IN THE COURT OF APPEALS OF GEORGIA CHRISTOPHER MOSES Plaintiff-Appellant, v. TRATON CORP., et al. Defendants-Appellees.
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Case Number A07A1474
Request for Oral Arguments and Certification of Service 17 April 2007 William L. Martin, III Clerk, Georgia Court of Appeals 47 Trinity Avenue Suite 501 Atlanta, GA 30334 Dear Mr. Martin: We hope that this letter finds you doing well. In accordance with Rule 28 of the Georgia Court of Appeals, Appellant hereby requests this Honorable Court for oral arguments on the above-captioned matter. This case is of paramount importance because the outcome of this case will affect the rights of every homeowner in Georgia. Oral argument should be granted in this appeal because the decision-making process will be significantly aided by oral arguments. The sole issue on appeal is whether the owner of the home (shown at right) has standing to sue for damages to the yard that is attached to his home (damaged yard also shown at right), when the owner has continuously maintained and cultivated the entire yard, and the condition of the entire yard affects the value of the home.
Court of Appeals Case Number A07A1474 17 April 2007 Page 2
This case hinges on the crucial but subtle legal distinction between possession and ownership. The presence of counsel to respond to questions by this Honorable Court, in distinguishing between possession and ownership, will significantly aid in the decision-making process. Appellant certifies that, on 29 March 2007, Appellant notified Appellees' counsel of Appellant's intent to argue this matter orally. Counsel for Appellees indicated, on 05 April 2007, that Appellees likewise intend to argue this matter orally. Both Appellant and Appellees request fifteen (15) minutes each for oral arguments. The undersigned attorney is scheduled to argue orally on behalf of Appellant. Appellant also certifies that this request has been properly served on counsel for Appellees. Sincerely,
Sam S. Han Georgia Bar Number 322284