Claire McCormack (Certified Law Student No. 14205)

David Sapp (Certified Law Student No. 13781)

Craig Largent (Certified Law Student No. 12860)

Margaret Stevenson (State Bar No. 112982)

Severa Keith (State Bar No. 218167)

Peter Reid (State Bar No.045808)

STANFORD COMMUNITY LAW CLINIC

2117 University Avenue, Suite A

East Palo Alto, CA 94303

(650) 475-0560

(650) 326-4162 (facsimile)

Attorneys for Plaintiff

SUPERIOR COURT OF CALIFORNIA, COUNTY OF SANTA CLARA

MARTHA LOPEZ,
Plaintiff,
vs.
HARRIS HOTDOG, WIDA FEDAIY, an individual, JOHN FEDAIY, an individual, and DOES 1-10, inclusive,
Defendants / )
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RESPONSE TO DEMAND FOR PRODUCTION OF DOCUMETNS

PROPOUNDING PARTY: Defendant, Wida Fedaiy.

RESPONDING PARTY: Plaintiff, Martha Lopez

SET NUMBER:ONE

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

  1. There are no documents identified in response to Interrogatory No. 9.2.
  2. TheSCLC obtained a written statement from Martha Garces1885 California St., #9, Mountain View, CA 94040, (650) 564-9476, regarding the Plaintiff’s employment by Harris Hotdog and John Fedaiy. The statement was obtained by Severa Keith, of the Stanford Community Law Clinic, 2117 University Avenue, East Palo Alto, CA94303, 650-475-0560 on March 15, 2004. The original statement is located at SCLC.
  3. Plaintiff has one photograph of Martha Lopez working at Harris Hotdog. The photograph was taken by Martha Lopez’ niece, Maribel Cortez. Maribel Cortez is presently residing in Mexico. Plaintiff has made reasonable efforts to locate this photograph recently, but has been unable to find it. Plaintiff will provide it in the future if she is able to find it.
  4. There are no documents identified in response to Interrogatory No. 12.5.
  5. Plaintiff is not aware of any reports made concerning the Plaintiff’s employment by John Fedaiy. Plaintiff is aware of reports that were generated during her employment by the Santa Clara Public Health Department in relation to Harris Hotdog. Plaintiff believes reports generated by Santa Clara Public Health Department were delivered to John Fedaiy. The originals of such reports have never been in the Plaintiff’s possession.
  6. 1) A written report regarding surveillance conducted at Harris Hotdog was prepared. The title of the report is Harris Hotdog Observation. The report was prepared on March 15, 2004 by Kaylan Lasky, a representative of the Stanford Community Law Clinic, 2117 University Avenue, Suite A, East Palo Alto, CA 94303, 650.475.0560, on behalf of Ms. Lopez. The original report is located at SCLC. The report was produced in preparation for the Opposition to the Motion to Set Aside the Default Judgment. This report attorney work product, and therefore, is not discoverable.

2) A written report regarding the surveillance conducted at FashionCity was prepared by representatives of SCLC. The report is entitled Declaration of Sarah Pappas in Support of Opposition to Motion to Set Aside Default and Default Judgment. The report was prepared on March 16, 2004by Sarah Pappas, Stanford Community Law Clinic, 2117 University Avenue, Suite A, East Palo Alto, CA 94303, 650.475.0560. The original report is located at SCLC and was included in the Opposition to the Motion to Set Aside Default Judgment.

  1. There are no documents identified in response to Interrogatory No. 50.1. Because all contractual agreements between Ms. Lopez and Defendants were oral, there are no documents representing the agreement or subsequent modifications to the agreement. Because Ms. Lopez was paid in cash, there are no documents evidencing the oral agreement and its subsequent modification.

DATE: ______, 2004STANFORD COMMUNITY LAW CLINIC

By:

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Claire McCormack

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Margaret Stevenson

PLAINTIFFS’ RESPONSE TO DEFENDANTS’ FORM INTERROGATORIES

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