Plaintiffs, in response to the Notice to Produce served in this matter, hereby say:

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1 ~be rlatu ffice of David Perry Davis 112 West Franklin Ave Pennington NJ (609) (609) (fax) Attorney ID: Attorney for plaintiffs Andreana Kavadas, Alisha Grabowski, LaQuay Dansby, Paulo Arede, individually and on behalf of all persons similarly situated, Plaintiffs vs. SUPERIOR COURT OF NEW JERSEY CHANCERY DIVISION - FAMILY PART MERCER COUNTY DOCKET NO. MER-L-I004-1S Civil Action Raymond P. Martinez, in his official capacity as Chief Administrator of the New Jersey Motor Vehicle Commission, and The New Jersey Motor Vehicle Commission, John Jay Hoffman, Esq., in his official capacity as Acting Attorney General of the State of New Jersey, and The State of New Jersey, PLAINTIFFS' RESPONSE TO DEFENDANTS' NOTICE TO PRODUCE Natasha Johnson, in her official capacity as Director of the Department of Human Services, Division of Family Development, Office of Child Support Services, and the Department of Human Services, Division of Family Development, Office of Child Support Services, Defendants Plaintiffs, in response to the Notice to Produce served in this matter, hereby say: 1. All documents identified in each plaintiff's answers to interrogatories in this action. Copies of plaintiffs' driving abstracts Kavadas - Andreana - MVC Abstract: KAV Dansby - LaQuay - Driver's Abstract Arede - Driver'S Abstract /1884 Grabowski - not suspended / not ordered

2 2. All documents that plaintiffs contend support any of the factual allegations of the verified complaint. Please see (1) documents previously supplied, including all attachments to the complaint and application for preliminary injunction, reply brief(s), sur-reply brief(s), motion for partial summary judgmen t. (2) documents provided herewith. Further responses, if any, shall be submitted prior to the hearing in accordance with court rule. 3. All documents that plaintiffs contend are in any way relevant to the issues in this action. This request is absurdly overbroad. Plaintiffs have previously supplied, or supply herewith, all documents that they anticipate could be submitted to the court or are otherwise responsive to this request. 4. All statements by persons relating to the claims, defenses or issues in this matter. Please see certifications, deposition transcripts, previously supplied, including all attachments to the complaint and application for preliminary injunction, reply brief(s), surreply brief(s), motion for partial summary judgment and attachments hereto. 5. Any and all documents which plaintiffs obtained from the Probation Division, the Administrative Office of the Courts, and any defendant which refer or relate in any way to the subject matter of this lawsuit. None beyond those provided to both parties from the Aoe and those provided to defendants by the DFD.

3 6. Any and all requests made pursuant to the Open Public Records Act (OPRA) or the common law right to access or right to know for documents related in any way to the subject matter of this lawsuit including but not limited to full copies of the exchange in Plaintiffs' Exhibit EI,G-1 and O. Note that this request includes but is not limited to information sought from the Administrative Office of the Courts, the judiciary, the Probation Division, the Motor Vehicle Commission, the Division of Family Development, the Office of Child Support Services pertaining to the subject matter of this lawsuit. Attached. Please see directory. 7. Any and all responses received pursuant to any request made as referenced in Request No. 6 including any documents provided to the plaintiffs. Attached. Please see directory. 8. Any and all responses and documents received pursuant to OPRA requests W95220 and C Attached. Please see directory. 9. Any and all Notices of Delinquency received by each plaintiff. There are no additional documents known beyond those defendants have supplied to plaintiff from the DFD and the documents received by all parties from the AOC. 10. Any and all Notices of Intent to Bench Warrant received by each plaintiff. There are no additional documents known beyond those defendants have supplied to plaintiff from the DFD and the documents received by all parties from the AOC.

4 11. Any and all documents related to the suspension of the plaintiff's driver's license. This request includes but is not limited to documents received from any defendant. There are no additional documents known beyond those supplied herewith, the documents defendants have supplied to plaintiff from the DFD and the documents received by all parties from the AOC. The only document received from any defendant would be abstracts and notices received from the MYC, which are attached. No abstract for plaintiff Grabowski was requested. 12. Any and all documents related to the reinstatement of the plaintiff's driver's license. There are no additional documents known beyond those supplied (abstracts), the documents defendants have supplied to plaintiff from the DFD and the documents received by all parties from the AOC. 13. Any and all summons issued to the plaintiff to appear for a child support related hearing. There are no additional documents known beyond the documents defendants have supplied to plaintiff from the DFD and the documents received by all parties from the AOC. 14. Any orders received by the plaintiff concerning a child support matter. There are no additional documents known beyond the documents defendants have supplied to plaintiff from the DFD and the documents received by all parties from the AOC. 15. A copy of each plaintiff's driver's license. Copies of driver's licenses: Grabowski KAV 1865 Dansby - LaQuay KAV 1879 Arede and Kavadas / to be supplied upon receipt

5 16. Copies of all documents related to each plaintiff's attempts to secure employment during the past five years including but not limited to employment and/or help wanted advertisements or announcements to which you responded including online job postings, all cover letters, letters of recommendation and all other application materials that you sent/submitted to all prospective employers including applications made online; all documents that you received from potential employers and/or persons and institutions to which you applied for employment or inquired about employment opportunities. All documents in possession have been attached. Please see directory. 17. Any and all documents submitted to the court, the Probation Division or any defendant in an attempt to prove indigency. Documents supplied: Determination by Social Security Administration that Paulo Arede qualifies for means-tested SS! benefits. Order from Hon. Catherine Fitzpatrick, PJFP appointing counsel for LaQuay Dansby as per Pasqua v. Council. Documents from the Board of Social Services approving LaQuay Dansby for food stamps. Document from East Brunswick Municipal Court appointing a public defender for LaQuay Dansby for charge of Driving While Revoked. Documents from the Board of Social Services approving LaQuay Dansby for food stamps.

6 Documents from the Board of Social Services approving Andreana Kavadas for food stamps. Public record: decision in DYFS v. A.K. indicating representation by the Public Defender's office. Certifications submitted in this matter asserting inability to pay. 18. Any and all documents submitted to the court, the Probation Division or any defendant in an attempt to prove that the plaintiff was unable to pay child support. See answers to number 17 above. 19. Any and all documents showing that plaintiff requested a hearing on indigency and/or ability to pay. Court orders finding Dansby and Arede indigent included. Appellate Decision reflecting appointment of counsel for Kavadas included. See also, AOC and DFD documents containing decisions on motions to modify support. 20. Any and all documents showing that plaintiff requested the appointment of counsel for a child support hearing. The Court is required to pro-actively inform all litigants as to their right to be represented by counsel at every hearing as per mandate of Pasqua v. Council, to inquire into indigence, and to appoint counsel. It is therefore irrelevant whether any plaintiff asked. Without waiving this objection, see response to #19.

7 21. Any and all documents which form the basis of any allegations asserted in plaintiffs' verified complaint or any briefs filed by plaintiffs including but not limited to any documents used to calculate all percentages set forth in plaintiffs' briefs. This demand is incomprehensibly vague. All the documents submitted herewith (2101 pages), all the documents attached to previous pleadings from both parties, all publicly available studies referenced by either party, all documents received by both parties from the Aoe and DFD.

8 CER'I'IFICATION I' hereby certify that I have reviewed the document production request and that I have made or caused to be made a good faith search for documents responsive to the request. I further certify that as of this date, to the best of my knowledge and information, the production is complete and a.ccurate based on my personal knowledge and/or information provided by others. I acknowl.edqe my continuing obligation to make a good faith effort to identify additional documents that are responsive to' the request and to promptly serve a supplemental written response and production of such documentsi as appropriate, as I become aware of them. The following is a list of the identity and source of knowledge;lof those who provided information to me: I certify that the foregoing statements by me are true. I understand that if any of the forgoing statements is willfully false l 'I may be subject to punishment. DATED: 9jJ5,/ts ~~~ ANDREANA I~VADAS 3.0 '

9 CERTIFICATION I hereby certify that I have reviewed the document production request and that I have made or caused to be made a good faith search for documents responsive to the request. I further certify that as of this date, to the best of my knowledge and Lnforma.t.Lon, the production is complete and accurate based on my personal knowledge and/or information provided by others. I acknowledge my continuing igation to make a good faith effort to identify additional documents that are responsive to the request and to promptly serve a supplemental written response and production of such documents, as appropriate, as I become aware of them. The following is a list of the identity and source of knowledge of those who provided information to me: I certify that the foregoing statements Joy me are true. I understand that if any of the forgoing statements is willfully false, I may be subject to punishment. DATED, ~tjid ALISHA WAGNER A/KI A ALISHA GRABOWSKI 11

10 l,,',. CERTIFICATION I hereby certify that I have reviewed the document production request and that I have made or caused to be made a good faith search for documents responsive to the request. I further certify that as of this date, to the best of my knowledge and information, the production is. oomplet.e ' and accurate based on my personal knowledge and/or information provided by others.. I acknowledge my continuing obligation to make a good faith effort to identify additional documents that are responsive to the request and to supplemental written response and production as appropriate, as I become aware of them. promptly serve a of such documents, The following is a list of the identity and source of knowledge of those who provided information to me: I certi fy that the foregoing statements by me are true. I understand that if any of the forgoing statements is willfully false, I may be subject. to punishment. PATED: i:kp+8s]cojy LA'CL~ LAQUAYD_ ~ 13

11 CERTIFICATION I hereby certify that I have reviewed the document production request and that I have made or caused to be made a good faith search for documents responsive to the request. I further certify that as of this date, to the best of my knowled;;re and information, the production is complete and accurate based on my personal knowledge and/or information provided by others. I acknowledge my continuing obligation to make a good faith effort to identify additional documents that az'e responsi ve to the request: and to promptly,serve a supplemental written response and production of such documents, as appropriate I as, I become aware of them. The following is a list of the identity and source of knowledge of those who provided information to me: I certify that the foregoing statements by me are true. I understand that if any of the forgoing statements is willfully false, I may be subject to punishment. DATED: -:J/-JB//Q ~ ,~- ----,-,----".,

12 ---- Kavadis v. Martinez Notice to Produce document production directory Document file online: (PDF Password KAV123) Document Page Open Public Records Act response requests previous civil rights suits, briefs and pleadings / Stianchi appellate brief - appellant Open Public Records Act response requests previous civil rights suits, briefs and pleadings / Stianchi appellate brief - respondent Open Public Records Act response requests previous civil rights suits, briefs and pleadings / Lerro appellate brief - respondent Automated tracking - Family Part - Arede s to/from AOC and DFD, DOL and counsel for plaintiffs / Beacham s to/from AOC and DFD, DOL, DOL and counsel for plaintiffs / Wilson Open Public Records Act response requests previous civil rights suits, briefs and pleadings / Lerro appellate brief-appellant Open Public Records Act Request C Open Public Records Act Request C99880 and receipt s to/from Somerset Probation and counsel for 325 plaintiffs (Dudas) Automated tracking - Family Part - Kavadas Correspondence from AOC ( attachment) / 328 (Dietrich) Open Public Records Act response requests previous civil rights suits, briefs and pleadings Open Public Records Act response requests previous civil rights suits, Baals opposition brief Open Public Records Act response requests previous civil rights suits, Baals appellant Open Public Records Act response requests previous civil rights suits, Baals brief respondent

13 Open Public Records Act response requests previous civil rights suits, Baals appendix Open Public Records Act rights notice 432 s to/from DHHS / OCSE and counsel for plaintiffs / Putze s to/from AOC and counsel for plaintiffs / 435 Dewan Open Public Records Act response requests previous civil rights suits, briefs and pleadings / Stianchi App Div Brief/Appendix defendant Open Public Records Act response requests I previous civil rights suits, briefs and pleadings / Stianchi Complaint/jury demand Correspondence Deputy Attorney General regarding suit s to/from court / Dupraz Ability to Comply orders Potential Plaintiff not used / Danese Potential Plaintiff not used / Quattrone Potential Plaintiff not used / Ciser Supreme Court Order / Arede 520 Payment status print-out / Arede Fax from Epting 523 Correspondence / Deputy Attorney General and Court protective order Application to modify court order (hand-written / submitted copy) / Kavadas / Remove from bench warrant status Correspondence to/from Deputy Attorney General RE 562 Discovery s to/from AOC and DFD, DOL and counsel for plaintiffs Motor Vehicle Commission Fairness and Affordability Study Correspondence to Motor Vehicle Commission (pre-suit) NJ Report to Legislature s to/from Deputy Attorney General s to/from Judge Grant

14 Open Public Records Act Request W s to/from Deputy Attorney General Cooperative Agreement between AOC and DFD, DOL FFY Characteristics of Families Served by the Child Support (IV-D) Program: 2010 Census Survey Results s to/from Deputy Attorney General / AOC s to/from Motor Vehicle Commission and DFD, DOL Open Public Records Act officers Correspondence Deputy Attorney General Transcript of oral argument July 22, Automated tracking - Family Part - Kavadas Kavadas / computer (summary) version of motion Certification portion from Dansby / omitted from 1157 OSC printer's error Correspondence to Deputy Attorney General 1158 Attachments to to Bruno / Howard on discrepancy in DL suspension s with potential plaintiffs not used Correspondence from Judge Grant NJ Report to Legislature 2008/ to/from Lisa Semel s from AOC Open Public Records Act response requests previous civil rights suits, briefs and pleadings Lerro Certification of Service Lerro motion for dismissal Lerro order granting dismissal Lerro brief-defendant Lerro Complaint/jury demand Directive # Open Public Records Act response requests previous civil rights suits, briefs and pleadings Stianchi trial court / Opposition Brief

15 NJ Driver's License Study / FINAL REPORT / August Sample case list to Gina Goldstein - seeking ELR 1362 hearing schedules Orders from potential plaintiffs not used - not good enough Federal Register / Dept Health Human Services from counsel for other cases s Patricia Risch / Vicki Turetsky Open Public Records Act response requests previous civil rights suits, briefs and pleadings Open Public Records Act response requests previous civil rights suits, briefs and pleadings - Baals trial court / Motion for leave to file amended complaint Open Public Records Act response requests previous civil rights suits, briefs and pleadings - Baals trial court / Certification Open Public Records Act response requests previous civil rights suits, briefs and pleadings - Baals trial court / Complaint Open Public Records Act response requests previous civil rights suits, briefs and pleadings - Baals Appellate Amended Complaint Open Public Records Act response requests previous civil rights suits, briefs and pleadings - Baals Appellant's Brief Open Public Records Act response requests previous civil rights suits, briefs and pleadings - (Stianchi Deputy Attorney General submission) Open Public Records Act response requests previous civil rights suits, briefs and pleadings - Lerro order Open Public Records Act response requests previous civil rights suits, briefs and pleadings Open Public Records Act requests previous civil rights suits, briefs and pleadings NJ Report to Legislature Memo from AOC on Directive # s to/from Deputy Attorney General s to court RE Kavadas file

16 s to/from AOC Open Public Records Act Request W Automated tracking - Family Part - Grabowski s to/from Deputy Attorney General Automated tracking - Family Part - Grabowski 1650 Open Public Records Act response requests previous civil rights suits, briefs and pleadings Open Public Records Act Request W94931 (Stianchi opp to motion to dismiss) Kavadas - Andreana - Motor Vehicle Commission Abstract: Kavadas - Andreana - Lease Kavadas - Andreana - Safelink Certification 1679 Kavadas - Andreana - Cape May County Technical 1680 School District Kavadas - Andreana - Inmate admission - Cumberland 1681 County Kavadas - Andreana - Two week warrant status (William Gerry) Kavadas - Andreana - Employment application Kavadas - Andreana - Employment application Kavadas - Andreana - Emergency Room Admission 1693 Kavadas - Andreana - Drug Test result (neg) 1694 Kavadas - Andreana - Career Center ID & Form Kavadas - Andreana - Employment application 1701 Kavadas - Andreana - Employment notes Kavadas - Andreana - Board of Social Services approval Kavadas - Andreana - Suspended driving ticket (Millville) Kavadas - Andreana - Motion for visitation 1713 Kavadas - Andreana - Employment application NJ Transit Kavadas - Andreana - Inmate receipt - Cumberland I County Kavadas - Andreana - Paystubs

17 Kavadas - Andreana - Social Security Earnings Statement (thru 2014) Kavadas - Andreana - Suspended driving summonses Kavadas - Andreana - Verification of court attendance Dansby - LaQuay - Driver's Abstract Arede - Driver's Abstract Arede, Paulo - Medication bottles (Escitalopram 1776 Gabapentin Venlafaxine) Open Public Records Act Request C (Race / suspensions) and summary Kavadas - Andreana - Motor Vehicle Commission child support suspension notices Kavadas - Andreana - Summary / warrant suspension history Kavadas - Andreana - Suspended driving ticket (Folsom) Kavadas - Andreana - Inmate receipt - Cumberland 1811 County Kavadas - Andreana - Paystubs Correspondence (pre-suit) to Commissioner Martinez Arede Deposition / order (two years before indigence finding) Arede Deposition / abstract summary Dansby - LaQuay Deposition documents Arede - SSI determination and correspondence Arede - Suspension notices Motor Vehicle Commission Arede - Two week warrant status order Arede - Correspondence from 2008 attorney 1864 Grabowski - copy of license 1865 Dansby - LaQuay Employment applications / list Dansby - LaQuay Board of Social Services / Food 1876 Stamp approval Dansby - LaQuay Employment applications / list Dansby - LaQuay - copy of license 1879 Dansby - LaQuay Employment applications / list

18 Arede - Abstract summary 1884 Arede - Prescriptions for medications 1885 Kavadas - Andreana Appellate Decision - DYFS v. AK / A T1 Kavadas - Andreana "Petition to Speak with 1908 Representative" I Arede - Order (hand written / not in file from I AOC/DFD I Arede - Letter from East Orange Hospital with 1919 psychiatric diagnoses Arede - Consent Order (not in file from AOC/DFD) I waive arrears for sole custody i Office of Child Support Enforcement Preliminary I Report FY 2014 I NJ Institute Social Justice Fact Sheet on DL 2055 suspensions Motor Vehicle Commission chart (was attachment) on restorations NJ Institute Social Justice Roadblock on the Way to Work / Suspension as a Barrier to Employment Kavadas - Andreana - Suspended driving and companion tickets disposition (Wildwood) Arede - Summary / warrant suspension history Dansby - Summary / warrant suspension history Summary: CS collection rate by state 2101 I -