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                                                           CLIENT/MATTER NUMBER
                                                                    059284-0141


                            September 28, 2001



ZAP
117 Morris Street
Sebastopol, California 95472

         Re:      ZAP

Gentlemen:

          We have acted as counsel to ZAP (the "Company"), in connection with
the registration of shares of ZAP Series B Convertible Preferred Stock (the
"Shares") as described in the Company's Registration Statement on Form SB-2
filed with the Securities and Exchange Commission under the Securities Act of
1933, as amended.

          We have reviewed such documents and have made such inquiries as we
have deemed necessary and appropriate to render the opinion set forth herein. We
have assumed that all documents that have been submitted to us as originals are
true and correct and those documents submitted to us, as copies conform to the
originals of those documents.

          The Shares are duly authorized, validly issued, fully paid and
non-assessable. We are not providing an opinion as to any other statements
contained in the Form SB-2 Registration Statement, nor as to matters that occur
after the date thereof.

          We consent to the filing of this opinion as an exhibit to the Form
SB-2 Registration Statement.

                                           Sincerely,


                                           /s/ FOLEY & LARDNER