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THE SUPERIOR COURT FOR THE COUNTY OF COBB

STATE OF GEORGIA

CHRISTOPHER MOSES ]
Plaintiff, ] Civil Action File
v. ]
] No.05-1-8395-35
TRATON CORP., et al. ] JURY TRIAL DEMANDED
Defendants. ]

PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO NON-


PARTY MARK CALHOUN

In accordance with O.C.G.A. § 9-11-34(c)(1), Plaintiff, Christopher L. Moses ("Mr.

Moses"), by and through its attorneys SAM HAN, P.C., hereby serves this PLAINTIFF'S FIRST

REQUEST FOR PRODUCTION OF DOCUMENTS TO NON-PARTY MARK CALHOUN

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

Bloombridge Way, Marietta, GA 30066, as required by O.C.G.A. § 9-11-34(b)(2).

NOTES AND INSTRUCTIONS

NOTE A: As used herein, the terms "Christopher L. Moses," "Christopher Moses,"

"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,

representatives, affiliates, and private investigators of or employed by said Christopher L. Moses,

and all others who are in possession of or who may have obtained information for or on behalf of

said Christopher L. Moses.

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,

servants, employees, representatives, affiliates, and private investigators of or employed by said

MARK CALHOUN, and all others who are in possession of or who may have obtained

information for or on behalf of said MARK CALHOUN

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,

partnerships, associations, corporations, government agencies, and government departments.

NOTE D: As used herein the term "document" includes all letters, telephone records

and notations, minutes, bulletins, instructions, advertisements, literature, reports, published

opinions, treaties, textbooks, records memoranda, notes, notebooks, work sheets, x-rays,

payments records, drawings, agreements, memoranda of conversations, recordings, photographs,

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

information or communication of whatever type or nature, whether tangible or not, by whomever

produced or reproduced now or at any time in plaintiff's actual or constructive possession,

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

which do not appear on the originals.

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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

in electronic format as it is normally stored on a client computer or a server computer and

accessible using the software by which the document was created.

NOTE F: These requests shall be deemed continuing so as to require supplemental

responses if you or your attorneys obtain further information between the time the answers are

served and the time of the trial.

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,

attached hereto as Exhibit A.

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

what is criminal trespass.

3. Produce all documents and tangible things that evidence your qualifications to determine

what is your property.

4. Produce all documents and tangible things that support your allegation that your mailbox

is situated on your property.

5. Produce all documents and tangible things that support your allegation that the right-of-

way, within which your mailbox is situated, is your property.

6. Produce all documents and tangible things that support your allegation that placing a

document within the right-of-way in front of your home is criminal trespass.

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

your home, is criminal trespass.

8. Produce all documents and tangible things that evidence your property interest in the

right-of-way in front of your home.

9. Produce all documents and tangible things that evidence your possessory interest in the

right-of-way in front of your home.

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Respectfully submitted September 11, 2006.

SAM HAN, P.C.


Sam S. Han, Ph.D.

Sam S. Han, Ph.D.


SAM HAN, P.C.
330 Bloombridge Way
Marietta, GA 30066
Phone: (404) 514 - 8237
email: sam.han.pc@gmail.com

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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

REQUEST FOR PRODUCTION OF DOCUMENTS TO NON-PARTY MARK CALHOUN by

first class mail to:

Mark Calhoun
2566 Lakefield Way
Marietta, Georgia 30064

and

Moore Ingram Johnson & Steele


192 Anderson Street
Marietta, Georgia 30060

Respectfully submitted September 11, 2006.

SAM HAN, P.C.


Sam S. Han, Ph.D.

Sam S. Han, Ph.D.


SAM HAN, P.C.
330 Bloombridge Way
Marietta, GA 30066
Phone: (404) 514 - 8237
email: sam.han.pc@gmail.com

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EXHIBIT
A

Defendants' Brief in Opposition to Plaintiff's Motion for


Summary Judgment and in Support of Defendants' Cross
Motion for Summary Judgment, with Hand-Written Note
from Mr. Mark Calhoun on the Back of the First Page,
Dated September 10, 2006