<p> 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</p><p>6</p><p>7</p><p>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 )</p><p>15</p><p>16 PROPOUNDING PARTY: Defendant, Wida Fedaiy.</p><p>17 RESPONDING PARTY: Plaintiff, Martha Lopez</p><p>18 SET NUMBER: ONE</p><p>19 Plaintiff Martha Lopez responds to Defendant’s Demand for Production of Documents as</p><p>20 follows:</p><p>21 INTRODUCTORY STATEMENT</p><p>22 1. There are no documents identified in response to Interrogatory No. 9.2.</p><p>23 2. The SCLC obtained a written statement from Martha Garces 1885 California St., #9, </p><p>24 Mountain View, CA 94040, (650) 564-9476, regarding the Plaintiff’s employment by </p><p>25 Harris Hotdog and John Fedaiy. The statement was obtained by Severa Keith, of the </p><p>PLAINTIFFS’ RESPONSE TO DEFENDANTS’ FORM INTERROGATORIES</p><p>- 1 - 1 Stanford Community Law Clinic, 2117 University Avenue, East Palo Alto, CA 94303, </p><p>2 650-475-0560 on March 15, 2004. The original statement is located at SCLC. It is </p><p>3 entitled Declaration of Martha Garces in Support of Opposition to Motion to Set Aside </p><p>4 Default Judgment. </p><p>5 3. Plaintiff has one photograph of Martha Lopez working at Harris Hotdog. The photograph</p><p>6 was taken by Martha Lopez’ niece, Maribel Cortez. Maribel Cortez is presently residing </p><p>7 in Mexico. The original photograph is retained by Ms. Lopez. (Martha was supposed </p><p>8 to drop it off last week—left two messages for her…)</p><p>9 4. There are no documents identified in response to Interrogatory No. 12.5.</p><p>10 5. Plaintiff is not aware of any reports made concerning the Plaintiff’s employment by John </p><p>11 Fedaiy. Plaintiff is aware of reports that were generated during her employment by the </p><p>12 Santa Clara Public Health Department in relation to Harris Hotdog. Plaintiff believes </p><p>13 reports generated by Santa Clara Public Health Department were delivered to John </p><p>14 Fedaiy. Such reports have never been in the Plaintiff’s possession. </p><p>15 6. 1) A written report regarding surveillance conducted at Harris Hotdog was prepared. The</p><p>16 title of the report is Harris Hotdog Observation. The report was prepared on March 15, </p><p>17 2004 by Kaylan Lasky, a representative of the Stanford Community Law Clinic, 2117 </p><p>18 University Avenue, Suite A, East Palo Alto, CA 94303, 650.475.0560, on behalf of Ms. </p><p>19 Lopez. The original report is located at SCLC. The report was produced in preparation </p><p>20 for the Opposition to the Motion to Set Aside the Default Judgment. This report attorney </p><p>21 work product, and therefore, not discoverable.</p><p>22 2) A written report regarding the surveillance conducted at Fashion City was prepared by </p><p>23 representatives of SCLC. The report is entitled Declaration of Sarah Pappas in Support </p><p>24 of Opposition to Motion to Set Aside Default and Default Judgment. The report was </p><p>25 prepared on March 16, 2004 by Sarah Pappas, Stanford Community Law Clinic, 2117 </p><p>PLAINTIFFS’ RESPONSE TO DEFENDANTS’ FORM INTERROGATORIES</p><p>- 2 - 1 University Avenue, Suite A, East Palo Alto, CA 94303, 650.475.0560. The original </p><p>2 report is located at SCLC.</p><p>3 7. There are no documents identified in response to Interrogatory No. 50.1. Because all </p><p>4 contractual agreements between Ms. Lopez and Defendants were oral, there are no </p><p>5 documents representing the agreement or subsequent modifications to the agreement. </p><p>6 Because Ms. Lopez was paid in cash, there are no documents evidencing the oral </p><p>7 agreement and its subsequent modification.</p><p>8</p><p>9</p><p>10 Dated this 27th day of April 2004.</p><p>11 STANFORD COMMUNITY 12 LAW CLINIC 2117 University Avenue, 13 Suite A East Palo Alto, CA 94303 14 Margaret Stevenson</p><p>15</p><p>16</p><p>17</p><p>18</p><p>19</p><p>20</p><p>21</p><p>22</p><p>23</p><p>24</p><p>25</p><p>PLAINTIFFS’ RESPONSE TO DEFENDANTS’ FORM INTERROGATORIES</p><p>- 3 -</p>