. 20. Mr. Moses is an individual that resides at 1155 Lakefield Walk, Marietta, Georgia 30064. 21. Traton Comp. is a Georgia corporation, duly licensed to do business in Georgia, and having its principal place of business at 639 Whitlock Ave, SW, Marietta, Georgia 30064. z, Traton Corp. oversees the development of the Lakefield Manor subdivision, and has appeared at zoning variance hearings related to the Lakefield Manor subdivision. 23. The registered agent for Traton Corp., John H. Moore, was served on October 18, 2005, at: JOHN H. MOORE 192 ANDERSON ST., STE 100 MARIETTA, GA 30060