Supplemental and Second Amended Complaint Exhibit R‘THE SUPERIOR COURT FOR THE COUNTY OF COBB STATE OF GEORGIA CHRISTOPHER MOSES. Plaintiff, Civil Action File v. TRATON CORP., RICK FOSTER, DALE BERCHER, WILLIAM POSTON, MILLBURN POSTON, NELLIE POSTON, CHRISTOPHER POSTON, CLIFF POSTON, SUSAN HECK, TAMMY CALHOUN, REBECCA BRYANT, and POSTON PROPERTIES, INC, No.05-1-8395-35 JURY TRIAL DEMANDED Defendants. SUPPLEMENTAL AND SECOND AMENDED COMPLAII Christopher Moses respectfully shows the honorable Court the following: U IC TIO! 1¢ Initial Tres 1. Traton (ce., Traton Corp. or its affiliates or agents or employees) has repeatedly caused damage to real property belonging to Christopher Moses (*M 2. Mr. Moses repeatedly requested that Traton cease damaging his property. 3. However, Traton flagrantly and purposefully disregarded Mr. Moses’ requests, and continued to damage Mr. Moses' property. 4, Traton has admitted that it has never attempted to fix the damage to Mr. Moses’property. 5. Inan attempt to amicably resolve this issue, Mr. Moses repeatedly contacted Traton. 6. However, Traton refused to respond to Mr. Moses’ communications. 7. Asaresult, Mr. Moses reported Traton to the Better Business Bureau ("BBB"). 8. Im response to Mr. Moses’ reporting Traton to the BBB, Traton responded through its attorneys. 9, * In that response, Traton expressly refused to fix the property that it damaged. 10, As such, Mr. Moses was forced to seck recourse through the Georgia Courts, 11, In filing the complaint, Mr, Moses sought to prevent Traton Corp. from continuing their trespass onto Mr. Moses’ property. ‘The Continuing Trespass 12. Unfortunately, despite Traton’s awareness of this pending litigation, Traton continued to flaunt its utter disregard for Mr. Moses' property rights. 13, Specifically, despite Mr. Moses’ repeated requests for Traton to stop entering onto his property, and despite the pending litigation against Traton Corp. for trespass, Traton continued its trespass onto Mr, Moses' property. 14, Astoundinly, Traton flaunted its gehts by taking pictures of its employee or agent standing on the damaged property. 15. Even more outrageoits than walking all over Mr. Moses’ yard to take pictures, Traton ran over the damaged portions of Mr. Moses’ yard with a lawn mower, in an effort to