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Despite Traton's ability to stop the continued ingress onto Mr.

Moses'
property by Traton's agents, Traton continued to approve of the
unauthorized entries. Traton never disciplined any of its agents for
entering onto Mr. Moses' property.38

38
Admitted by Defendant, Traton's First Admissions, ¶¶ 69 and 74.
Traton never disciplined any of its agents for tampering with evidence39
(i.e., running over a portion of Mr. Moses' property with a lawn mower).

39
Admitted by Defendant, Traton's First Admissions, ¶ 80.
Although Traton instructed its agents to enter onto Mr. Moses' property:40
(1) Traton does not assume responsibility for the actions of its employees.41
(2) Traton does not assume responsibility for the actions of its agents.42
(3) Traton does not assume responsibility for the actions of its
contractors.43 In fact, it appears that Traton refuses to accept responsibility
for anything.

40
See, Foster's First Admissions, ¶¶ 30 through 37.
41
Admitted by Defendant, Traton's First Admissions, ¶ 83.
42
Admitted by Defendant, Traton's First Admissions, ¶ 85.
43
Admitted by Defendant, Traton's First Admissions, ¶ 87.
Notwithstanding the numerous unauthorized entries onto Mr. Moses'
property by Traton's agents, Traton has never instructed its contractors to
refrain from driving over Mr. Moses' property.44

44
Admitted by Defendant, Traton's First Admissions, ¶ 96.
Rather than rationally discussing this matter and seeking prompt
resolution, Traton continues to press forth with this lawsuit, despite the
numerous opportunities that have been provided to Traton to resolve this
issue. In doing so, Traton has continued to stall and obstruct discovery.
For example, in responding to discovery requests, Traton has indicated that
it "lacks sufficient knowledge to admit or deny" who are its own corporate
officers.45 In other words, Traton's position, at one time, was that it did not
even know the identity of its own officers.

45
Admitted by Defendant, Plaintiff's Third Request for Admissions to Defendant Traton Corp., and Traton Corp.'s Responses and
Objections to Plaintiff's Third Request for Admissions (collectively "Traton's Third Admissions"), ¶¶ 2 through 12.
This is despite the fact that the officers for various Traton entities are listed
on the website for the Georgia Secretary of State,46 as well as on Traton
Corp.'s tax statements.47

46
Admitted by Defendant, Traton's Second Admissions, ¶¶ 104 through 109.
47
Tax Statements of Traton Corp. for 2005, Exhibit V.
Additionally, Traton's attorneys engaged in underhanded tactics, which
formed the bases of a grievance filed with the State Bar of Georgia.48

48
See, Memorandum of Grievance Against Jeffrey Daxe, filed with the Office of the General Counsel of the State Bar of Georgia,
March 1, 2006, Exhibit W. See, also, Rebuttal Memorandum: Grievance Against Jeffrey Daxe, filed with the State Bar of Georgia,
April 6, 2006, Exhibit X.
Other facts, which are relevant to the amount of damages and attorneys
fees, include revenue information that has been published by two (2)
independent sources,49 as well as the corporate tax statements of
Defendants.50

49
2005 Giants Results, housingzone.com, downloaded from <http://www.housingzone.com/>, November 25, 2005, and produced to
Defendants as MOS 0000131, Exhibit Y; Builder 100 Listing, BuilderOnline.com, downloaded from
<http://www.builderonline.com>, December 9, 2005, and produced to Defendants as MOS 0000144, Exhibit Z.
50
Tax Statements of Traton Corp. for 2005.