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,		)
						)	REQUEST FOR
V.						)	DOCUMENTS
						)
BARRY KORT,					)
						)
			Defendant		)


                         Defendant's First Request for
                   Production of Documents from the Plaintiffs


Pursuant to Rule 34 of Massachusetts Rules of Civil Procedure, the
Defendant hereby requests that the Plaintiffs, Frederick Aufiero et al,
produce all of the documents described herein which are in their possession
or custody.


1.  Copies of all Requests for Determination and/or Applications to the
Bedford Planning Board, Bedford Code Enforcement Office, or Bedford
Conservation Commission seeking approvals for the construction of a golf
course upon Parcels "C" and "D", together with the Decisions of those
agencies.

2.  Copies of the Site Plan and Landscaping Plans for Parcels "C" and "D"
as prepared and submitted to the Town by Moore Homes, Moore-McAlpine, or
the Bedfordshire Condominium Association.

3.  Minutes of all Votes and Decisions of the Trustees discussing or
approving proposals to alter the Common Open Space and/or Conservation
Lands to construct, extend, or improve the Golf Course.

4.  Copies of all Contracts with landscapers for alteration  of the Common
Open Space or the Conservation Land for construction of the Golf Course.

5. An accounting of the source of funds for the above Contracts.

6.  To the extent that any of the above funds were raised privately, the
names of unit owners and amounts given to pay for construction of the Golf
Course.

7.  Copies of any written Agreements between the Trustees and Unit Owners
regarding the responsibility for continuing maintenance of privately funded
alterations to the Common Open Space.

8.  A record of all Votes of the Unit owners pursuant to the ByLaws and MGL
approving alterations to the Common Open Space for the construction of the
Golf Course or extensions and improvements.

9.  Copies of all correspondence between the Trustees and the Town
regarding the construction of the Golf Course, the use of the abutting
Town-owned lands, the drawing of water from the Shawsheen River, or issues
of compliance with the Massachussets Wetlands Protection Act and/or the
Bedford Conservation ByLaws.

10.  Copies of any and all documents which the Plaintiffs intend to use as
Exhibits in the trial of this matter.


						By the Defendant



						_____________________
						Barry Kort
						12 Mitchell Grant Way
						Bedford MA 01730-1200
						275-4468