THE SUPERIOR COURT FOR THE COUNTY OF COBB STATE OF GEORGIA CHRISTOPHER MOSES Plaintiff, Civil Action File v, TRATON CORP., and No.05-1-8395-35 RICK FOSTER JURY TRIAL DEMANDED Defendants. PLAINTIFF'S SECOND REQUEST FOR ADMISSIONS TO DEFENDANT TRATON CORP. Plaintiff, Christopher L. Moses, by and through its undersigned attomeys hereby requests that Defendant Traton Corp. ("Traton") answer under oath the following SECOND REQUEST FOR ADMISSIONS, fully and in writing, within the time and in the manner provided and required by law. NOTEA: 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 attomeys, 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. NOTEB: As used herein, the terms "Traton Corp. ‘ou," or "your" are intended to and shall embrace and include Defendant Traton Corp. and all attomeys, accountants,agents, servants, employees, representatives, affiliates (including Poston Properties, Inc.) and private investigators of or employed by said Traton Corp., and all others who are in possession of or who may have obtained information for or on behalf of said Traton Corp. REQUEST FOR Al IISSIONS: 1. Admit that Traton Corp. is careful to not commingle its assets with the assets of other Traton entities 2, Admit that Traton Corp. is careful to maintain independence in corporate governance from other Traton entities. 3. Admit that Traton is careful to not mislead others. 4, Adinit that Traton is careful to not mislead others by publishing false information. 5. Admit that Traton is careful to ensure that its records are correct. 6. Admit that Traton is not careful to ensure that its records are correct. 7. Admit that Traton is careful to ensure that its records are accurate. 8 Admit that Traton is not careful to ensure that its records are accurate, 9. Admit that Traton is careful to ensure that its records are complete. 10. Admit that Traton is not careful to ensure that its records are complete. 11. Admit that Traton Corp., through its agent, appeared for a variance hearing before the Cobb County Government, specifically before the Board of Zoning Appeals, on April 13, 2005 (hereafter "April 15 Variance Hearing"). 12, Admit that Traton Corp. is the requestor of a variance at the April 15 Variance Hearing.13, Admit that a representative of Traton Corp. spoke on behalf of Traton Corp. at the April 15 Variance Hearing. 14, Admit that, during the April 15 Variance Hearing, Traton Corp. requested a variance for property in the Lakefield Manor subdivision, 15, Admit that video footage of the April 15 Variance Hearing is available on the Internet. 16, Admit that at the April 15 Variance Hearing, the representative of Traton Corp. used "Traton," "Traton Corp," and "Traton Homes" interchangeably. 17, Admit that the representative for Traton Corp. represented that Traton Corp. is involved in the deveiopment of homes in the Lakefield Manor subdivision. 18, Admit that the representative for Traton Corp. misrepresented that Traton Corp. is involved in the development of homes in the Lakefield Manor subdivision. 19, Admit that Traton Corp. is a developer of the Lakefield Manor subdivision 20. Admit that Poston Properties, Inc. is a developer of the Lakefield Manor subdivision, 21. Admit that contractors delivered materials to construction sites within the Lakefield Manor subdivision. 22. Admit that Traton has no standing to bring a lawsuit for damage to a right of way in the Lakefield Manor subdivision. 23. Admit that Mr. Moses complained to Traton about damage to a yard, 24. Admit that Mr. Moses complained to Traton about damage to his yard. 25. Admit that Ms. Rebecca Bryant, on behalf of the Lakefield Manor Homeowners