THE SUPERIOR COURT FOR THE COUNTY OF COBB STATE OF GEORGIA CHRISTOPHER MOSES Plaintiff, v. TRATON CORP., et al.

Defendants. ] ] ] ] ] ]

Civil Action File No.05-1-8395-35 JURY TRIAL DEMANDED

PLAINTIFF'S FIRST REQUEST FOR PRODUCTION OF DOCUMENTS TO NONPARTY 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 3

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-ofway, 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, v. TRATON CORP., et al. Defendants. ] ] ] ] ]

Civil Action File JURY TRIAL DEMANDED No.05-1-8395-35

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 6

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

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