UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION

CARRIE BAUER, §

STEPHANEY MAYFIELD, §

and ELIZABETH SUE §

§

Plaintiffs, §

§ CA No. 3:21-cv-2250-BH

v. §

§

RUFE SNOW INVESTMENT, LLC., § JURY DEMANDED

d/b/a IN-N-OUT GYROS and STOP-N-GO §

GYROS, and §

ZIAD MASSARWA, Individually §

§

Defendants §

DEFENDANT RUFE SNOW INVESTMENT, LLC., d/b/a IN-N-OUT GYROS

and STOP-N-GO GYROS RESPONSES TO PLAINTIFF ELIZABETH SUE’S 

FIRST SET OF INTERROGATORIES

TO: Elizabeth Sue by and through her attorney, David Langenfeld, LEICHTER 

LAW FIRM1602 East 7th Street Austin, TX 78702 

Respectfully submitted,

By: Wes Dauphinot 

WES DAUPHINOT

State Bar No. 00793584 

wes@dauphinotlawfirm.com 

DAUPHINOT LAW FIRM

900 W. Abram Street 

Arlington, Texas 76013 

(817) 462-0676 telephone

(817) 704-4788 facsimile

By: Hani F. Kobty 

HANI F. KOBTY

State Bar No. 24087855 

hani@kobtylawfirm.com 

KOBTY LAW FIRM, PLLC

900 W. Abram Street 

Arlington, Texas 76013 

Exhibit A

Case 3:21-cv-02250-BH Document 23-1 Filed 11/18/22 Page 1 of 5 PageID 1105
(817) 223-0989 telephone

(817) 549-9325 facsimile

ATTORNEYS FOR DEFENDANTS

CERTIFICATE OF SERVICE

The undersigned hereby certifies that a copy of the foregoing document was

served on counsel for the Plaintiff(s), in the manner indicated, on August 18, 2022, as 

follows: 

David Langenfeld Via Email david@leichterlaw.com

LEICHTER LAW FIRM

1602 East 7th Street

Austin, Texas 78702 

Stephen Le Brocq Via Email stephen@lebrocqhorner.com 

LE BROCQ & HORNER, PLLC

2150 N Josey Lane 

Suite 227 

Carrollton, Texas 75006 

 

 ______/s/ Wes Dauphinot_________________ 

 WES DAUPHINOT

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INTERROGATORY NO. 16

If the Plaintiff monitored or implemented legal compliance measures on behalf of the 

Defendant, please describe how and when (on a workweek-by-workweek basis) the 

Plaintiff did so.

ANSWER: None.

INTERROGATORY NO. 17

By week start date and end date for each workweek that the Plaintiff was employed, please 

state:

a). The total number of hours worked each week by the Plaintiff in each such time 

period; and 

b). The total number of hours for which the Plaintiff was paid by the Defendant for each 

week that the Plaintiff worked. 

ANSWER: Please see the paycheck details for Elizabeth Sue previously provided by 

Defendant in discovery. 

INTERROGATORY NO. 18

Please state the exact amount of all compensation the Plaintiff was paid for each workweek 

the Plaintiff was employed by the Defendant, and, state how much of each such amount 

consisted of: 

a). salary;

b). hourly wage;

c). bonuses;

d). commissions;

e). tips; and

f). any additional manner of compensation.

ANSWER: Elizabeth Sue received an hourly wage of $13.00 per hour until May of 2021 

when her pay increased to $17.00 per hour. While she received $13.00 per hour, she 

received additional compensation of cash tips and electronic tips from credit cards. While 

she received $17.00 per hour, she received additional compensation of cash tips, but no 

Case 3:21-cv-02250-BH Document 23-1 Filed 11/18/22 Page 3 of 5 PageID 1107
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electronic tips. 

INTERROGATORY NO. 19

Identify all evidence which in any way would indicate hours worked by Plaintiff including, 

but not limited to, emails, time sheets, time cards, credit card records, travel records, 

computer log-in records, computer log-out records, building entry records, building exit 

records, parking facility entry records, parking facility exit records and invoices or other 

documents to clients/customers or any third party payor evidencing billing for work 

performed by Plaintiff or in any way documenting work performed by Plaintiff. 

ANSWER: Please see the paycheck details previously produced by Defendant in discovery. 

INTERROGATORY NO. 20

For each shift worked by Plaintiff, state the amount of money paid by customers as tips 

and identify all other employees working during that shift and the employee who waited 

on the customer who paid the tip. 

ANSWER: Please see the paycheck details previously produced by Defendant in discovery. 

INTERROGATORY NO. 21

Identify allsupervisors of Plaintiff during the relevant time period including their job titles and 

dates such person supervised Plaintiff.

ANSWER: Haneen Mahmood (210) 984-1992 was her supervisor for the first few months 

of Elizabeth’s employment. 

INTERROGATORY NO. 22

If you contend that your actions with respect to Plaintiff were taken in good faith with 

reasonable grounds to believe such conduct comported with the FLSA or interpretations of 

the FLSA pursuant to 29 U.S.C. § 260, then identify every fact upon which you rely in 

support of such contention. 

ANSWER: Defendant treated Plaintiff in accordance with the law and paid her 

compensation for everything she was entitled to under the law. 

INTERROGATORY NO. 23

If you contend your acts or omissions with regard to any claims brought by Plaintiff were 

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