THE SUPERIOR COURT FOR THE COUNTY OF COBB STATE OF GEORGIA CHRISTOPHER MOSES ] J Plaintiff, ] Civil Action File v. ] ] TRATON CORP., and ] No.05-1-8395-35 RICK FOSTER J ] JURY TRIAL DEMANDED Defendants. ] PLAINTIFF'S FIRST REQUEST FOR ADMISSIONS TO DEFENDANT RICK FOSTER Plaintiff, Christopher L. Moses, by and through its undersigned attorneys hereby requests that Defendant Rick Foster answer under oath the following FIRST REQUEST FOR ADMISSIONS TO DEFENDANT RICK FOSTER, fully and in writing, within the time and in the manner provided and required by law. NOTE A: As used herein, the terms "you" or "your" are intended to and shall embrace and include Defendant Rick Foster, and all attorneys, agents, servants, employees, representatives, and private investigators of or employed by Rick Foster and all others who are in possession of or who may have obtained information for or on behalf of Rick Foster. NOTEB: —_Asused herein, the term "Traton" is intended to and shall embrace and include Defendant Traton Corporation, affiliates of Traton Corporation (e.g., Traton Corp. of Cobb, Inc., Traton Development Corp., Traton Homes Realty, Inc., Traton Homes, LLC, Traton Investments, LLC, Traton of Georgia, LLC, or Poston Properties, Inc. (hereafter "Traton entities")), attorneys, agents, servants, employees, representatives, and private investigators of or employed by any of the Traton entities and all others who are in possession of or who may haveobtained information for or on behalf of any of the Traton entities. NOTEC: — Asused 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, partnerships, associations, corporations, government agencies, and government departments. REQUEST FOR ADMISSIONS 1. Admit that, in an email message of September 14, 2005, to Mr. Moses ("September 14 email message"), you stated "it seemed reasonable to assume that the developer's large equipment trailers ran over your curb and placed a rut in your grass.” 2. Admit that it was reasonable to assume that developer's large equipment trailers ran over Mr. Moses’ curb and damaged Mr. Moses' property. 3. Admit that you were referring to Traton Corporation when you referred to "the developer" in the September 14 email message. 4, Admit that you were referring to Traton Corp. of Cobb, Inc., when you referred to “the developer" in the September 14 email message. 5. Admit that you were referring to Traton Development Corp. when you referred to "the developer" in the September 14 email message. 6. Admit that you were referring to Traton Homes Realty, Inc., when you referred to "the developer” in the September 14 email message, 7, Admit that you were referring to Traton Homes, LLC, when you referred to "the developer" in the September 14 email message. 8. Admit that you were referring to ‘Traton Investments, LLC, when you referred to"the developer" in the September 14 email message. 9. Admit that you were referring to Traton of Georgia, LLC, when you referred to “the developer" in the September 14 email message. 10. Admit that you were referring to Poston Properties, Inc., when you referred to "the developer" in the September 14 email message. 11, Admit that, in a letter addressed to you, Mr. Moses expressly stated: "To ease the tension between both parties, I strongly suggest revisiting communication methods and beginning to document communication and commitment dates." 12, Admit that Mr. Moses contacted Traton Corporation through its Intemet form, at http://www.tratonhomes.com/contactus.php. 13, Admit that Mr. Moses contacted Traton Corp. of Cobb, Inc., through its Internet form, at http//www tratonhomes.com/contactus.php. 14, Admit that Mr. Moses contacted ‘Traton Development Corp. through its Internet form, at http://www tratonhomes.com/contactus.php. 15. Admit that Mr. Moses contacted Traton Homes Realty, Inc., through its Internet form, at http://www tratonhomes.com/contactus.php. 16. Admit that Mr, Moses contacted Traton Homes, LLC, through its Internet form, at http:/www.tratonhomes.cony/contactus.php. 17. Admit that Mr. Moses contacted Traton Investments, LLC, through its Internet form, at http://www. tratonhomes.com/contactus,php. 18, Admit that Mr. Moses contacted Traton of Georgia, LLC, through its Internet form, at http://www. tratonhomes.com/contactus.php.