COMMONWEALTH OF MASSACHUSETTS MIDDLESEX, ss. MALDEN DISTRICT COURT CIVIL ACTION NO. 9450CV872 __________________________________ ) PHILIP GREENSPUN, ) Plaintiff, ) v. ) PLAINTIFF'S FIRST SET OF ) DOCUMENT REQUESTS TO SMYLY AUTOS, INC. ) DEFENDANT Defendant. ) __________________________________) Philip Greenspun ("Greenspun") pursuant to the provisions of Rule 34 of the Massachusetts Rules of Civil Procedure, requests that the documents listed below be produced by Smyly Autos, Inc. ("Smyly"). 1. Any documents relating to who was physically on Smyly's premises between 10 a.m. on April 13, 1994 and noon on April 15, 1994, including time sheets, lists of employees, records from the customer service order database, etc. 2. Any drawings, photographs, maps, or blueprints of Smyly's premises. 3. Any documents of any kind relating to Smyly's security procedures, including instructions for security guards, instructions to employees, specifications and instructions for any alarm systems, and protocols for interactions among employees. 4. Any documents relating to alleged criminal activity or lack of integrity on the part of Smyly, its employees, or its agents, including but not limited to letters from customers, letters from Chrysler, letters from employees, complaints filed against Smyly in Massachusetts and other courts, judgments of Massachusetts and other courts, criminal convictions of employees, etc. 5. Any documents relating to this incident or Philip Greenspun that are not covered by the attorney-client privilege, including but not limited to letters, other correspondence, service records, service orders estimates, internal memoranda, electronic mail, and phone messages. 6. Copies of any and all reports submitted by experts on this case. 7. Copies of all printed or recorded statements of witnesses to the incidents described in my Complaint. The demand is to include all after-acquired documents of the type made reference to in this request. The defendant is therefore requested to update the request by forwarding copies to the plaintiff or by putting the plaintiff on notice as to any newly acquired materials. Philip G. Greenspun 55 Russell Street Melrose, MA 02176 (617) 662-8735 Dated: November 1, 1994 CERTIFICATE OF SERVICE I hereby certify that I have served the above document upon all other counsel of record by facsimile transmission, on November 1, 1994, and that the above document was served within the time limits set forth in Standing Order 1-88. Philip G. Greenspun 55 Russell Street Melrose, MA 02176 (617) 662-8735