COMMONWEALTH OF MASSACHUSETTS MIDDLESEX, ss. SUPERIOR COURT DEPARTMENT CIVIL ACTION NO. 95-4563 FREDERICK AUFIERO, FREDERICK ) BIRD, GORDON JAMESON, DONALD ) KREBS, RICHARD MAZOW, HOWARD ) RUBINSTEIN AND JOHN M. ) UPDEGRAPH, JR., AS TRUSTEES OF ) BEDFORDSHIRE CONDOMINIUM TRUST, ) ) Plaintiff, ) ) V. ) ) BARRY KORT, ) ) Defendant ) Trustees of Bedfordshire Condominium's Response to the Defendant's Request for Production of Documents 1. Objection, this request is not relevant to the subject matter involved in the pending action and is not reasonably calculated to lead to the discovery of admissible evidence. Without waiver of such objection the Trustees state they do not have the requested documents in their possession. 2. Objection, this request is not relevant to the subject matter involved in the pending action and is not reasonably calculated to lead to the discovery of admissible evidence. Without waiver of such objection the Trustees state they do not have the requested documents in their possession. 3. Objection, this request is not relevant to the subject matter involved in the pending action and is not reasonably calculated to lead to the discovery of admissible evidence. Without waiver of such objection the Trustees state all minutes of Trustees meetings are available to all unit owners upon request. If the defendant provides specific dates of such meetings, they Trustees will produce the minutes of the meetings if any exist. 4. Objection, this request is not relevant to the subject matter involved in the pending action and is not reasonably calculated to lead to the discovery of admissible evidence. Without waiver of such objection the Trustees state there are no such documents. 5. Objection, this request is not relevant to the subject matter involved in the pending action and is not reasonably calculated to lead to the discovery of admissible evidence. 6. Objection, this request is not relevant to the subject matter involved in the pending action and is not reasonably calculated to lead to the discovery of admissible evidence. 7. Objection, this request is not relevant to the subject matter involved in the pending action and is not reasonably calculated to lead to the discovery of admissible evidence. Without waiver of such objection the Trustees state there are no such documents. 8. Objection, this request is not relevant to the subject matter involved in the pending action and is not reasonably calculated to lead to the discovery of admissible evidence. Without waiver of such objection the Trustees state the minutes of the Annual Meetings will be produced. 9. Objection, this request is not relevant to the subject matter involved in the pending action and is not reasonably calculated to lead to the discovery of admissible evidence. 10. These documents will be produced. Trustees, Bedfordshire Condominium Trust By Their Attorney Michael W. Merrill, Esq. Merrill & McGeary One Beacon Street, Suite 1120 Boston, MA 02108 (617) 523-1760