COMMONWEALTH OF MASSACHUSETTS MIDDLESEX, SS. ****************************** PHILIP GREENSPUN, PLAINTIFF VS . SHYLY AUTOS, INC., DEFENDANT DISTRICT COURT DEPARTMENT MALDEN DIVISION CIVIL ACTION NO. 9450CV872 Defendant, Smyly Autos, Inc.'s Request for Production of Documents to the Plaintiff, Philip Greenspun The above named defendant, pursuant to Rule 34 of the Massachusetts Rules of Civil Procedure hereby requests that the above-named plaintiff produce the following items for inspection and copying: (Items are requested to be produced at the office of Neville & Kelley, Bulfinch Square, 43 Thorndike Street, Cambridge, MA 02141). The plaintiff may comply with this request by forwarding a copy of any documents or tangible things requested to counsel for the defendant postmarked prior to the date called for inspection. 1. Copies of any and all photographs setting forth or depicting the alleged damage sustained by the plaintiff's vehicle after the alleged theft. 2. Copies of any and all photographs of the premises of Smyly Autos, Inc. 3. Copies of any and all photographs which the plaintiff intends to offer into evidence at the time of trial. 4. Copies of any and all diagrams and/or drawings of the scene of the incident made by the plaintiff or subject to the plaintiff's control. 5. All printed or recorded (or reproduced by any other mechanical or electrical process) records, memoranda, notations, statements, copies of summaries or records of personal or telephone conversations or any other documents relating to the alleged theft or alleged damages which the plaintiff, his agents, servants, employees, or attorneys obtained from or as a result of interviewing all witnesses whomsoever purporting to have knowledge of the alleged theft or alleged damages. 6. Copies of all signed and or unsigned statements or statements recorded by mechanical or electric process made by the defendant, its agents, servants and/or employees, which are in the possession of the plaintiff or under his control and which relate directly or indirectly to this incident. 7. Copies of all signed and or unsigned statements or statements recorded by mechanical and or electronic means made by the plaintiff which are in the possession of the plaintiff or under his control and which relate directly or indirectly to this incident. 8. Copies of all reports made by the plaintiff to any police agency or any other governmental agency with regard to the facts of the alleged theft or alleged damages suffered as a result thereof. 9. True copies of all local police agencies reports with respect to this incident. 10. Copies of any and all applications, notice, proof of loss, reports, letters of correspondence sent or submitted by the plaintiff to any insurance company dealing with the alleged theft or alleged damages. 11. Copies of any and all documentary evidence which the plaintiff intends to offer at the time of trial. 12. Copies of any and all reports submitted by experts on this case. 13. Copies of any and all sales receipts, purchases agreements and any other documents evidencing plaintiff's purchase of the stereo that was allegedly stolen from the plaintiff's vehicle. 14. Copies of any and all estimates and any other documents received by the plaintiff upon leaving his vehicle Smyly Autos, Inc. 15. Copies of any and all repair bills received by the plaintiff from Smyly Autos, Inc. based on the repairs performed on his automobile. 16. Copies of any and all correspondence between the plaintiff and the defendant that is in any way relevant to this action. 17. Copies of any and all appraisals, estimates, repair bills, receipts, invoices or other documents evidencing the damages sustained by the plaintiff's automobile after the alleged theft and the costs of repairing said damages. 18. Employer(s) or school(s) confirmation or verification of time and earnings lost (or days missed from school) as a result of this accident. 19. Copies of plaintiff's federal income tax forms for the time period encompassing three years before the date of the accident up to and including the present year. 20. Copies of plaintiff's W-2 forms for the time period encompassing three years before the date of the accident. The demand is to include all after-acauired documents of the type made reference to in this request. The plaintiff is therefore requested to update the request by forwarding copies to the defendant or by putting the defendant on notice as to any newly acquired materials. By its attorney, Karl D. Drews, Esquire BBO # 561289 NEVILLE & KELLEY Bulfinch Square 43 Thorndike Street Cambridge, MA 02141 (617) 876-7100