Preview
Karl P. Schlecht, Esq. (SBN 182294)
Email: kschlecht tresslerllp.com
Jihoon Kim, Esq. (SBN 289780)
Email: jkim@tresslerllp.com
TRESSLER LP
2 Park Plaza, Suite 1050
Irvine, California 92614
Telephone: (949) 336-1232
Fax: (949) 752-0645
Attorneys for Defendants,
JENNIFER RUNYON, AN INDIVIDUAL and
WELCOME HOME PROPERTY MANAGEMENT, AN ENTITY
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF KERN
Case No. BCV-23-100822
10 NILKA COOKS; AN INDIVIDUAL,
[Related to: Lead Case No. BCV-23-100672,
11 Plaintiff, BCV-23-100778, BCV-23-100849,
BCV-23-100850, BCV-23-100851,
12 Vv. BCV-23-100853, BCV-23-100922,
BCV-23-100996, BCV-23-101460,
13 KRYSTAL WALLER, AN INDIVIDUAL; BCV-23-101462, BCV-23-101463]
JENNIFER RUNYON, AN INDIVIDUAL;
14 PARS-15 LLC., A CALIFORNIA LIMITED Assigned to the Hon. T. Mark Smith
LIABILITY COMPANY; WELCOME Dept. T-2 (3131 Arrow St., Bakersfield, CA)
15 HOME PROPERTY MANAGEMENT, AN
ENTITY; AND DOES 1-100, INCLUSIVE, DECLARATION OF KARL SCHLECHT
16 IN SUPPORT OF DEFENDANTS’
Defendants. MOTIONS TO COMPEL FURTHER
17 RESPONSES TO WRITTEN DISCOVERY
FROM PLAINTIFF NILKA COOKS AND
18 DEFENDANTS’ REQUEST FOR
MONETARY SANCTIONS VOLUME #3
19 [Filed concurrently with Jennifer Runyon’s
Motion to Compel Further Responses to
20 Amended Special Interrogatories, Set One;
Jennifer Runyon’s Motion to Compel Further
21 Responses to Amended Request for
Production of Documents, Set One; Welcome
22 Home's Motion to Compel Further
Responses to Amended Special
23 Interrogatories, Set One; Welcome Home's
Motion to Compel Further Responses to
24 Amended Request for Production of
Documents, Set One; Separate Statements in
25 Support of Motions to Compel (x4); and
[Proposed] Orders (x4)]
26
Verified Complaint filed: March 17, 2023
27
VOLUME #3 OF 4
28
1
DECLARATION OF KARL P. SCHLECHT IN SUPPORT OF DEFENDANTS’ MOTIONS TO COMPEL VOLUME #3
794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
the meaning of this interrogatory, Responding Party responds as follows:
Subject to and without waiving the foregoing, and pursuant to the Responding Party’s
understanding as to the meaning of this request, the Responding Party states that after a careful
search and reasonable inquiry Responding Party cannot produce the requested documents
because the documents in question have never been, or are no longer in the possession, custody,
or control of the Responding Party.
10 REQUEST FOR PRODUCTION NO. 30:
11 Please produce any and all DOCUMENTS that support YOUR contention that the UNIT
12 violated building codes as alleged in the COMPLAINT.
13 RESPONSE TO REQUEST FOR PRODUCTION NO. 30:
14 Objection; this request is vague, ambiguous, overbroad, burdensome, and
15 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
16 407. Objection; the requested inspection request is not described with specificity. Objection;
17 this request violates the attorney-client and or attorney work product privileges and judicial
18 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and §
19 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
20 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
21 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
22 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
23 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not
24 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
25 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v.
26 Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
27 Procedure § 2017.010. Objection; this request is equally available to propounding party. See
28 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
33
PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION
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is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
the meaning of this interrogatory, Responding Party responds as follows:
Without waiving objections, the Responding Party states that the inspection of the
documents which are admissible, responsive to this request, and inspectable have been
submitted by bates stamp numbers: #0000001-#0000079.
REQUEST FOR PRODUCTION NO. 31:
10 Please produce any and all DOCUMENTS that support YOUR contention that the UNIT
11 violated health codes as alleged in the COMPLAINT.
12 RESPONSE TO REQUEST FOR PRODUCTION NO. 31:
13 Objection; this request is vague, ambiguous, overbroad, burdensome, and
14 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
15 407. Objection; the requested inspection request is not described with specificity. Objection;
16 this request violates the attorney-client and or attorney work product privileges and judicial
17 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and §
18 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
19 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
20 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
21 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
22 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal. App. 3d 770, 798. Objection; this request is not
23 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
24 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v.
25 Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
26 Procedure § 2017.010. Objection; this request is equally available to propounding party. See
27 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
28 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
34
PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION
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794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
the meaning of this interrogatory, Responding Party responds as follows:
Without waiving objections, the Responding Party states that the inspection of the
documents which are admissible, responsive to this request, and inspectable have been
submitted by bates stamp numbers: #0000001-#0000079.
REQUEST FOR PRODUCTION NO. 32:
Please produce any and all DOCUMENTS that support YOUR contention that the UNIT
10 violated safety codes as alleged in the COMPLAINT.
11 RESPONSE TO REQUEST FOR PRODUCTION NO. 32:
12 Objection; this request is vague, ambiguous, overbroad, burdensome, and
13 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
14 407. Objection; the requested inspection request is not described with specificity. Objection;
15 this request violates the attorney-client and or attorney work product privileges and judicial
16 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and §
17 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
18 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
19 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
20 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
21 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not
22 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
23 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v.
24 Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
25 Procedure § 2017.010. Objection; this request is equally available to propounding party. See
26 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
27 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
28 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
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PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION
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ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
the meaning of this interrogatory, Responding Party responds as follows:
Without waiving objections, the Responding Party states that the inspection of the
documents which are admissible, responsive to this request, and inspectable have been
submitted by bates stamp numbers: #0000001-#0000079.
REQUEST FOR PRODUCTION NO. 33:
Please produce any and all DOCUMENTS that support YOUR contention that there were
DYSFUNCTIONAL ELECTRICAL SYSTEMS in the UNIT as alleged in the COMPLAINT.
10 “DYSFUNCTIONAL ELECTRICAL SYSTEMS” shall refer to and mean “[w]hen using multiple
11 appliances, Plaintiffs allege the electrical shuts off entirely, suffering frequent outages which force
12 the Plaintiff to repeatedly flip the breaker to reinstall electrical supply.”
13 RESPONSE TO REQUEST FOR PRODUCTION NO. 33:
14 Objection; this request is vague, ambiguous, overbroad, burdensome, and
15 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
16 407. Objection; the requested inspection request is not described with specificity. Objection;
17 this request violates the attorney-client and or attorney work product privileges and judicial
18 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and §
19 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
20 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
21 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
22 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
23 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not
24 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
25 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v.
26 Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
27 Procedure § 2017.010. Objection; this request is equally available to propounding party. See
28 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
36
PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION
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is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
the meaning of this interrogatory, Responding Party responds as follows:
Without waiving objections, the Responding Party states that the inspection of the
documents which are admissible, responsive to this request, and inspectable have been
submitted by bates stamp numbers: #0000001-#0000079.
REQUEST FOR PRODUCTION NO. 34:
10 If YOU contend that YOU informed DEFENDANT about DYSFUNCTIONAL
11 ELECTRICAL SYSTEMS in the UNIT as alleged in the COMPLAINT, provide each and every
12 DOCUMENT that evidences YOUR notice.
13 RESPONSE TO REQUEST FOR PRODUCTION NO. 34:
14 Objection; this request is vague, ambiguous, overbroad, burdensome, and
15 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
16 407. Objection; the requested inspection request is not described with specificity. Objection;
17 this request violates the attorney-client and or attorney work product privileges and judicial
18 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and §
19 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
20 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
21 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
22 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
23 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not
24 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
25 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v.
26 Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
27 Procedure § 2017.010. Objection; this request is equally available to propounding party. See
28 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
37
PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION
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is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
the meaning of this interrogatory, Responding Party responds as follows:
Subject to and without waiving the foregoing, and pursuant to the Responding Party’s
understanding as to the meaning of this request, the Responding Party states that after a careful
search and reasonable inquiry Responding Party cannot produce the requested documents
because the documents in question have never been, or are no longer in the possession, custody,
10 or control of the Responding Party.
11 REQUEST FOR PRODUCTION NO. 35:
12 Please produce any and all DOCUMENTS that support YOUR contention that there was
13 mold inside the UNIT as alleged in the COMPLAINT.
14 RESPONSE TO REQUEST FOR PRODUCTION NO. 35:
15 Objection; this request is vague, ambiguous, overbroad, burdensome, and
16 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
17 407. Objection; the requested inspection request is not described with specificity. Objection;
18 this request violates the attorney-client and or attorney work product privileges and judicial
19 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and §
20 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
21 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
22 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
23 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
24 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not
25 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
26 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v.
27 Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
28 Procedure § 2017.010. Objection; this request is equally available to propounding party. See
38
PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION
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Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
the meaning of this interrogatory, Responding Party responds as follows:
Without waiving objections, the Responding Party states that the inspection of the
documents which are admissible, responsive to this request, and inspectable have been
submitted by bates stamp numbers: #0000001-#0000079.
10 REQUEST FOR PRODUCTION NO. 36:
11 If YOU contend that YOU notified DEFENDANT of the existence of mold in the UNIT,
12 provide each and every DOCUMENT that evidences YOUR notice.
13 RESPONSE TO REQUEST FOR PRODUCTION NO. 36:
14 Objection; this request is vague, ambiguous, overbroad, burdensome, and
15 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
16 407. Objection; the requested inspection request is not described with specificity. Objection;
17 this request violates the attorney-client and or attorney work product privileges and judicial
18 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and §
19 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
20 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
21 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
22 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
23 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal. App. 3d 770, 798. Objection; this request is not
24 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
25 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v.
26 Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
27 Procedure § 2017.010. Objection; this request is equally available to propounding party. See
28 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
39
PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION
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is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
the meaning of this interrogatory, Responding Party responds as follows:
Subject to and without waiving the foregoing, and pursuant to the Responding Party’s
understanding as to the meaning of this request, the Responding Party states that after a careful
search and reasonable inquiry Responding Party cannot produce the requested documents
because the documents in question have never been, or are no longer in the possession, custody,
10 or control of the Responding Party.
11 REQUEST FOR PRODUCTION NO. 37:
12 Please produce any and all DOCUMENTS that support YOUR contention that there was
13 “improper hot and cold water supply” in the UNIT as alleged in the COMPLAINT.
14 RESPONSE TO REQUEST FOR PRODUCTION NO. 37:
15 Objection; this request is vague, ambiguous, overbroad, burdensome, and
16 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
17 407. Objection; the requested inspection request is not described with specificity. Objection;
18 this request violates the attorney-client and or attorney work product privileges and judicial
19 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and §
20 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
21 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
22 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
23 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
24 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not
25 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
26 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v.
27 Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
28 Procedure § 2017.010. Objection; this request is equally available to propounding party. See
40
PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION
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Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
the meaning of this interrogatory, Responding Party responds as follows:
Subject to and without waiving the foregoing, and pursuant to the Responding Party’s
understanding as to the meaning of this request, the Responding Party states that after a careful
search and reasonable inquiry Responding Party cannot produce the requested documents
10 because the documents in question have never been, or are no longer in the possession, custody,
11 or control of the Responding Party.
12 REQUEST FOR PRODUCTION NO. 38:
13 Please produce any and all DOCUMENTS that support YOUR contention that “carpeting
14 in the Subject Property is extremely deteriorated and in dire need of replacement” in the UNIT as
15 alleged in the COMPLAINT.
16 RESPONSE TO REQUEST FOR PRODUCTION NO. 38:
17 Objection; this request is vague, ambiguous, overbroad, burdensome, and
18 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
19 407. Objection; the requested inspection request is not described with specificity. Objection;
20 this request violates the attorney-client and or attorney work product privileges and judicial
21 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and §
22 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
23 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
24 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
25 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
26 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal. App. 3d 770, 798. Objection; this request is not
27 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
28 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v.
41
PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION
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Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
Procedure § 2017.010. Objection; this request is equally available to propounding party. See
Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
the meaning of this interrogatory, Responding Party responds as follows:
Without waiving objections, the Responding Party states that the inspection of the
10 documents which are admissible, responsive to this request, and inspectable have been
11 submitted by bates stamp numbers: #0000001-#0000079.
12 REQUEST FOR PRODUCTION NO. 39:
13 Please produce any and all DOCUMENTS that support YOUR contention there were
14 cockroaches in the PROPERTY as alleged in the COMPLAINT.
15 RESPONSE TO REQUEST FOR PRODUCTION NO. 39:
16 Objection; this request is vague, ambiguous, overbroad, burdensome, and
17 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
18 407. Objection; the requested inspection request is not described with specificity. Objection;
19 this request violates the attorney-client and or attorney work product privileges and judicial
20 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and §
21 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
22 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
23 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
24 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
25 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not
26 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
27 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v.
28 Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
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PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION
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Procedure § 2017.010. Objection; this request is equally available to propounding party. See
Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
the meaning of this interrogatory, Responding Party responds as follows:
Without waiving objections, the Responding Party states that the inspection of the
documents which are admissible, responsive to this request, and inspectable have been
10 submitted by bates stamp numbers: #0000001-#0000079.
11 REQUEST FOR PRODUCTION NO. 40:
12 If YOU contend that YOU informed DEFENDANT that there were cockroaches in the
13 PROPERTY as YOU allege in the COMPLAINT, provide each and every DOCUMENT that
14 evidences YOUR notice.
15 RESPONSE TO REQUEST FOR PRODUCTION NO. 40:
16 Objection; this request is vague, ambiguous, overbroad, burdensome, and
17 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
18 407. Objection; the requested inspection request is not described with specificity. Objection;
19 this request violates the attorney-client and or attorney work product privileges and judicial
20 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and §
21 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
22 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
23 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
24 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
25 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not
26 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
27 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v.
28 Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
43
PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION
Doc ID: e8bf18de62ef2946397 169b0af1282dc8c7b6d9!
Procedure § 2017.010. Objection; this request is equally available to propounding party. See
Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
the meaning of this interrogatory, Responding Party responds as follows:
Subject to and without waiving the foregoing, and pursuant to the Responding Party’s
understanding as to the meaning of this request, the Responding Party states that after a careful
10 search and reasonable inquiry Responding Party cannot produce the requested documents
11 because the documents in question have never been, or are no longer in the possession, custody,
12 or control of the Responding Party.
13 REQUEST FOR PRODUCTION NO. 41:
14 Please produce any and all DOCUMENTS that support YOUR contention there were
15 cockroaches in the UNIT as alleged in the COMPLAINT.
16 RESPONSE TO REQUEST FOR PRODUCTION NO. 41:
17 Objection; this request is vague, ambiguous, overbroad, burdensome, and
18 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
19 407. Objection; the requested inspection request is not described with specificity. Objection;
20 this request violates the attorney-client and or attorney work product privileges and judicial
21 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and §
22 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
23 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
24 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
25 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
26 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not
27 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
28 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v.
44
PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION
Doc ID: e8bf18de62ef2946397 169b0af1282dc8c7b6d9!
Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
Procedure § 2017.010. Objection; this request is equally available to propounding party. See
Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
the meaning of this interrogatory, Responding Party responds as follows:
Without waiving objections, the Responding Party states that the inspection of the
10 documents which are admissible, responsive to this request, and inspectable have been
11 submitted by bates stamp numbers: #0000001-#0000079.
12 REQUEST FOR PRODUCTION NO. 42:
13 If YOU contend that YOU informed DEFENDANT that there were cockroaches inside
14 the UNIT as YOU allege in the COMPLAINT, provide each and every DOCUMENT that
15 evidences YOUR notice.
16 RESPONSE TO REQUEST FOR PRODUCTION NO. 42:
17 Objection; this request is vague, ambiguous, overbroad, burdensome, and
18 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
19 407. Objection; the requested inspection request is not described with specificity. Objection;
20 this request violates the attorney-client and or attorney work product privileges and judicial
21 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and §
22 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
23 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
24 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
25 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
26 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal. App. 3d 770, 798. Objection; this request is not
27 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
28 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v.
45
PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION
Doc ID: e8bf18de62ef2946397 169b0af1282dc8c7b6d9!
Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
Procedure § 2017.010. Objection; this request is equally available to propounding party. See
Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
the meaning of this interrogatory, Responding Party responds as follows:
Subject to and without waiving the foregoing, and pursuant to the Responding Party’s
10 understanding as to the meaning of this request, the Responding Party states that after a careful
11 search and reasonable inquiry Responding Party cannot produce the requested documents
12 because the documents in question have never been, or are no longer in the possession, custody,
13 or control of the Responding Party.
14 REQUEST FOR PRODUCTION NO. 43:
15 Please produce each and every DOCUMENT that supports YOUR contention there were
16 DYSFUNCTIONAL PLUMBING SYSTEMS inside the UNIT as YOU allege in the
17 COMPLAINT. (“DYSFUNCTIONAL PLUMBING SYSTEMS” shall mean and refer to the
18 frequently leaking and clogging sinks in the bathroom and kitchen, and bathtubs, without proper
19 hot and cold-water access, that only release scalding hot water.)
20 RESPONSE TO REQUEST FOR PRODUCTION NO. 43:
21 Objection; this request is vague, ambiguous, overbroad, burdensome, and
22 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
23 407. Objection; the requested inspection request is not described with specificity. Objection;
24 this request violates the attorney-client and or attorney work product privileges and judicial
25 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and §
26 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
27 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
28 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
46
PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION
Doc ID: e8bf18de62ef2946397 169b0af1282dc8c7b6d9!
Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not
reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v.
Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
Procedure § 2017.010. Objection; this request is equally available to propounding party. See
Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
10 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
11 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
12 the meaning of this interrogatory, Responding Party responds as follows:
13 Without waiving objections, the Responding Party states that the inspection of the
14 documents which are admissible, responsive to this request, and inspectable have been
15 submitted by bates stamp numbers: #0000001-#0000079.
16 REQUEST FOR PRODUCTION NO. 44:
17 If YOU contend that YOU notified DEFENDANT of the existence of
18 DYSFUNCTIONAL PLUMBING SYSTEMS inside the UNIT, provide each and every
19 DOCUMENT that evidences YOUR notice.
20 RESPONSE TO REQUEST FOR PRODUCTION NO. 44:
21 Objection; this request is vague, ambiguous, overbroad, burdensome, and
22 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
23 407. Objection; the requested inspection request is not described with specificity. Objection;
24 this request violates the attorney-client and or attorney work product privileges and judicial
25 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and §
26 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
27 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
28 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
47
PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION
Doc ID: e8bf18de62ef2946397 169b0af1282dc8c7b6d9!
Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not
reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v.
Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
Procedure § 2017.010. Objection; this request is equally available to propounding party. See
Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
10 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
11 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
12 the meaning of this interrogatory, Responding Party responds as follows:
13 Subject to and without waiving the foregoing, and pursuant to the Responding Party’s
14 understanding as to the meaning of this request, the Responding Party states that after a careful
15 search and reasonable inquiry Responding Party cannot produce the requested documents
16 because the documents in question have never been, or are no longer in the possession, custody,
17 or control of the Responding Party.
18 REQUEST FOR PRODUCTION NO. 45:
19 Please produce each and every DOCUMENT that the DEFENDANT did not hire
20 “professional or licensed contractors” as YOU allege in Paragraph 45 the COMPLAINT.
21 RESPONSE TO REQUEST FOR PRODUCTION NO. 45:
22 Objection; this request is vague, ambiguous, overbroad, burdensome, and
23 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
24 407. Objection; the requested inspection request is not described with specificity. Objection;
25 this request violates the attorney-client and or attorney work product privileges and judicial
26 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and §
27 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
28 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
48
PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION
Doc ID: e8bf18de62ef2946397 169b0af1282dc8c7b6d9!
within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not
reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v.
Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
Procedure § 2017.010. Objection; this request is equally available to propounding party. See
Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
10 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
11 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
12 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
13 the meaning of this interrogatory, Responding Party responds as follows:
14 Without waiving objections, the Responding Party states that the inspection of the
15 documents which are admissible, responsive to this request, and inspectable have been
16 submitted by bates stamp numbers: #0000001-#0000079.
17 REQUEST FOR PRODUCTION NO. 46:
18 If YOU contend that YOU notified DEFENDANT that the DEFENDANT did not hire
19 “professional or licensed contractors”, provide each and every DOCUMENT that evidences
20 YOUR notice.
21 RESPONSE TO REQUEST FOR PRODUCTION NO. 46:
22 Objection; this request is vague, ambiguous, overbroad, burdensome, and
23 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
24 407. Objection; the requested inspection request is not described with specificity. Objection;
25 this request violates the attorney-client and or attorney work product privileges and judicial
26 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and §
27 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
28 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
49
PLAINTIFF’S RES
Preview
Karl P. Schlecht, Esq. (SBN 182294) Email: kschlecht tresslerllp.com Jihoon Kim, Esq. (SBN 289780) Email: jkim@tresslerllp.com TRESSLER LP 2 Park Plaza, Suite 1050 Irvine, California 92614 Telephone: (949) 336-1232 Fax: (949) 752-0645 Attorneys for Defendants, JENNIFER RUNYON, AN INDIVIDUAL and WELCOME HOME PROPERTY MANAGEMENT, AN ENTITY SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF KERN Case No. BCV-23-100822 10 NILKA COOKS; AN INDIVIDUAL, [Related to: Lead Case No. BCV-23-100672, 11 Plaintiff, BCV-23-100778, BCV-23-100849, BCV-23-100850, BCV-23-100851, 12 Vv. BCV-23-100853, BCV-23-100922, BCV-23-100996, BCV-23-101460, 13 KRYSTAL WALLER, AN INDIVIDUAL; BCV-23-101462, BCV-23-101463] JENNIFER RUNYON, AN INDIVIDUAL; 14 PARS-15 LLC., A CALIFORNIA LIMITED Assigned to the Hon. T. Mark Smith LIABILITY COMPANY; WELCOME Dept. T-2 (3131 Arrow St., Bakersfield, CA) 15 HOME PROPERTY MANAGEMENT, AN ENTITY; AND DOES 1-100, INCLUSIVE, DECLARATION OF KARL SCHLECHT 16 IN SUPPORT OF DEFENDANTS’ Defendants. MOTIONS TO COMPEL FURTHER 17 RESPONSES TO WRITTEN DISCOVERY FROM PLAINTIFF NILKA COOKS AND 18 DEFENDANTS’ REQUEST FOR MONETARY SANCTIONS VOLUME #3 19 [Filed concurrently with Jennifer Runyon’s Motion to Compel Further Responses to 20 Amended Special Interrogatories, Set One; Jennifer Runyon’s Motion to Compel Further 21 Responses to Amended Request for Production of Documents, Set One; Welcome 22 Home's Motion to Compel Further Responses to Amended Special 23 Interrogatories, Set One; Welcome Home's Motion to Compel Further Responses to 24 Amended Request for Production of Documents, Set One; Separate Statements in 25 Support of Motions to Compel (x4); and [Proposed] Orders (x4)] 26 Verified Complaint filed: March 17, 2023 27 VOLUME #3 OF 4 28 1 DECLARATION OF KARL P. SCHLECHT IN SUPPORT OF DEFENDANTS’ MOTIONS TO COMPEL VOLUME #3 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and without waiving the foregoing, and pursuant to the understanding of the Responding Party as to the meaning of this interrogatory, Responding Party responds as follows: Subject to and without waiving the foregoing, and pursuant to the Responding Party’s understanding as to the meaning of this request, the Responding Party states that after a careful search and reasonable inquiry Responding Party cannot produce the requested documents because the documents in question have never been, or are no longer in the possession, custody, or control of the Responding Party. 10 REQUEST FOR PRODUCTION NO. 30: 11 Please produce any and all DOCUMENTS that support YOUR contention that the UNIT 12 violated building codes as alleged in the COMPLAINT. 13 RESPONSE TO REQUEST FOR PRODUCTION NO. 30: 14 Objection; this request is vague, ambiguous, overbroad, burdensome, and 15 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 16 407. Objection; the requested inspection request is not described with specificity. Objection; 17 this request violates the attorney-client and or attorney work product privileges and judicial 18 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and § 19 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 20 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 21 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 22 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 23 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not 24 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may 25 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v. 26 Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil 27 Procedure § 2017.010. Objection; this request is equally available to propounding party. See 28 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request 33 PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION Doc ID: e8bf18de62ef2946397 169b0af1282dc8c7b6d9! is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and without waiving the foregoing, and pursuant to the understanding of the Responding Party as to the meaning of this interrogatory, Responding Party responds as follows: Without waiving objections, the Responding Party states that the inspection of the documents which are admissible, responsive to this request, and inspectable have been submitted by bates stamp numbers: #0000001-#0000079. REQUEST FOR PRODUCTION NO. 31: 10 Please produce any and all DOCUMENTS that support YOUR contention that the UNIT 11 violated health codes as alleged in the COMPLAINT. 12 RESPONSE TO REQUEST FOR PRODUCTION NO. 31: 13 Objection; this request is vague, ambiguous, overbroad, burdensome, and 14 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 15 407. Objection; the requested inspection request is not described with specificity. Objection; 16 this request violates the attorney-client and or attorney work product privileges and judicial 17 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and § 18 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 19 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 20 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 21 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 22 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal. App. 3d 770, 798. Objection; this request is not 23 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may 24 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v. 25 Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil 26 Procedure § 2017.010. Objection; this request is equally available to propounding party. See 27 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request 28 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 34 PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION Doc ID: e8bf18de62ef2946397 169b0af1282dc8c7b6d9! 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and without waiving the foregoing, and pursuant to the understanding of the Responding Party as to the meaning of this interrogatory, Responding Party responds as follows: Without waiving objections, the Responding Party states that the inspection of the documents which are admissible, responsive to this request, and inspectable have been submitted by bates stamp numbers: #0000001-#0000079. REQUEST FOR PRODUCTION NO. 32: Please produce any and all DOCUMENTS that support YOUR contention that the UNIT 10 violated safety codes as alleged in the COMPLAINT. 11 RESPONSE TO REQUEST FOR PRODUCTION NO. 32: 12 Objection; this request is vague, ambiguous, overbroad, burdensome, and 13 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 14 407. Objection; the requested inspection request is not described with specificity. Objection; 15 this request violates the attorney-client and or attorney work product privileges and judicial 16 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and § 17 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 18 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 19 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 20 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 21 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not 22 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may 23 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v. 24 Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil 25 Procedure § 2017.010. Objection; this request is equally available to propounding party. See 26 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request 27 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 28 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, 35 PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION Doc ID: e8bf18de62ef2946397 169b0af1282dc8c7b6d9! ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and without waiving the foregoing, and pursuant to the understanding of the Responding Party as to the meaning of this interrogatory, Responding Party responds as follows: Without waiving objections, the Responding Party states that the inspection of the documents which are admissible, responsive to this request, and inspectable have been submitted by bates stamp numbers: #0000001-#0000079. REQUEST FOR PRODUCTION NO. 33: Please produce any and all DOCUMENTS that support YOUR contention that there were DYSFUNCTIONAL ELECTRICAL SYSTEMS in the UNIT as alleged in the COMPLAINT. 10 “DYSFUNCTIONAL ELECTRICAL SYSTEMS” shall refer to and mean “[w]hen using multiple 11 appliances, Plaintiffs allege the electrical shuts off entirely, suffering frequent outages which force 12 the Plaintiff to repeatedly flip the breaker to reinstall electrical supply.” 13 RESPONSE TO REQUEST FOR PRODUCTION NO. 33: 14 Objection; this request is vague, ambiguous, overbroad, burdensome, and 15 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 16 407. Objection; the requested inspection request is not described with specificity. Objection; 17 this request violates the attorney-client and or attorney work product privileges and judicial 18 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and § 19 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 20 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 21 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 22 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 23 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not 24 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may 25 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v. 26 Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil 27 Procedure § 2017.010. Objection; this request is equally available to propounding party. See 28 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request 36 PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION Doc ID: e8bf18de62ef2946397 169b0af1282dc8c7b6d9! is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and without waiving the foregoing, and pursuant to the understanding of the Responding Party as to the meaning of this interrogatory, Responding Party responds as follows: Without waiving objections, the Responding Party states that the inspection of the documents which are admissible, responsive to this request, and inspectable have been submitted by bates stamp numbers: #0000001-#0000079. REQUEST FOR PRODUCTION NO. 34: 10 If YOU contend that YOU informed DEFENDANT about DYSFUNCTIONAL 11 ELECTRICAL SYSTEMS in the UNIT as alleged in the COMPLAINT, provide each and every 12 DOCUMENT that evidences YOUR notice. 13 RESPONSE TO REQUEST FOR PRODUCTION NO. 34: 14 Objection; this request is vague, ambiguous, overbroad, burdensome, and 15 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 16 407. Objection; the requested inspection request is not described with specificity. Objection; 17 this request violates the attorney-client and or attorney work product privileges and judicial 18 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and § 19 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 20 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 21 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 22 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 23 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not 24 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may 25 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v. 26 Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil 27 Procedure § 2017.010. Objection; this request is equally available to propounding party. See 28 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request 37 PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION Doc ID: e8bf18de62ef2946397 169b0af1282dc8c7b6d9! is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and without waiving the foregoing, and pursuant to the understanding of the Responding Party as to the meaning of this interrogatory, Responding Party responds as follows: Subject to and without waiving the foregoing, and pursuant to the Responding Party’s understanding as to the meaning of this request, the Responding Party states that after a careful search and reasonable inquiry Responding Party cannot produce the requested documents because the documents in question have never been, or are no longer in the possession, custody, 10 or control of the Responding Party. 11 REQUEST FOR PRODUCTION NO. 35: 12 Please produce any and all DOCUMENTS that support YOUR contention that there was 13 mold inside the UNIT as alleged in the COMPLAINT. 14 RESPONSE TO REQUEST FOR PRODUCTION NO. 35: 15 Objection; this request is vague, ambiguous, overbroad, burdensome, and 16 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 17 407. Objection; the requested inspection request is not described with specificity. Objection; 18 this request violates the attorney-client and or attorney work product privileges and judicial 19 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and § 20 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 21 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 22 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 23 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 24 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not 25 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may 26 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v. 27 Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil 28 Procedure § 2017.010. Objection; this request is equally available to propounding party. See 38 PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION Doc ID: e8bf18de62ef2946397 169b0af1282dc8c7b6d9! Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and without waiving the foregoing, and pursuant to the understanding of the Responding Party as to the meaning of this interrogatory, Responding Party responds as follows: Without waiving objections, the Responding Party states that the inspection of the documents which are admissible, responsive to this request, and inspectable have been submitted by bates stamp numbers: #0000001-#0000079. 10 REQUEST FOR PRODUCTION NO. 36: 11 If YOU contend that YOU notified DEFENDANT of the existence of mold in the UNIT, 12 provide each and every DOCUMENT that evidences YOUR notice. 13 RESPONSE TO REQUEST FOR PRODUCTION NO. 36: 14 Objection; this request is vague, ambiguous, overbroad, burdensome, and 15 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 16 407. Objection; the requested inspection request is not described with specificity. Objection; 17 this request violates the attorney-client and or attorney work product privileges and judicial 18 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and § 19 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 20 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 21 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 22 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 23 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal. App. 3d 770, 798. Objection; this request is not 24 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may 25 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v. 26 Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil 27 Procedure § 2017.010. Objection; this request is equally available to propounding party. See 28 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request 39 PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION Doc ID: e8bf18de62ef2946397 169b0af1282dc8c7b6d9! is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and without waiving the foregoing, and pursuant to the understanding of the Responding Party as to the meaning of this interrogatory, Responding Party responds as follows: Subject to and without waiving the foregoing, and pursuant to the Responding Party’s understanding as to the meaning of this request, the Responding Party states that after a careful search and reasonable inquiry Responding Party cannot produce the requested documents because the documents in question have never been, or are no longer in the possession, custody, 10 or control of the Responding Party. 11 REQUEST FOR PRODUCTION NO. 37: 12 Please produce any and all DOCUMENTS that support YOUR contention that there was 13 “improper hot and cold water supply” in the UNIT as alleged in the COMPLAINT. 14 RESPONSE TO REQUEST FOR PRODUCTION NO. 37: 15 Objection; this request is vague, ambiguous, overbroad, burdensome, and 16 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 17 407. Objection; the requested inspection request is not described with specificity. Objection; 18 this request violates the attorney-client and or attorney work product privileges and judicial 19 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and § 20 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 21 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 22 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 23 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 24 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not 25 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may 26 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v. 27 Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil 28 Procedure § 2017.010. Objection; this request is equally available to propounding party. See 40 PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION Doc ID: e8bf18de62ef2946397 169b0af1282dc8c7b6d9! Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and without waiving the foregoing, and pursuant to the understanding of the Responding Party as to the meaning of this interrogatory, Responding Party responds as follows: Subject to and without waiving the foregoing, and pursuant to the Responding Party’s understanding as to the meaning of this request, the Responding Party states that after a careful search and reasonable inquiry Responding Party cannot produce the requested documents 10 because the documents in question have never been, or are no longer in the possession, custody, 11 or control of the Responding Party. 12 REQUEST FOR PRODUCTION NO. 38: 13 Please produce any and all DOCUMENTS that support YOUR contention that “carpeting 14 in the Subject Property is extremely deteriorated and in dire need of replacement” in the UNIT as 15 alleged in the COMPLAINT. 16 RESPONSE TO REQUEST FOR PRODUCTION NO. 38: 17 Objection; this request is vague, ambiguous, overbroad, burdensome, and 18 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 19 407. Objection; the requested inspection request is not described with specificity. Objection; 20 this request violates the attorney-client and or attorney work product privileges and judicial 21 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and § 22 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 23 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 24 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 25 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 26 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal. App. 3d 770, 798. Objection; this request is not 27 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may 28 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v. 41 PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION Doc ID: e8bf18de62ef2946397 169b0af1282dc8c7b6d9! Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil Procedure § 2017.010. Objection; this request is equally available to propounding party. See Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and without waiving the foregoing, and pursuant to the understanding of the Responding Party as to the meaning of this interrogatory, Responding Party responds as follows: Without waiving objections, the Responding Party states that the inspection of the 10 documents which are admissible, responsive to this request, and inspectable have been 11 submitted by bates stamp numbers: #0000001-#0000079. 12 REQUEST FOR PRODUCTION NO. 39: 13 Please produce any and all DOCUMENTS that support YOUR contention there were 14 cockroaches in the PROPERTY as alleged in the COMPLAINT. 15 RESPONSE TO REQUEST FOR PRODUCTION NO. 39: 16 Objection; this request is vague, ambiguous, overbroad, burdensome, and 17 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 18 407. Objection; the requested inspection request is not described with specificity. Objection; 19 this request violates the attorney-client and or attorney work product privileges and judicial 20 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and § 21 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 22 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 23 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 24 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 25 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not 26 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may 27 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v. 28 Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil 42 PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION Doc ID: e8bf18de62ef2946397 169b0af1282dc8c7b6d9! Procedure § 2017.010. Objection; this request is equally available to propounding party. See Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and without waiving the foregoing, and pursuant to the understanding of the Responding Party as to the meaning of this interrogatory, Responding Party responds as follows: Without waiving objections, the Responding Party states that the inspection of the documents which are admissible, responsive to this request, and inspectable have been 10 submitted by bates stamp numbers: #0000001-#0000079. 11 REQUEST FOR PRODUCTION NO. 40: 12 If YOU contend that YOU informed DEFENDANT that there were cockroaches in the 13 PROPERTY as YOU allege in the COMPLAINT, provide each and every DOCUMENT that 14 evidences YOUR notice. 15 RESPONSE TO REQUEST FOR PRODUCTION NO. 40: 16 Objection; this request is vague, ambiguous, overbroad, burdensome, and 17 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 18 407. Objection; the requested inspection request is not described with specificity. Objection; 19 this request violates the attorney-client and or attorney work product privileges and judicial 20 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and § 21 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 22 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 23 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 24 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 25 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not 26 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may 27 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v. 28 Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil 43 PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION Doc ID: e8bf18de62ef2946397 169b0af1282dc8c7b6d9! Procedure § 2017.010. Objection; this request is equally available to propounding party. See Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and without waiving the foregoing, and pursuant to the understanding of the Responding Party as to the meaning of this interrogatory, Responding Party responds as follows: Subject to and without waiving the foregoing, and pursuant to the Responding Party’s understanding as to the meaning of this request, the Responding Party states that after a careful 10 search and reasonable inquiry Responding Party cannot produce the requested documents 11 because the documents in question have never been, or are no longer in the possession, custody, 12 or control of the Responding Party. 13 REQUEST FOR PRODUCTION NO. 41: 14 Please produce any and all DOCUMENTS that support YOUR contention there were 15 cockroaches in the UNIT as alleged in the COMPLAINT. 16 RESPONSE TO REQUEST FOR PRODUCTION NO. 41: 17 Objection; this request is vague, ambiguous, overbroad, burdensome, and 18 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 19 407. Objection; the requested inspection request is not described with specificity. Objection; 20 this request violates the attorney-client and or attorney work product privileges and judicial 21 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and § 22 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 23 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 24 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 25 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 26 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not 27 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may 28 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v. 44 PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION Doc ID: e8bf18de62ef2946397 169b0af1282dc8c7b6d9! Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil Procedure § 2017.010. Objection; this request is equally available to propounding party. See Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and without waiving the foregoing, and pursuant to the understanding of the Responding Party as to the meaning of this interrogatory, Responding Party responds as follows: Without waiving objections, the Responding Party states that the inspection of the 10 documents which are admissible, responsive to this request, and inspectable have been 11 submitted by bates stamp numbers: #0000001-#0000079. 12 REQUEST FOR PRODUCTION NO. 42: 13 If YOU contend that YOU informed DEFENDANT that there were cockroaches inside 14 the UNIT as YOU allege in the COMPLAINT, provide each and every DOCUMENT that 15 evidences YOUR notice. 16 RESPONSE TO REQUEST FOR PRODUCTION NO. 42: 17 Objection; this request is vague, ambiguous, overbroad, burdensome, and 18 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 19 407. Objection; the requested inspection request is not described with specificity. Objection; 20 this request violates the attorney-client and or attorney work product privileges and judicial 21 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and § 22 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 23 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 24 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 25 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 26 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal. App. 3d 770, 798. Objection; this request is not 27 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may 28 be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v. 45 PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION Doc ID: e8bf18de62ef2946397 169b0af1282dc8c7b6d9! Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil Procedure § 2017.010. Objection; this request is equally available to propounding party. See Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and without waiving the foregoing, and pursuant to the understanding of the Responding Party as to the meaning of this interrogatory, Responding Party responds as follows: Subject to and without waiving the foregoing, and pursuant to the Responding Party’s 10 understanding as to the meaning of this request, the Responding Party states that after a careful 11 search and reasonable inquiry Responding Party cannot produce the requested documents 12 because the documents in question have never been, or are no longer in the possession, custody, 13 or control of the Responding Party. 14 REQUEST FOR PRODUCTION NO. 43: 15 Please produce each and every DOCUMENT that supports YOUR contention there were 16 DYSFUNCTIONAL PLUMBING SYSTEMS inside the UNIT as YOU allege in the 17 COMPLAINT. (“DYSFUNCTIONAL PLUMBING SYSTEMS” shall mean and refer to the 18 frequently leaking and clogging sinks in the bathroom and kitchen, and bathtubs, without proper 19 hot and cold-water access, that only release scalding hot water.) 20 RESPONSE TO REQUEST FOR PRODUCTION NO. 43: 21 Objection; this request is vague, ambiguous, overbroad, burdensome, and 22 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 23 407. Objection; the requested inspection request is not described with specificity. Objection; 24 this request violates the attorney-client and or attorney work product privileges and judicial 25 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and § 26 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 27 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 28 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 46 PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION Doc ID: e8bf18de62ef2946397 169b0af1282dc8c7b6d9! Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not reasonably calculated to lead to the discovery of admissible evidence, and no good cause may be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v. Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil Procedure § 2017.010. Objection; this request is equally available to propounding party. See Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, 10 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and 11 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to 12 the meaning of this interrogatory, Responding Party responds as follows: 13 Without waiving objections, the Responding Party states that the inspection of the 14 documents which are admissible, responsive to this request, and inspectable have been 15 submitted by bates stamp numbers: #0000001-#0000079. 16 REQUEST FOR PRODUCTION NO. 44: 17 If YOU contend that YOU notified DEFENDANT of the existence of 18 DYSFUNCTIONAL PLUMBING SYSTEMS inside the UNIT, provide each and every 19 DOCUMENT that evidences YOUR notice. 20 RESPONSE TO REQUEST FOR PRODUCTION NO. 44: 21 Objection; this request is vague, ambiguous, overbroad, burdensome, and 22 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 23 407. Objection; the requested inspection request is not described with specificity. Objection; 24 this request violates the attorney-client and or attorney work product privileges and judicial 25 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and § 26 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 27 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 28 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 47 PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION Doc ID: e8bf18de62ef2946397 169b0af1282dc8c7b6d9! Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not reasonably calculated to lead to the discovery of admissible evidence, and no good cause may be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v. Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil Procedure § 2017.010. Objection; this request is equally available to propounding party. See Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, 10 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and 11 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to 12 the meaning of this interrogatory, Responding Party responds as follows: 13 Subject to and without waiving the foregoing, and pursuant to the Responding Party’s 14 understanding as to the meaning of this request, the Responding Party states that after a careful 15 search and reasonable inquiry Responding Party cannot produce the requested documents 16 because the documents in question have never been, or are no longer in the possession, custody, 17 or control of the Responding Party. 18 REQUEST FOR PRODUCTION NO. 45: 19 Please produce each and every DOCUMENT that the DEFENDANT did not hire 20 “professional or licensed contractors” as YOU allege in Paragraph 45 the COMPLAINT. 21 RESPONSE TO REQUEST FOR PRODUCTION NO. 45: 22 Objection; this request is vague, ambiguous, overbroad, burdensome, and 23 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 24 407. Objection; the requested inspection request is not described with specificity. Objection; 25 this request violates the attorney-client and or attorney work product privileges and judicial 26 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and § 27 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 28 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 48 PLAINTIFF’S RESPONSES TO DEFENDANT’S AMENDED FIRST SET OF REQUESTS FOR PRODUCTION Doc ID: e8bf18de62ef2946397 169b0af1282dc8c7b6d9! within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not reasonably calculated to lead to the discovery of admissible evidence, and no good cause may be shown to compel such evasive inspection. See Columbia Broadcasting System, Inc. v. Superior Court of Los Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil Procedure § 2017.010. Objection; this request is equally available to propounding party. See Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 10 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, 11 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and 12 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to 13 the meaning of this interrogatory, Responding Party responds as follows: 14 Without waiving objections, the Responding Party states that the inspection of the 15 documents which are admissible, responsive to this request, and inspectable have been 16 submitted by bates stamp numbers: #0000001-#0000079. 17 REQUEST FOR PRODUCTION NO. 46: 18 If YOU contend that YOU notified DEFENDANT that the DEFENDANT did not hire 19 “professional or licensed contractors”, provide each and every DOCUMENT that evidences 20 YOUR notice. 21 RESPONSE TO REQUEST FOR PRODUCTION NO. 46: 22 Objection; this request is vague, ambiguous, overbroad, burdensome, and 23 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 24 407. Objection; the requested inspection request is not described with specificity. Objection; 25 this request violates the attorney-client and or attorney work product privileges and judicial 26 doctrines; all in direct violation of California Code of Civil Procedure § 2017.010 and § 27 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 28 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 49 PLAINTIFF’S RES