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 Interrogatories Propounded
        Documents to the Plaintiff, Philip Greenspun


1.  Please state your full name, date of birth, residential
address, business address, social security number, and occupation
at the time of the alleged accident.

2.  Please set forth, based upon you own personal knowledge, a
complete and detailed account of all facts upon which you base the
allegations contained in your complaint.

3.  Please set forth any additional facts not recited in your
answer to interrogatory number 2 above upon which you base your
complaint. Please state the source (i.e. name of witness, document,
etc.) of the facts you provide.

4.  Please state with regard to the stereo in the plaintiff's
automobile that was left to be repaired by Smyly Autos, Inc. the
following:

     a.  The year, make and model of said stereo;
     
     b.  The serial number at the time of the alleged theft;
     
     c.  The date said stereo was purchased by the plaintiff; and
     
     d.  The price that was paid for said stereo by the plaintiff.

5.  Please state when the plaintiff's automobile was left at Smyly
Auto, Inc.

6.  Please state why the plaintiff's automobile was left at
Smyly Auto, Inc. specifically stating complaints the
plaintiff had regarding said automobile.

7.  Please state whether an estimate of the cost of repairing
said automobile was given at the time the plaintiff left his
automobile at Smyly Auto, Inc., and if so, please state:

     a.  What repairs were to be made; and
     
     b.  The total cost of said repairs.

8.  Please state the amount of the total repair bill after
the repairs were completed on the plaintiff's automobile.

9.   Please  state whether the plaintiff has paid the  repair
bill, and if so, the date of such payment.

10. If  the  repair bill has not been paid, please state  why
     not.

11. Please  state  when the plaintiff was notified  that  the
     repairs on said automobile had been completed.

12. Please  state  how many sets of keys there  were  to  the
     plaintiff's vehicle at the time of the alleged theft and
     who had custody of each set.

13. Please  state when the plaintiff first learned  that  his
     stereo was missing and how he learned it was missing.

14. Please  state  whether  the plaintiff  notified  any  law
     enforcement agency that the stereo was missing.

15. If  the  preceding  interrogatory  was  answered  in  the
     affirmative,  please state what law  enforcement  agency
     was informed and the date that the notice was given.

16. Please state the name and address of the company, if any,
     that  provided  automobile insurance  to  the  plaintiff
     covering the plaintiff's automobile at the time  of  the
     alleged theft.

17. Please state whether a claim was made with said insurance
     company,  and if so, please state the date  that  notice
     was first given and the claim number of said claim.

18.   If  the  preceding interrogatory was  answered  in  the
affirmative, please state whether said insurance company paid
said  claim, and if so, please state the amount paid by  said
insurance company, and the amount of the deductible  paid  by
the plaintiff, if any.

19. With  regard  to the plaintiff's automobile, please  give
     the following:

     a. A detailed account of all the damage sustained to said
          automobile as a result of the alleged
     
     b. An itemized account of the cost of all repairs to said
          automobile as a result of the alleged theft; and

     c. The name and address of the person or business that made
          said repairs.

20. Please state whether the plaintiff's stereo was recovered, and
     if so, when it was found, where it was found, and the name
     and address of the person who found it.

21. Please set forth the names and addresses of each witness to
     the events set forth in your complaint (including your
     alleged damages) and with regard to each, please state:

     a. A complete description of what each witnessed; and

     b. Whether or not you or your attorney have obtained a
          statement from the witness.

22. With regard to each and every expert you intend to call at
     the time of trial, please state:

     a. Name and address;

     b. Area of expertise;

     c. The subject matter upon which each is expected to
          testify;

     d. The substance of the facts and opinions to which each
          expert is to testify; and

     e. A summary of the grounds for each such opinion.

23. Please state whether anyone was arrested for the theft of the
     plaintiff's stereo, and if so, please state:

     a. The name and address of the person arrested;

     b. The court in which said person was prosecuted; and

     c. The results of said prosecution.

24. If you have suffered financial loss as a result of the alleged
     incident, please state in what amount. In answering this
     interrogatory, itemize as far as possible, bills, expenses,
     and loss in wages, salary or business.

25. If you missed work as a result of the alleged incident, please
     state:

     a. The dates which you missed.
     
     b.  The name and address of your employer at the time of
          the alleged incident; and
     
     c.   The average amount of your weekly salary or wages;
     
     d.   The name and address of your present employer.

By its attorney,

Karl D. Drews, Esquire
BBO # 561289
NEVILLE & RELLEY
Bulfinch Square
43 Thorndike Street
Cambridge, MA 02141
(617) 876-7100