Zoning and Ordinance Restrictions on Short Term Rentals in California

Under Santa Barbara Municipal Code Section 4.08.030, all owners of short-term residential rentals (i.e., 30 days or less) are required to collect from their guests and then pay to City a transient occupancy tax of 10% of the rent charged. Further, under Municipal Code Section 4.08.060, all owners of short term rental properties are required to register their property with the City’s Director of Finance.

In the 2015 litigation proponents of short-term rentals negotiated for a settlement in which they would be exempt from the proposed amendment banning short-term rentals. They were “grandfathered in.” They negotiated the wording of the proposed amendment, including the separate voting requirements for future amendments relating to short-term rentals.

At the time he purchased the vacation home from the developer Gaul asserts he was told he could use it as a short-term rental. At that time the HOA rules did not prohibit short- term rentals. From 2011 – 2015, the HOA requested that he relinquish his right to engage in short-term rentals. In 2015, the HOA proposed amending the CC&Rs to prohibit rentals of fewer than 28 days and the amendment was passed by the members.

As a result, he is still subject to the requested injunction even though the short term rentals were accomplished via an intermediary lessee.

Failure to Make Findings Related to Short-Term Rentals Petitioner makes an argument the City failed to make required findings related to short-term rentals. Petitioner’s argument mirrors its CHBC argument. That is, if the City had made a finding about short-term rentals, the City would have agreed with Petitioner. (Opening Brief 6:20-21.) As with its CHBC argument, Petitioner fails to persuade.

Triable issues are also raised as to UMF 26, in which the Glenns state that they were unaware of any controversy regarding short term rentals before they purchased their property.

[JF 5, 6, 7] It is further undisputed that Defendants have allowed members of the public to reserve rooms at 417 OFW for short-term rentals since 2012. [JF 34] The dispute is whether, as an apartment house, 417 OFW may also rent its units on a short-term basis (i.e., rentals for a period of 30 days or less).

Plaintiff alleges that in or about 2017 the home owners’ association, Defendant here, proposed through its board of directors an amendment to the CC&Rs that would prohibit short-term rentals. Plaintiff objected to this amendment to Section 2.3 of the CC&Rs prohibiting rentals of fewer than 30 days, and now claims that she is entitled to declaratory relief.

Respondent’s Evidence[2] The City has been plagued by the proliferation of unpermitted short-term vacation rentals. Mick Decl. ¶9. It is difficult for City staff to check websites for unpermitted short-term rentals, investigate them, and issue a citation. Id. Short-term rentals create issues of loud noise, parking constraints, and degredation of neighborhoods. Id.

This order precluded short-term rentals, vacation rentals, and other short-term lodging within the County of Riverside unless lodgings were needed to protect the homeless population, house people isolating or quarantining, or who could not return home because a person at their resident was isolating or quarantining. The Court grants Table Rock’s request and takes judicial notice of these myriad orders.

Plaintiff alleges that in or about 2017 the home owners’ association, Defendant here, proposed through its board of directors an amendment to the CC&Rs that would prohibit short-term rentals. Plaintiff objected to this amendment to Section 2.3 of the CC&Rs prohibiting rentals of fewer than 30 days, and now claims that she is entitled to declaratory relief.

The first cause of action alleged in the complaint seeks a declaration as to the "validity of [the City's] practice of accepting and approving permit applications for Short-Term Vacation Rentals within areas of the City zoned R-1-B." The second cause of action seeks an injunction restraining the City from approving applications for Short-Term Vacation Rentals within R-1-B zones. Discussion An action for declaratory relief is only proper when it raises a judiciable controversy.

Plaintiffs allege that Williams began operating a short term vacation rental of her property in 2005 (renting the property to large groups of people from 3-10 days). Plaintiffs allege that the short term rentals produced disturbances (i.e., excessive and constant noise at all hours of the day and night, excessive traffic, and parking violations).

(6) Defendant allowed 1090 Airbnb short-term renters to occupy apartment number 2 (Id. at ¶ 7, Exhibit 4 at 5:15-16; Id. at ¶ 7, Exhibit 7 at 2:12; Id. at ¶ 7, Exhibit 5 at 6:8-9; Id. at ¶ 7, Exhibit 8 at 2:27); and (7) Defendant received gross receipts of $213,975 from her Airbnb short-term rentals of apartment number 2 (Id. at ¶ 8, Exhibit 4 at 5:20-21; Id. at ¶ 7, Exhibit 7 at 2:15.)

They also fail to discuss any defenses pursued regarding the seventh cause of action, which seeks an injunction to prevent the Gregors from engaging in short term rentals. The Gregors never deny they engaged in short term rentals.

Pursuant to DBMC section 22.08.030, operation of a short-term rental is not one of the approved uses for this type of zoning district. Furthermore, DBMC section 5.08.050 specifically prohibits the operation of short-term rentals in Diamond Bar.

Analysis: The complaint alleges and the evidence demonstrates that the defendant has been advertising his property for short-term rentals continuously since receiving title on September 23, 2021, and has been actually renting the property on a short-term basis since October of 2021. Given that the conduct has been occurring continuously for the last 10 months, the Court cannot conclude that there are exigent circumstances justifying a temporary restraining order.

Analysis: The complaint alleges and the evidence demonstrates that the defendant has been advertising his property for short-term rentals continuously since receiving title on September 23, 2021, and has been actually renting the property on a short-term basis since October of 2021. Given that the conduct has been occurring continuously for the last 10 months, the Court cannot conclude that there are exigent circumstances justifying a temporary restraining order.

Analysis: The complaint alleges and the evidence demonstrates that the defendant has been advertising his property for short-term rentals continuously since receiving title on September 23, 2021, and has been actually renting the property on a short-term basis since October of 2021. Given that the conduct has been occurring continuously for the last 10 months, the Court cannot conclude that there are exigent circumstances justifying a temporary restraining order.

Plaintiff alleges the agreement prohibited short-term rentals, the tenant was required to use the unit as a residence and not for any business purpose, use of the facilities was permitted only by Plaintiff, and a 2016 addendum prohibited subletting. (Compl. ¶¶ 12-20.)

However, CC&Rs do not expressly give Plaintiffs the right to short-term rentals. And the Plaintiffs provide no authority that the right to short-term rentals is a benefit under the agreement. While the County’s moratorium will impact Plaintiffs, this moratorium is supposed to end in July 2024. As such, it will not be a permanent bar to Plaintiffs obtaining a permit.

Defendants’ separate statement asserts that “[t]here were no laws that prohibited short-term rentals in 1927, the year 830 Van Ness was built.” (PMF 10.) However, Defendants submit absolutely no evidence that the Subject Property was intended for short term and long term rentals at the time it was built. Thus, Defendants’ assertions are unsupported by any evidence, and are therefore insufficient to create a triable issue of fact.

They further allege that Young represented to Shigang Li that Yan Li had actually purchased the premises for the purpose of making short term rentals through Airbnb and that a license for short term rentals could be easily obtained. (Id., ¶ 10). Shigang Li asked A. Lin, who was Han’s “principal officer,” and Cheng to sign the lease for the premises as guarantors, in exchange for part ownership in Moon, which was subsequently formed to engage in short-term rentals. (Id., ¶¶ 1 and 11).

Defendant Jabli has subleased the property for short-term rentals, even though the property is not registered for home sharing. (Complaint, ¶¶ 48, 51, 75; LAMC, § 12.22, subd. (A)(d)(1)-(2).) In addition, the allegations suggest Defendant Jabli has subleased the property for the purposes of parties that have violated the Los Angeles House Party Ordinance. (Complaint, ¶ 2, 48, 51, 83; see LAMC, §§ 41.58.1, 116.01.)

On May 30, 2017, plaintiff filed a complaint alleging breach of fiduciary duty, violation of CC&R's, fraud, trespass, negligence, intentional infliction of emotional distress, negligent infliction of emotional distress, accounting and declaratory relief against the homeowner association defendant and two individual defendants (Bill Cima and Spiro Demis) arising out of a dispute over short term rentals in a four-unit community.

The SAC alleges Doe and Olson agreed there would be no time restriction on renting her unit, allowing for short-term rentals. SAC ¶51. For purposes of pleading, this must be treated as true. Defendants argue after the CC&Rs were amended to prohibit short-term rentals, Doe was not grandfathered in to old rules allowing short-term rentals. Doe alleges she is grandfathered in, per her agreement with Olson. SAC ¶53. On demurrer, Does allegations must be treated as true.

The documents may be relevant to issue of harm if they show that Plaintiff’s use of the property for short-term rentals creates a risk of damage to the property or potential liability for Defendant as the owner.

Li that Yan Li had actually purchased the premises for the purpose of making short term rentals through Airbnb and that a license for short term rentals could be easily obtained. (FACC, ¶¶ 16 and 17). S. Li asked A. Lin, who was Han’s “principal officer,” and Cheng to sign the lease for the premises as guarantors, in exchange for part ownership in Moon, which was subsequently formed to engage in short-term rentals. (Id., ¶ 1; Cross-Complaint, ¶ 11). Cross-complainants allege that Young told S.

Defendants assert that given the plain meaning of the RSO does not clearly indicate whether it prohibits short-term rentals, the Court should turn to other sources, which Defendants submit as evidence. Defendants submitted evidence suggesting that, prior to July 1, 2019, the RSO did not prohibit short-term rentals of 30 days or less.

The Court is hesitant to curtail Defendants' right and ability to earn a livelihood, especially given that the short-term rental income is necessary to maintain the subject property. It may be difficult to quantify the monetary damages associated with enjoining short term vacation rentals.

Li that Yan Li had actually purchased the premises for the purpose of making short term rentals through Airbnb and that a license for short term rentals could be easily obtained. (Id., ¶ 10). S. Li asked A. Lin, who was Han’s “principal officer,” and Cheng to sign the lease for the premises as guarantors, in exchange for part ownership in Moon, which was subsequently formed to engage in short-term rentals. (Id., ¶¶ 1 and 11). Cross-complainants allege that Young told S.

RESPONDENT OFFICE OF SHORT TERM RENTALS, CITY AND COUNTY OF SAN FRANCISCO DEMURRER to Amended PETITION FOR WRIT OF MANDATE/ PROHIBITION/ CERTIFICATION is continued to September 23, 2021 per stipulation and order. =(501/CFH) Parties may appear in-person, telephonically or via Zoom (Video - Webinar ID: 836 2280 0051; Password: 613303; or Phone Dial in: (415) 762-9988; Webinar ID: 836 2280 0051; Password: 613303).

The judgment sought would seek to give later purchasers of plaintiff’s house relief to which they are not entitled, and it would eliminate the entire amendment to the CC&Rs when only the ban on short-term rentals is being challenged. Additionally, the Answer denies facts that are essential to plaintiff’s right to relief, such as that he bought a house in the subdivision on a date that precedes that date of the amendment plaintiff challenges. (See, e.g., FAC, ¶ 23; Answer, ¶ 23.)

Here, accepting all allegations as true they do not rise to the standard of conscious disregard and/or despicable conduct in continuing to utilize their property for short-term rentals.

Both properties were legally allowed to accommodate short-term rentals because through June 30, 2019 the City did not prohibit short-term rentals in apartment houses. On December 11, 2018, the City passed Ordinance 185931, (the “Ordinance”). The Ordinance prohibits all short-term rentals (rentals for 30 consecutive days or less) of residential units in the City, except for very limited home sharing. The Ordinance went into effect on July 1, 2019.

As to damages, the complaint states “[p]laintiff has been damaged by [d]efendants’ willful and knowing use of the Apartment Home and Lincoln Place for unauthorized short term rentals and commercial activity[,]” without clarifying the nature of the damages. Complaint at ¶25. Defendant argues plaintiff suffered no actual damages, but argues it can recover through disgorgement or restitution of profits. This theory is not alleged.

The Complaints allege the common Defendants flouted regulations by opening up the Property for short-term rentals (e.g., Airbnb). The Complaints allege the Property had insufficient security measures under the Los Angeles Municipal Code, as evidenced by "a host of theft and break in incidents after soliciting short-term rentals.

Defendant argue the complaint does not allege he actively engaged in any conduct marketing the apartment for short term rentals or engaged in intentional, reckless or negligent conduct. (Demurrer at p. 8.) Plaintiff alleges that all defendants knowingly and willfully marketed the apartment on Airbnb.com, VRBO.com, and similar hosting websites, using Plaintiff’s property without authorization. (Complaint ¶ 18.)

RESPONDENTS OFFICE OF SHORT TERM RENTALS AND CITY AND COUNTY OF SAN FRANCISCO'S DEMURRER TO AMENDED PETITION FOR WRIT OF MANDATE/ PROHIBITION/ CERTIFICATION Hearing Required to address whether petitioner can allege in good faith that the third-floor bedroom was legal at all relevant times.

SC123601 Hearing Date May 11, 2022 Plaintiffs Notice of Motion for Attorneys Fees and Motion to be Determined the Prevailing Party (UNOPPOSED) Plaintiff HOA alleges defendant Peters violated CC&Rs by leasing her unit for short-term rentals. Plaintiff prevailed at trial in July 2016 and filed this motion for attorneys fees on August 1, 2016. Proceedings were stayed July 7, 2017, after defendant declared bankruptcy.

At Apreas judgment debtor examination on July 25, 2022, she testified that in the past she has also received income from other short-term rental websites such as Booking.com and VRBO.com. (Linzer Decl., ¶ 12.) Aprea argues the payments are not subject to assignment because income from short-term rentals is not rent under CCP § 708.510(a)(2). Assuming that is correct, it is irrelevant. The enumerated types of payments are only examples.

Nor is it relevant to show that the landlord had no problem with short term rentals. A landlord is entitled to choose to engage in short term rentals with the landlords own unit; that does not mean that the landlord is under an obligation to allow tenants to do the same. MIL 4 . The court is inclined to DENY the motion. While the landlords motivation is not dispositive, it does go to credibility.

The HOA alleges that Defendants violated the CC&Rs and the La Quinta Fairways Rules and Regulations (together, the “Governing Documents”) by advertising their individual properties as short-term rentals and submitting leases to the HOA for approval that, inter alia, hide the length of the rental. (FAC, ¶¶ 17-19, 22, 27-29, 34, 37-39, 44, 47-49, 54, 57-59, 64, 67-69, 75.)

which bans vacation rentals and limits short-term rentals within the City and requires the residents obtain a License from the Respondent for home-sharing. (Memo P&A 1:22-23.) Respondent opposes the motion. The motion is DENIED. As an initial matter, as Respondent denied Petitioner a home-sharing license, there is no administrative decision to stay. Petitioner is not requesting a stay through his motion. Instead, he is requesting a mandatory injunction.

The general effect of the writ is to limit, at least temporarily, the City's then-ongoing effort to restrict the availability of short-term vacation rentals in the Coastal Zone of the city of Santa Barbara. Kracke seeks an award of attorneys' fees pursuant to Code of Civil Procedure section 1021.5.

Here, as noted above, Treitel declares that Defendant is not the owner or proprietor of any short-term rental business at the property, does not have the right to rent rooms for short-term rentals there, and is not primarily or secondarily responsible for the operation of any short-term rental business. (Defendant’s UMF Nos. 1-3; Treitel Decl. ¶¶ 2-4.) These are not evidentiary facts; they are legal conclusions.

That Essex allowed short-term rentals does not make Essex liable for conduct that occurred when it was not in control of the premises. Essexs motion for summary judgment is GRANTED.

The City's generalized policies with respect to refuse collection for short term rentals in the Mission Beach neighborhood has little, if any, bearing on the specific denial of the City provided refuse collection services at issue in this action. The Court is not persuaded that its interpretation of the applicable ordinances and regulations was in error. The Court is not persuaded that its determination that the City did not act arbitrarily or capriciously was in error.

Huesca et al., Case No. 20SMCV00130 Hearing Date February 2, 2023 Aimco Venezia LLCs Special Motion to Strike (Anti-SLAPP Motion) Second Amended Cross-Complaint (UNOPPOSED) Plaintiff Aimco Venezia LLC alleges its former tenants Luske and Huesca wrongfully used their rental property for short-term rentals on Airbnb and similar websites. Luske and Huesca cross-complained.

Lin’s representations, that the tenant used the Property as a short-term rental property inconsistent with their agreement with Plaintiff Yan, that, had Yan known about the tenants’ intention to conduct short term rentals on the Property, Yan would not have agreed to lease the Property to them and that the Property was damaged on or about March 25, 2017, when the Property was rented out to a third party for a social event. (Id., ¶¶ 18-24 and 26.)

The Motion (ROA # 38) of Respondent California Coastal Commission ("Respondent" or "Commission") to dismiss the Petition of Petitioner City of Del Mar ("Petitioner" or "City") for writ of mandamus to challenge the Commission's June 7, 2018 decision to reject and then certify with suggested modifications the City's Local Coastal Program Amendment ("LCP amendment") addressing short-term rentals ("STRs"), is GRANTED.

FILED: January 13 , 2022 PROCEEDINGS: REQUEST FOR ENTRY OF DEFAULT JUDGMENT MOVING PARTY: Ultimate Host LLC RESP ONDING PARTY: Juan Antonio Molina BACKGROUND This case arises from a dispute over a short term rental . Plaintiff Ultimate Host LLC is a concierge company t hat provides high - end short - term rentals.

In this case, for every day that the court’s preliminary injunction remains in effect, the city finds itself enjoined and restrained from enforcing significant portions of its current and former ordinances governing short-term rentals. Failure to comply with the preliminary injunction subjects the city to contempt proceedings as well as other sanctions. In fact, previous failures to comply with the injunction have already resulted in a finding of contempt and an award of attorney’s fees.

In this case, for every day that the court’s preliminary injunction remains in effect, the city finds itself enjoined and restrained from enforcing significant portions of its current and former ordinances governing short-term rentals. Failure to comply with the preliminary injunction subjects the city to contempt proceedings as well as other sanctions. In fact, previous failures to comply with the injunction have already resulted in a finding of contempt and an award of attorney’s fees.

In this case, for every day that the court’s preliminary injunction remains in effect, the city finds itself enjoined and restrained from enforcing significant portions of its current and former ordinances governing short-term rentals. Failure to comply with the preliminary injunction subjects the city to contempt proceedings as well as other sanctions. In fact, previous failures to comply with the injunction have already resulted in a finding of contempt and an award of attorney’s fees.

As previously expressed, all Rancho Mirage residents are now subject to a total short-term rental ban, namely ordinance 1189. All Rancho Mirage residents (save and except petitioners herein) may no longer rent their properties on a short-term basis, and 1189’s June 30, 2022 phase-out deadline is now two months passed. Given the presumed validity of ordinance 1189 (see, e.g., Hale v. Morgan (1978) 22 Cal.3d 388, 404; Corona- Norco Unified School Dist. v.

Right or wrong, this court has consistently stated, and still maintains, that the city has the general power to prohibit short-term rentals within its jurisdiction. (Ewing v. City of Carmel-By-The-Sea (1991) 234 Cal.App.3d 1579; see also Kasper v.

Having read the FAC the Court concludes Plaintiffs are complaining about enforcement – specifically, that the City is interpreting the law in an incorrect manner and is therefore not enforcing the San Diego Municipal Code ("SDMC") with respect to short term vacation rentals ("STVRs").

Moreover, there is no evidence a long-term rental would be useful to Petitioner (who lives in Wyoming) in the future or that long-term rentals are a measure of Petitioner’s financial benefit from the litigation. [6] Instead, since December 2015 through 2019, Petitioner rented the property for multiple short-term periods. (Keen Decl., ¶¶ 5, 6.) Thus, the monetary comparison of long- to short-term rentals on this evidence is: zero versus $74,221 (net). (Keen Decl., ¶ 15.)

In brief, in May 2017 Del Mar Alliance submitted a request under the Public Records Act ("PRA") to the City of Del Mar for 25 categories of documents regarding short-term rentals. When it did not receive any documents, Del Mar Alliance filed a complaint and petition for writ of mandate on July 17, alleging the City of Del Mar failed to comply the PRA. Del Mar Alliance seeks declaratory, mandamus and injunctive relief under the PRA. Govt. Code, § 6258.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.

On June 20, 2022, Plaintiff provided Defendant with a supplemental response to RFA No. 5, which states the following: Plaintiff admits that it participated in the VIP RENTAL PROGRAM for rentals but further states that it agreed to permit Defendant to invoice it for authorized short-term rentals as part of the monthly MELA invoicing that Defendant sent to Plaintiff but denies that the two programs ever merged or overlapped.