COMMONWEALTH OF MASSACHUSETTS

MIDDLESEX, ss.                         MALDEN DISTRICT COURT
                                  CIVIL ACTION NO. 9450CV872

__________________________________
                                  )
PHILIP GREENSPUN,                 )
Plaintiff,                        )
v.                                )  PLAINTIFF'S RESPONSE TO
                                  )  DEFENDANT'S REQUEST
SMYLY AUTOS, INC.                 )  FOR PRODUCTION OF
Defendant.                        )  DOCUMENTS
__________________________________)

1.  I have four Fujichrome Velvia slides of the hole in my
dashboard created by Smyly.   These were taken with a Yashica T4
camera and are stored in my filing cabinet in a hanging
polypropylene slide page.  Smyly is welcome to inspect these on
the light table in my house or to order copies from ZONA
Laboratory, 138 Rogers Street, Cambridge.  ZONA will make prints
from these slides for $30 each according to their latest price
list.  I do not have the equipment for making copies myself.

2.  I do not have any photographs of the premises of Smyly
Autos, Inc.

3.  As mentioned in paragraph 1, whatever photographic services
Smyly wishes to pay ZONA Laboratory for, Smyly will have my
cooperation in obtaining.

4.  I did not make any diagrams or drawings of Smyly Autos, Inc.

5.  I have not made any transcripts of statements by witnesses.

6.  I have no statements of other kinds.

7.  I have no statements of other kinds.

8.  I do not have a copy of the report I made to the Malden
Police.

9.  I repeat my answer to paragraph 8.

10.  I sent nothing to my insurance company regarding Smyly's
theft of my stereo.

11.  I have not decided what I am going to introduce at trial.

12.  I have no reports submitted by experts.

13.  I have already supplied Smyly with receipts for both the
stereo stolen by Smyly and the stereo purchased to replace it.

14.  I did not receive any documents upon leaving my vehicle at
Smyly.

15.  I have attached a copy of the repair bill for $33.28 from
April 15, 1994 that Smyly should already have in its possession.
I have also attached a copy of the rental car bill from
Enterprise for $63.30.

16.  I have never received any correspondence from Smyly.  The
only documents that I sent them that are relevant are my 93A
demand letter of April 19, 1994 and my followup FAX of April 23,
1994.  If Smyly has lost these documents, I would be happy to
print new copies from my computer system, but they will not be
signed photocopies of the original.

17.  I have already produced the repair order from Rich's Car
Tunes.

18.  I do not have any documents meeting this description.

19.  This is beyond the scope of permissible discovery.

20.  This is beyond the scope of permissible discovery.



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