Claire Mccormack (Certified Law Student No

Claire McCormack (Certified Law Student No. 14205) 1 David Sapp (Certified Law Student No. 13781) Craig Largent (Certified Law Student No. 12860) 2 Margaret Stevenson (State Bar No. 112982) Severa Keith (State Bar No. 218167) 3 Peter Reid (State Bar No.045808) 4 STANFORD COMMUNITY LAW CLINIC 2117 University Avenue, Suite A 5 East Palo Alto, CA 94303

8 ) Case No. 1-03-000895: 9 MARTHA LOPEZ, ) ) RESPONSE TO DEMAND FOR 10 Plaintiff, ) PRODUCTION OF DOCUMETNS ) 11 vs. ) HARRIS HOTDOG, WIDA FEDAIY, an ) 12 individual, JOHN FEDAIY, an individual, and ) DOES 1-10, inclusive, ) 13 ) Defendant ) 14 )

16 PROPOUNDING PARTY: Defendant, Wida Fedaiy.

17 RESPONDING PARTY: Plaintiff, Martha Lopez

18 SET NUMBER: ONE

19 Plaintiff Martha Lopez responds to Defendant’s Demand for Production of Documents as

20 follows:

21 INTRODUCTORY STATEMENT

22 1. There are no documents identified in response to Interrogatory No. 9.2.

23 2. The SCLC obtained a written statement from Martha Garces 1885 California St., #9,

24 Mountain View, CA 94040, (650) 564-9476, regarding the Plaintiff’s employment by

25 Harris Hotdog and John Fedaiy. The statement was obtained by Severa Keith, of the

PLAINTIFFS’ RESPONSE TO DEFENDANTS’ FORM INTERROGATORIES

- 1 - 1 Stanford Community Law Clinic, 2117 University Avenue, East Palo Alto, CA 94303,

2 650-475-0560 on March 15, 2004. The original statement is located at SCLC. It is

3 entitled Declaration of Martha Garces in Support of Opposition to Motion to Set Aside

4 Default Judgment.

5 3. Plaintiff has one photograph of Martha Lopez working at Harris Hotdog. The photograph

6 was taken by Martha Lopez’ niece, Maribel Cortez. Maribel Cortez is presently residing

7 in Mexico. The original photograph is retained by Ms. Lopez. (Martha was supposed

8 to drop it off last week—left two messages for her…)

9 4. There are no documents identified in response to Interrogatory No. 12.5.

10 5. Plaintiff is not aware of any reports made concerning the Plaintiff’s employment by John

11 Fedaiy. Plaintiff is aware of reports that were generated during her employment by the

12 Santa Clara Public Health Department in relation to Harris Hotdog. Plaintiff believes

13 reports generated by Santa Clara Public Health Department were delivered to John

14 Fedaiy. Such reports have never been in the Plaintiff’s possession.

15 6. 1) A written report regarding surveillance conducted at Harris Hotdog was prepared. The

16 title of the report is Harris Hotdog Observation. The report was prepared on March 15,

17 2004 by Kaylan Lasky, a representative of the Stanford Community Law Clinic, 2117

18 University Avenue, Suite A, East Palo Alto, CA 94303, 650.475.0560, on behalf of Ms.

19 Lopez. The original report is located at SCLC. The report was produced in preparation

20 for the Opposition to the Motion to Set Aside the Default Judgment. This report attorney

21 work product, and therefore, not discoverable.

22 2) A written report regarding the surveillance conducted at Fashion City was prepared by

23 representatives of SCLC. The report is entitled Declaration of Sarah Pappas in Support

24 of Opposition to Motion to Set Aside Default and Default Judgment. The report was

25 prepared on March 16, 2004 by Sarah Pappas, Stanford Community Law Clinic, 2117

- 2 - 1 University Avenue, Suite A, East Palo Alto, CA 94303, 650.475.0560. The original

2 report is located at SCLC.

3 7. There are no documents identified in response to Interrogatory No. 50.1. Because all

4 contractual agreements between Ms. Lopez and Defendants were oral, there are no

5 documents representing the agreement or subsequent modifications to the agreement.

6 Because Ms. Lopez was paid in cash, there are no documents evidencing the oral

7 agreement and its subsequent modification.

10 Dated this 27th day of April 2004.

11 STANFORD COMMUNITY 12 LAW CLINIC 2117 University Avenue, 13 Suite A East Palo Alto, CA 94303 14 Margaret Stevenson