3 Affidavits to Cty AttorneyIii
1
O M. COHEN
SsOC FATES
RNEYS AT LAW
ELARD TOWER
PARK, MINNESOTA
s•e -esoo
STATE OF MINNESOTA IN DISTRICT COURT
COUNTY OF HENNEPIN FOURTH JUDICIAL DISTRICT
Golden Key Health Club, Inc.,
a Minnesota corporation,
vs.
Plaintiff,
William P. Craig, City
Manager for Hopkins, Minnesota,
and the City of Hopkins,
Defendants.
STATE OF MINNESOTA)
)SS.
COUNTY OF HENNEPIN)
SYLVIA CONTRERAS, being first duly sworn upon oath,
deposes and states as follows:
1. That the affiant resides at 2742 Hennepin Avenue
South, Apartment 103, Minneapolis, Minnesota.
2. That the affiant is employed by the Golden Key
Health Club, and has been since August 8, 1980, and is employed
on a part -time basis as a masseuse.
3. That the affiant has knowledge that between 3:00
p.m. and 5:00 p.m., on August 8, 1980, the affiant was
interviewed by Mr. Melvin Dart, the owner of the Golden Key
Health Club.
4. That the affiant also has knowledge that when she
was interviewed by Mr. Dart, that he accepted her application
for employment, and that Mr. Dart called in her name to the
City of Hopkins.
5. That the affiant knows that when Mr. Dart called
in her name to the City of Hopkins, that he asked for a
certain lady with the City of Hopkins, he spoke to her, that
he gave this lady her name, her address, and her birth date,
and he ended his conversation with the words, "Okay, good
bye."
AFFIDAVIT
1
COHEN
IATES
YS AT LAW
ARD TOWER
K, MINNESOTA
6900
6. That after rlr. Dart called in affiant's name, he
told affiant the rules and regulations regarding operation
of the Golden Key Health Club, and that all rules and regulations
were complied with by the affiant.
7. That the affiant has knowledge that her name was
one that was reported into the City of Hopkins, and that she
has knowledge that her name was called in by Mr. Dart.
FURTHER YOUR AFFIANT SAYETH NOT.
S LV CONTRERAS
Subscribed and sworn to before me
this 15th day of January, 1981.
4„,'/ 3
Notary Public
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4 r,. M. COHEN
A SSOCIATES
ATTORNEYS AT LAW
1390 SHELARO TOWER
LOUIS PARK, MINNESOTA
346 -6300
STATE OF MINNESOTA
COUNTY OF HENNEPIN
Golden Key Health Club, Inc.,
a Minnesota corporation,
vs.
Plaintiff,
William P. Craig, City
Manager for Hopkins, Minnesota,
and the City of Hopkins,
Defendants.
STATE OF MINNESOTA)
SS.
COUNTY OF HENNEPIN)
DEBORAH BERG, being first duly sworn upon oath, deposes and
states as follows:
1. That she has been employed by Golden Key Health Club
of Hopkins, Minnesota, for two years.
2. That your affiant was present on the business
premises when Mr. 0. Paul Carlson called the City of Hopkins
and reported to the proper officials at City Hall that he had
hired one, Diane Morvich, to work at Golden Key Health Club.
3. Diane Morvich had been recommended by your affiant, and
on Friday, June 20, 1980, between noon and 1:00 p.m., Diane
Morvich came in for an interview.
4. After the interview, your affiant and Rolande Gardner,
who' were then on duty, asked Mr. Carlson whether Diane had been
hired. Mr. Carlson affirmed this and stated she was going to
start work that night.
5. Mr. Carlson then called Pat at the City Clerk's office
while your affiant was present in the room and listening in,
and when Mr. Clarson was halfway through with the conversation
Rolande Gardner came in and heard the second part of the
conversation.
IN DISTRICT COURT
FOURTH JUDICIAL DISTRICT
AFFIDAVIT
Subscribed and sworn to before
me this 15th day of January, 1981.
FURTHER YOUR AFFIANT SAYETH NOT.
1.• 4r.,
Notary Public
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My Commission Expires Mar. 23, 1983 t
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EBORAH BERG
%1. COHEN
ASSOCIATES
TTORNEYS AT LAW
30 SHELARD TOWER
■OIS PARK, MINNESOTA
846-6300
11
STATE OF MINNESOTA IN DISTRICT COURT
COUNTY OF HENNEPIN FOURTH JUDICIAL DISTRICT
Golden Key Health Club, Inc.,
a Minnesota corporation,
vs.
William P. Craig, City
Manager for Hopkins, Minnesota,
and the City of Hopkins,
STATE OF MINNESOTA)
)SS.
COUNTY OF HENNEPIN)
ROLANDE GARDNER, being first duly sworn upon oath,
deposes and states as follows:
1. That the affiant resides at 1351 Hampshire Avenue,
Apartment 300, St. Louis Park, Minnesota.
2. That the affiant was employed by the Golden Key
Health Club as a masseuse.
3. That the affiant has direct knowledge that Paul
Carlson, one of the owners of the Golden Key Health Club,
did make a telephone call to the City of Hopkins, to report
in the name of Diane Morvich.
4. That the affiant was present in the room when this
telephone call was made by Paul Carlson, and said telephone
call was made on June 20, 1980. At that time Paul Carlson
told the City of Hopkins that Diane Morvich was employed by
the Golden Key Health Club.
5. That the affiant has since learned that Diane
Morvich is listed as one of the employees of the Golden Key
Health Club, for which there is no record that her name was
reported to the City of Hopkins, pursuant to local ordinances.
Plaintiff,
Defendants.
4
AFFIDAVIT
t
6. That the affiant knows that this telephone call
was made, and that the name of Diane Morvich was, in fact,
reported to the City of Hopkins, in compliance with the
licensing requirements for massage parlors and saunas.
FURTHER YOUR AFFIANT SAYETH NOT.
Subscribed and sworn to before me
this 15th day of January, 1981.
7 1
Notary Public
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My Ccnmim;s: Ex !;cs Mar. 23, 1983
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ROLANbE GAR