IN THE

COURT OF APPEALS OF GEORGIA

CHRISTOPHER MOSES ]
Plaintiff-Appellant, ] Case Number
v. ] A07A1474
TRATON CORP., et al. ]
Defendants-Appellees. ]

Request for Oral Arguments and Certification of Service

17 April 2007

William L. Martin, III

Clerk, Georgia Court of Appeals
47 Trinity Avenue
Suite 501
Atlanta, GA 30334

Dear Mr. Martin:

We hope that this letter finds you doing well.

In accordance with Rule 28 of the Georgia Court of Appeals,

Appellant hereby requests this Honorable Court for oral arguments
on the above-captioned
matter.

This case is of paramount

importance because the
outcome of this case will
affect the rights of every
homeowner in Georgia. Oral
argument should be granted
in this appeal because the
decision-making process
will be significantly aided
by oral arguments.

The sole issue on appeal is

whether the owner of the
home (shown at right) has
standing to sue for damages
to the yard that is
attached to his home
(damaged yard also shown at
right), when the owner has
continuously maintained and
cultivated the entire yard,
and the condition of the
entire yard affects the
value of the home.
Court of Appeals Case Number A07A1474
17 April 2007
Page 2

This case hinges on the crucial but subtle legal distinction

between possession and ownership. The presence of counsel to
respond to questions by this Honorable Court, in distinguishing
between possession and ownership, will significantly aid in the
decision-making process.

Appellant certifies that, on 29 March 2007, Appellant notified

Appellees' counsel of Appellant's intent to argue this matter
orally. Counsel for Appellees indicated, on 05 April 2007, that
Appellees likewise intend to argue this matter orally. Both
Appellant and Appellees request fifteen (15) minutes each for
oral arguments.

The undersigned attorney is scheduled to argue orally on behalf

of Appellant.

Appellant also certifies that this request has been properly

served on counsel for Appellees.

Sincerely,

Sam S. Han
Georgia Bar Number 322284