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THE SUPERIOR COURT FOR THE COUNTY OF COBB STATE OF GEORGIA CHRISTOPHER MOSES Plaintiff, Civil Action File ve No.05-1-8395-35 TRATON CORP. and RICK FOSTER Defendants. PLAINTIFF’S RESPONSES TO DEFENDANTS’ REQUEST FOR ENTRY ONTO LAND TO INSPECT Plaintiff CHRISTOPHER MOSES hereby responds and objects to Defendants TRATON CORP. and RICK FOSTER’s First Request for Production of Documents as follows: L Plaintiff objects to Defendants’ request for entry onto Plaintiff's premises. Specifically, the request is overbroad, insofar as the identified premises, 1155 Lakefield Walk, Marietta, Georgia 30064, includes not only Mr. Moses’ damaged lawn, but undamaged portions of Mr. Moses’ lawn, as well as the residence. Insofar as Defendants’ request is overbroad and overly intrusive, Mr. Moses objects to Defendants’ request and DENIES their request to enter upon the land to inspect the land. This 11th day of February, 2006. Sam $. Han, Ph.D. Georgia Bar No. 322284 SAM HAN, P.C. 330 Bloombridge Way, NW Marietta, GA 30066 Ph: (404) 514-8237 Email: sam.han.pe@gmail.com AM HAN, P.C. Sam S. Han, Ph.D. THE SUPERIOR COURT FOR THE COUNTY OF COBB STATE OF GEORGIA CHRISTOPHER MOSES Plaintiff, Civil Action File v. TRATON CORP., and RICK FOSTER 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. RES! TO DEFEND: ST FOR ENTRY AND TO INSPECT upon the following via first class mail, postage prepaid, and properly addressed as follows: Eldon Basham, Esq. Attorney for Traton Corp. and Mr. Rick Foster ‘Moore Ingram Johnson & Steele 192 Anderson Street Marietta, Georgia 30060 Charles B. Pekor, Esq. Pekor & DeWoskin ‘Suite 1060 270 Peachtree Street, N.W. Atlanta, Georgia 30303