Preview
1 Karl P. Schlecht, Esq. (SBN 182294)
Email: kschlecht@tresslerllp.com
2 Jihoon Kim, Esq. (SBN 289780)
Email: jkim@tresslerllp.com
3 TRESSLER LLP
2 Park Plaza, Suite 1050
4 Irvine, California 92614
Telephone: (949) 336-1232
5 Fax: (949) 752-0645
6 Attorneys for Defendants,
JENNIFER RUNYON, AN INDIVIDUAL and
7 WELCOME HOME PROPERTY MANAGEMENT, AN ENTITY
8 SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF KERN
9
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 v. 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 #4
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 #4 OF 4
28
1
DECLARATION OF KARL P. SCHLECHT IN SUPPORT OF DEFENDANTS’ MOTIONS TO COMPEL VOLUME #4
EXHIBITD.3
JACOB 0. PARTIYELI, ESQ. (SBN: 295967)
1 Law Office of Jacob 0. Partiyeli
Complex Litigation Bureau
2 4751 Whittier Boulevard.
Los Angeles, California. 90022
3 Phone:310-801-1919
Fax: 323-647-2387
4 E-service Email: complex@jacobfights.com
5 Attorney For Plaintiff
6
7 SUPERIOR COURT OF THE STATE OF CALIFORNIA
8 COUNTY OF KERN
9
10 NILKA COOKS, AN INDIVIDUAL, Case No. BCV-23-100822
11 Plaintiff, PLAINTIFF'S RESPONSES TO
DEFENDANT'S AMENDED FIRST
12 v. SET OF SPECIAL
INTERROGATORIES
13 KRYSTAL WALLER, AN INDIVIDUAL;
JENNIFER RUNYON, AN INDIVIDUAL;
14 PARS-15 LLC., A CALIFORNIA LIMITED
LIABILITY COMPANY; WELCOME
15 HOME PROPERTY MANAGEMENT, AN
ENTITY; AND DOES 1-100, INCLUSIVE,
16
Defendants.
17
18 PROPOUNDING PARTY: WELCOME HOME PROPERTY MANAGEMENT
19
RESPONDING PARTY: NILKACOOKS
20
SET NO: One
21
Ill
22
23 Ill
24 Ill
25 Ill
26
Ill
27
Ill
28
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PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES
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1 PRELIMINARY STATEMENT
2 This Preliminary Statement and all objections set forth herein apply to each response. To
3 the extent that response to said Request for Special Interrogatories have been previously provided
4 by this responding party, it is providing further responses in accommodation, and is not, nor has
5 it agreed to forfeit or otherwise waive any and all rights afforded it by statute, law or custom,
6 including but not limited to specific rights and options set forth in Code of Civil Procedures §
7 2030.010, et seq.
8 This Responding Party has not fully completed the investigation of the facts relating to
9 this case, has not fully completed discovery in this action, and has not completed its preparation
10 for trial. Discovery in this case is presently ongoing and it is anticipated that further discovery,
11 investigation, legal research, and analyses will supply facts and new meaning to the already
12 known facts, as well as establish entirely new factual conclusions and legal contentions, all of
13 which may lead to changes in, or variations from the contentions and response as set forth herein.
14 The following responses are made without prejudice to the responding party's right to produce
15 evidence of any subsequently investigated, discovered and/or analyzed evidence which the
16 responding party may later recall which pertains to or is otherwise relevant or responsive to the
17 discovery responded to herein. Responding Party has accordingly reserved the right to change any
18 and all answers herein as additional facts are ascertained, analyses are made, legal research is
19 completed, and contentions are formulated. The responses contained herein are made in good faith
20 effort to supply as much formulated. The responses contained herein made in good faith effort to
21 supply as much factual information and as much specification of legal contention as is presently
22 known.
23 In setting forth these responses, Responding Party does not waive rights afforded by the
24 attorney work product privilege, attorney work product doctrine, or other privilege or immunity
25 from disclosure which may attach to information called forth in, or responsive to, any
26 Interrogatories, or, in responding to all or any portion of any Interrogatories, or the subject matter
27 to which the Interrogatory refers.
28 Ill
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PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES
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1 These responses are submitted by Responding Party subject to, and without in any way
2 waiving or intending to waive, but on the contrary, intending to reserve and reserving;
3 (1) All questions as to competency, materiality, privilege and admissibility as
4 evidenced for any purpose of any of the documents referred to or further response are given, or
5 the subject matter thereof, in any subsequent proceeding in, or trial of, this action or any other
6 action or proceeding;
7 (2) The right to object to other discovery procedures involving or relating to the
8 subject matter of the Interrogatories herein responded to, including any Interrogatory specifically
9 identified herein; and
10 (3) The right at any time to revise, correct, add to, or clarify any of the responses set
11 forth herein, or documents produced or referred herein.
12 Ill
13 Plaintiff, NILKA COOKS, (hereinafter referred to as "Plaintiff' or "Responding Party")
14 hereby responds and objects to the Amended First Set of Special Interrogatories, Set One,
15 propounded by Defendant, WELCOME HOME PROPERTY MANAGEMENT, (hereinafter
16 referred to as "Defendant" or "Propounding Party,") as follows:
17 RESPONSES TO SPECIAL INTERROGATORIES
18 SPECIAL INTERROGATORY NO. 1:
19 IDENTIFY all individuals that reside(d) at the UNIT during the duration of your lease
20 agreement with DEFENDANT. ("IDENTIFY" "IDENTITY," or "IDENTIFICATION" when
21 used in conjunction with: (1) an individual, requires YOU to state the individual's full name, last
22 known home address, last known home and business telephone numbers, present or last known
23 business affiliation or employer, business address and job title, exact or approximate date and
24 place of death if deceased; (2) a PERSON other than an individual, requires YOU to state its
25 name, address and telephone number and the name of the principal individuals with knowledge
26 of the subject matter of these requests; and (3) a DOCUMENT, requires YOU to state the type of
27 document, its date of creation, the full name of the author, all recipients thereof, subject matter,
28 number of pages, and the full names of each person who (to the best of Plaintiffs knowledge and
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PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES
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1 belief) has seen such document (including copies thereof) or has knowledge of the subject matter
2 or context thereof.) ("UNIT" shall be defined as the premises described in the lease entered into
3 between the Plaintiff, NILKA COOKS and Defendant WELCOME HOME PROPERTY
4 MANAGEMENT, INC, located at 3400 15th Street West, Unit 91, Rosamond, California 93560.)
5 (YOU" or "YOUR(S)" refers to Plaintiff, NILKA COOKS, an individual, and includes her
6 attorneys, investigators, and anyone else acting on her behalf.) ("DEFENDANT" shall mean and
7 refer to defendant, JENNIFER RUNYON, or any individual, entity, agent, employee, officer or
8 representative acting on its behalf.) ("Property" shall be defined as the entire apartment complex
9 located at 3400 15th Street West, Rosamond, California 93560) ("COMPLAINT" shall refer to
10 the verified complaint entitled Nilka Cooks, an Individual, vs. Krystal Waller, et.al., filed on
11 March 17, 2023, in Kem County Superior Court, Case No. BCV-23-100822.)
12 RESPONSE TO SPECIAL INTERROGATORY NO. 1:
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 ofLos 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,
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PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES
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1 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
2 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
3 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
4 the meaning of this interrogatory, Responding Party responds as follows:
5 1. Nilka Cooks. 3400 15th Street West. Apartment 91. Rosamond, California. 93560.
6 (360) 980-7089.
7 SPECIAL INTERROGATORY NO. 2:
8 For each of the individuals identified in Special Interrogatory No. 1, state the duration and
9 dates on which they reside(d) at the UNIT.
10 RESPONSE TO SPECIAL INTERROGATORY NO. 2:
11 Objection; this request is vague, ambiguous, overbroad, burdensome, and
12 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
13 407. Objection; the requested inspection request is not described with specificity. Objection;
14 this request violates the attorney-client and or attorney work product privileges and judicial
15 doctrines; all in direct violation of California Code of Civil Procedure§ 2017.010 and§
16 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
17 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
18 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
19 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
20 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not
21 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
22 be shown to compel such evasive inspection See Columbia Broadcasting System, Inc. v.
23 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
24 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See
25 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
26 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
27 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
28 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
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1 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
2 the meaning of this interrogatory, Responding Party responds as follows:
3 1. In or around April 2018, to the Present.
4 SPECIAL INTERROGATORY NO. 3:
5 State, if any, the breed and species of any PETS kept by YOU at the UNIT. ("PETS" shall
6 mean any domesticated or tamed animal.)
7 RESPONSE TO SPECIAL INTERROGATORY NO. 3:
8 Objection; this request is vague, ambiguous, overbroad, burdensome, and
9 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
10 407. Objection; the requested inspection request is not described with specificity. Objection;
11 this request violates the attorney-client and or attorney work product privileges and judicial
12 doctrines; all in direct violation of California Code of Civil Procedure§ 2017.010 and§
13 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
14 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
15 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
16 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
17 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not
18 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
19 be shown to compel such evasive inspection See Columbia Broadcasting System, Inc. v.
20 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
21 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See
22 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
23 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
24 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
25 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
26 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
27 the meaning of this interrogatory, Responding Party responds as follows:
28 None.
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1 SPECIAL INTERROGATORY NO. 4:
2 State, if any, the COMMERICAL ACTIVITY conducted by YOU at the UNIT.
3 ("COMMERICAL ACTIVITY'' shall mean an activity intended for exchange in the market to
4 earn an economic profit.)
5 RESPONSE TO SPECIAL INTERROGATORY NO. 4:
6 Objection; this request is vague, ambiguous, overbroad, burdensome, and
7 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
8 407. Objection; the requested inspection request is not described with specificity. Objection;
9 this request violates the attorney-client and or attorney work product privileges and judicial
10 doctrines; all in direct violation of California Code of Civil Procedure§ 2017.010 and§
11 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
12 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
13 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
14 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
15 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not
16 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
17 be shown to compel such evasive inspection See Columbia Broadcasting System, Inc. v.
18 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
19 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See
20 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
21 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
22 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
23 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
24 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
25 the meaning of this interrogatory, Responding Party responds as follows:
26 None.
27 Ill
28 Ill
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1 SPECIAL INTERROGATORY NO. 5:
2 State, if any, the ILLEGAL ACTIVITY conducted by YOU at the UNIT. ("ILLEGAL
3 ACTIVITY" shall mean an activity carried out for illegal purposes under United States Law,
4 California State Law, and/or under any other applicable law(s).)
5 RESPONSE TO SPECIAL INTERROGATORY NO. 5:
6 Objection; this request is vague, ambiguous, overbroad, burdensome, and
7 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
8 407. Objection; the requested inspection request is not described with specificity. Objection;
9 this request violates the attorney-client and or attorney work product privileges and judicial
10 doctrines; all in direct violation of California Code of Civil Procedure§ 2017.010 and§
11 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
12 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
13 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
14 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
15 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not
16 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
17 be shown to compel such evasive inspection See Columbia Broadcasting System, Inc. v.
18 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
19 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See
20 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
21 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
22 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
23 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
24 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
25 the meaning of this interrogatory, Responding Party responds as follows:
26 None.
27 Ill
28 Ill
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1 SPECIAL INTERROGATORY NO. 6:
2 State, if any, the ILLICIT ACTIVITY conducted by YOU at the UNIT. ("ILLICIT
3 ACTIVITY" shall mean an activity considered to be improper or socially forbidden; they may or
4 may not be illegal but go against social norms and values.)
5 RESPONSE TO SPECIAL INTERROGATORY NO. 6:
6 Objection; this request is vague, ambiguous, overbroad, burdensome, and
7 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
8 407. Objection; the requested inspection request is not described with specificity. Objection;
9 this request violates the attorney-client and or attorney work product privileges and judicial
10 doctrines; all in direct violation of California Code of Civil Procedure§ 2017.010 and§
11 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
12 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
13 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
14 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
15 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not
16 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
17 be shown to compel such evasive inspection See Columbia Broadcasting System, Inc. v.
18 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
19 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See
20 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
21 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
22 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
23 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
24 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
25 the meaning of this interrogatory, Responding Party responds as follows:
26 None.
27 SPECIAL INTERROGATORY NO. 7:
28 Identify the duration and the dates in which YOU resided at the PROPERTY.
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PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES
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1 RESPONSE TO SPECIAL INTERROGATORY NO. 7:
2 Objection; this request is vague, ambiguous, overbroad, burdensome, and
3 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
4 407. Objection; the requested inspection request is not described with specificity. Objection;
5 this request violates the attorney-client and or attorney work product privileges and judicial
6 doctrines; all in direct violation of California Code of Civil Procedure§ 2017.010 and§
7 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
8 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7, 10. Such protections are also embodied
9 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
10 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
11 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not
12 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
13 be shown to compel such evasive inspection See Columbia Broadcasting System, Inc. v.
14 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
15 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See
16 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
17 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
18 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
19 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
20 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
21 the meaning of this interrogatory, Responding Party responds as follows:
22 In or around April 2018, to the Present.
23 SPECIAL INTERROGATORY NO. 8:
24 State whether you were in possession and control of the UNIT during the entire duration
25 of YOUR lease for the UNIT.
26 RESPONSE TO SPECIAL INTERROGATORY NO. 8:
27 Objection; this request is vague, ambiguous, overbroad, burdensome, and
28 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
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1 407. Objection; the requested inspection request is not described with specificity. Objection;
2 this request violates the attorney-client and or attorney work product privileges and judicial
3 doctrines; all in direct violation of California Code of Civil Procedure§ 2017.010 and§
4 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
5 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
6 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
7 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
8 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not
9 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
10 be shown to compel such evasive inspection See Columbia Broadcasting System, Inc. v.
11 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
12 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See
13 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
14 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
15 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
16 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
17 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
18 the meaning of this interrogatory, Responding Party responds as follows:
19 Yes.
20 SPECIAL INTERROGATORY NO. 9:
21 IDENTIFY, if any, any sublease agreement for the UNIT that YOU were a party to.
22 RESPONSE TO SPECIAL INTERROGATORY NO. 9:
23 Objection; this request is vague, ambiguous, overbroad, burdensome, and
24 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
25 407. Objection; the requested inspection request is not described with specificity. Objection;
26 this request violates the attorney-client and or attorney work product privileges and judicial
27 doctrines; all in direct violation of California Code of Civil Procedure§ 2017.010 and§
28 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
11
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1 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
2 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
3 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
4 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not
5 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
6 be shown to compel such evasive inspection See Columbia Broadcasting System, Inc. v.
7 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
8 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See
9 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
10 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
11 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
12 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
13 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
14 the meaning of this interrogatory, Responding Party responds as follows:
15 None.
16 SPECIAL INTERROGATORY NO. 10:
17 IDENTIFY, if any, any contractual agreements regarding the UNIT that YOU were a party
18 to.
19 RESPONSE TO SPECIAL INTERROGATORY NO. 10:
20 Objection; this request is vague, ambiguous, overbroad, burdensome, and
21 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
22 407. Objection; the requested inspection request is not described with specificity. Objection;
23 this request violates the attorney-client and or attorney work product privileges and judicial
24 doctrines; all in direct violation of California Code of Civil Procedure§ 2017.010 and§
25 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
26 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
27 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
28 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
12
PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES
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1 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not
2 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
3 be shown to compel such evasive inspection See Columbia Broadcasting System, Inc. v.
4 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
5 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See
6 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
7 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
8 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
9 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
10 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
11 the meaning of this interrogatory, Responding Party responds as follows:
12 The Responding Party contends that there is a written lease agreement that was signed in
13 or around April 2018.
14 SPECIAL INTERROGATORY NO. 11:
15 State all YOUR efforts to maintain the UNIT.
16 RESPONSE TO SPECIAL INTERROGATORY NO. 11:
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.
13
PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES
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1 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
2 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See
3 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
4 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
5 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
6 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
7 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
8 the meaning of this interrogatory, Responding Party responds as follows:
9 The Responding Party consistently communicates concerns to the owners and overseers
10 of the premises approximately every two weeks. Additionally, the Responding Party purchases
11 cockroach repellent products on a monthly basis and strategically deploys these items within the
12 residence in an effort to mitigate the presence of cockroaches.
13 SPECIAL INTERROGATORY NO. 12:
14 State all YOUR efforts to repair the UNIT.
15 RESPONSE TO SPECIAL INTERROGATORY NO. 12:
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 ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
14
PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES
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1 Procedure § 2017.010. Objection; this request is equally available to propounding party. See
2 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
3 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
4 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
5 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
6 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
7 the meaning of this interrogatory, Responding Party responds as follows:
8 None.
9 SPECIAL INTERROGATORY NO. 13:
10 State all modifications made by YOU to the UNIT.
11 RESPONSE TO SPECIAL INTERROGATORY NO. 13:
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 ofLos 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,
15
PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES
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1 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
2 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
3 the meaning of this interrogatory, Responding Party responds as follows:
4 None.
5 SPECIAL INTERROGATORY NO. 14:
6 IDENTIFY all dates on which YOU demanded DEFENDANTS to YOUR COMPLAINT
7 to make repairs in YOUR UNIT as YOU alleged in the COMPLAINT.
8 RESPONSE TO SPECIAL INTERROGATORY NO. 14:
9 Objection; this request is vague, ambiguous, overbroad, burdensome, and
10 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
11 407. Objection; the requested inspection request is not described with specificity. Objection;
12 this request violates the attorney-client and or attorney work product privileges and judicial
13 doctrines; all in direct violation of California Code of Civil Procedure§ 2017.010 and§
14 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
15 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
16 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
17 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
18 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not
19 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
20 be shown to compel such evasive inspection See Columbia Broadcasting System, Inc. v.
21 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
22 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See
23 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
24 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
25 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
26 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
27 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
28 the meaning of this interrogatory, Responding Party responds as follows:
16
PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES
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1 Upon information and belief, the Responding Party submitted complaints on a bi-
2 monthly frequency since in or around April 2018, to the Present.
3 SPECIAL INTERROGATORY NO. 15:
4 State each and every date YOU contend that the County of Kem Public Health Department
5 "Health Department," County of Kem Public Works Code Compliance "Code Enforcement,"
6 and/or the County of Kem Public Works Building Inspection "Building Department" inspected
7 the UNIT as alleged in the COMPLAINT.
8 RESPONSE TO SPECIAL INTERROGATORY NO. 15:
9 Objection; this request is vague, ambiguous, overbroad, burdensome, and
10 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
11 407. Objection; the requested inspection request is not described with specificity. Objection;
12 this request violates the attorney-client and or attorney work product privileges and judicial
13 doctrines; all in direct violation of California Code of Civil Procedure§ 2017.010 and§
14 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
15 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7, 10. Such protections are also embodied
16 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
17 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
18 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not
19 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
20 be shown to compel such evasive inspection See Columbia Broadcasting System, Inc. v.
21 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
22 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See
23 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
24 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
25 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
26 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
27 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to
28 the meaning of this interrogatory, Responding Party responds as follows:
17
PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES
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1 After a good faith effort to ascertain the dates, the Responding Party contends that the
2 dates are not readily available, nor ascertainable at the present time, and given the penalty of
3 perjury penalty, the Responding Party will not guess dates for which they have no concrete
4 backing or support thereof. Discovery is on-going, and future litigation and facts will confirm
5 these dates. The Responding Party is not waiving its rights to amend at a future time.
6 SPECIAL INTERROGATORY NO. 16:
7 Do you contend that the DEFENDANT received a citation(s) from the County of Kem
8 Public Health Department for the UNIT?
9 RESPONSE TO SPECIAL INTERROGATORY NO. 16:
10 Objection; this request is vague, ambiguous, overbroad, burdensome, and
11 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d
12 407. Objection; the requested inspection request is not described with specificity. Objection;
13 this request violates the attorney-client and or attorney work product privileges and judicial
14 doctrines; all in direct violation of California Code of Civil Procedure§ 2017.010 and§
15 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591,
16 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied
17 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior
18 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th
19 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not
20 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may
21 be shown to compel such evasive inspection See Columbia Broadcasting System, Inc. v.
22 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil
23 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See
24 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request
25 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787,
26 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain,
27 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and
28 Ill
18
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1 withou
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1 Karl P. Schlecht, Esq. (SBN 182294) Email: kschlecht@tresslerllp.com 2 Jihoon Kim, Esq. (SBN 289780) Email: jkim@tresslerllp.com 3 TRESSLER LLP 2 Park Plaza, Suite 1050 4 Irvine, California 92614 Telephone: (949) 336-1232 5 Fax: (949) 752-0645 6 Attorneys for Defendants, JENNIFER RUNYON, AN INDIVIDUAL and 7 WELCOME HOME PROPERTY MANAGEMENT, AN ENTITY 8 SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF KERN 9 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 v. 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 #4 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 #4 OF 4 28 1 DECLARATION OF KARL P. SCHLECHT IN SUPPORT OF DEFENDANTS’ MOTIONS TO COMPEL VOLUME #4 EXHIBITD.3 JACOB 0. PARTIYELI, ESQ. (SBN: 295967) 1 Law Office of Jacob 0. Partiyeli Complex Litigation Bureau 2 4751 Whittier Boulevard. Los Angeles, California. 90022 3 Phone:310-801-1919 Fax: 323-647-2387 4 E-service Email: complex@jacobfights.com 5 Attorney For Plaintiff 6 7 SUPERIOR COURT OF THE STATE OF CALIFORNIA 8 COUNTY OF KERN 9 10 NILKA COOKS, AN INDIVIDUAL, Case No. BCV-23-100822 11 Plaintiff, PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST 12 v. SET OF SPECIAL INTERROGATORIES 13 KRYSTAL WALLER, AN INDIVIDUAL; JENNIFER RUNYON, AN INDIVIDUAL; 14 PARS-15 LLC., A CALIFORNIA LIMITED LIABILITY COMPANY; WELCOME 15 HOME PROPERTY MANAGEMENT, AN ENTITY; AND DOES 1-100, INCLUSIVE, 16 Defendants. 17 18 PROPOUNDING PARTY: WELCOME HOME PROPERTY MANAGEMENT 19 RESPONDING PARTY: NILKACOOKS 20 SET NO: One 21 Ill 22 23 Ill 24 Ill 25 Ill 26 Ill 27 Ill 28 1 PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES Doc1D:97e29dc27d9f13620c3c6aa6a97509a743965e a 1 PRELIMINARY STATEMENT 2 This Preliminary Statement and all objections set forth herein apply to each response. To 3 the extent that response to said Request for Special Interrogatories have been previously provided 4 by this responding party, it is providing further responses in accommodation, and is not, nor has 5 it agreed to forfeit or otherwise waive any and all rights afforded it by statute, law or custom, 6 including but not limited to specific rights and options set forth in Code of Civil Procedures § 7 2030.010, et seq. 8 This Responding Party has not fully completed the investigation of the facts relating to 9 this case, has not fully completed discovery in this action, and has not completed its preparation 10 for trial. Discovery in this case is presently ongoing and it is anticipated that further discovery, 11 investigation, legal research, and analyses will supply facts and new meaning to the already 12 known facts, as well as establish entirely new factual conclusions and legal contentions, all of 13 which may lead to changes in, or variations from the contentions and response as set forth herein. 14 The following responses are made without prejudice to the responding party's right to produce 15 evidence of any subsequently investigated, discovered and/or analyzed evidence which the 16 responding party may later recall which pertains to or is otherwise relevant or responsive to the 17 discovery responded to herein. Responding Party has accordingly reserved the right to change any 18 and all answers herein as additional facts are ascertained, analyses are made, legal research is 19 completed, and contentions are formulated. The responses contained herein are made in good faith 20 effort to supply as much formulated. The responses contained herein made in good faith effort to 21 supply as much factual information and as much specification of legal contention as is presently 22 known. 23 In setting forth these responses, Responding Party does not waive rights afforded by the 24 attorney work product privilege, attorney work product doctrine, or other privilege or immunity 25 from disclosure which may attach to information called forth in, or responsive to, any 26 Interrogatories, or, in responding to all or any portion of any Interrogatories, or the subject matter 27 to which the Interrogatory refers. 28 Ill 2 PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES Doc1D:97e29dc27d9f13620c3c6aa6a97509a743965e a 1 These responses are submitted by Responding Party subject to, and without in any way 2 waiving or intending to waive, but on the contrary, intending to reserve and reserving; 3 (1) All questions as to competency, materiality, privilege and admissibility as 4 evidenced for any purpose of any of the documents referred to or further response are given, or 5 the subject matter thereof, in any subsequent proceeding in, or trial of, this action or any other 6 action or proceeding; 7 (2) The right to object to other discovery procedures involving or relating to the 8 subject matter of the Interrogatories herein responded to, including any Interrogatory specifically 9 identified herein; and 10 (3) The right at any time to revise, correct, add to, or clarify any of the responses set 11 forth herein, or documents produced or referred herein. 12 Ill 13 Plaintiff, NILKA COOKS, (hereinafter referred to as "Plaintiff' or "Responding Party") 14 hereby responds and objects to the Amended First Set of Special Interrogatories, Set One, 15 propounded by Defendant, WELCOME HOME PROPERTY MANAGEMENT, (hereinafter 16 referred to as "Defendant" or "Propounding Party,") as follows: 17 RESPONSES TO SPECIAL INTERROGATORIES 18 SPECIAL INTERROGATORY NO. 1: 19 IDENTIFY all individuals that reside(d) at the UNIT during the duration of your lease 20 agreement with DEFENDANT. ("IDENTIFY" "IDENTITY," or "IDENTIFICATION" when 21 used in conjunction with: (1) an individual, requires YOU to state the individual's full name, last 22 known home address, last known home and business telephone numbers, present or last known 23 business affiliation or employer, business address and job title, exact or approximate date and 24 place of death if deceased; (2) a PERSON other than an individual, requires YOU to state its 25 name, address and telephone number and the name of the principal individuals with knowledge 26 of the subject matter of these requests; and (3) a DOCUMENT, requires YOU to state the type of 27 document, its date of creation, the full name of the author, all recipients thereof, subject matter, 28 number of pages, and the full names of each person who (to the best of Plaintiffs knowledge and 3 PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES Doc1D:97e29dc27d9f13620c3c6aa6a97509a743965e a 1 belief) has seen such document (including copies thereof) or has knowledge of the subject matter 2 or context thereof.) ("UNIT" shall be defined as the premises described in the lease entered into 3 between the Plaintiff, NILKA COOKS and Defendant WELCOME HOME PROPERTY 4 MANAGEMENT, INC, located at 3400 15th Street West, Unit 91, Rosamond, California 93560.) 5 (YOU" or "YOUR(S)" refers to Plaintiff, NILKA COOKS, an individual, and includes her 6 attorneys, investigators, and anyone else acting on her behalf.) ("DEFENDANT" shall mean and 7 refer to defendant, JENNIFER RUNYON, or any individual, entity, agent, employee, officer or 8 representative acting on its behalf.) ("Property" shall be defined as the entire apartment complex 9 located at 3400 15th Street West, Rosamond, California 93560) ("COMPLAINT" shall refer to 10 the verified complaint entitled Nilka Cooks, an Individual, vs. Krystal Waller, et.al., filed on 11 March 17, 2023, in Kem County Superior Court, Case No. BCV-23-100822.) 12 RESPONSE TO SPECIAL INTERROGATORY NO. 1: 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 ofLos 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, 4 PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES Doc1D:97e29dc27d9f13620c3c6aa6a97509a743965e a 1 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, 2 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and 3 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to 4 the meaning of this interrogatory, Responding Party responds as follows: 5 1. Nilka Cooks. 3400 15th Street West. Apartment 91. Rosamond, California. 93560. 6 (360) 980-7089. 7 SPECIAL INTERROGATORY NO. 2: 8 For each of the individuals identified in Special Interrogatory No. 1, state the duration and 9 dates on which they reside(d) at the UNIT. 10 RESPONSE TO SPECIAL INTERROGATORY NO. 2: 11 Objection; this request is vague, ambiguous, overbroad, burdensome, and 12 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 13 407. Objection; the requested inspection request is not described with specificity. Objection; 14 this request violates the attorney-client and or attorney work product privileges and judicial 15 doctrines; all in direct violation of California Code of Civil Procedure§ 2017.010 and§ 16 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 17 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 18 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 19 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 20 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not 21 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may 22 be shown to compel such evasive inspection See Columbia Broadcasting System, Inc. v. 23 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil 24 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See 25 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request 26 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 27 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, 28 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and 5 PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES Doc1D:97e29dc27d9f13620c3c6aa6a97509a743965e a 1 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to 2 the meaning of this interrogatory, Responding Party responds as follows: 3 1. In or around April 2018, to the Present. 4 SPECIAL INTERROGATORY NO. 3: 5 State, if any, the breed and species of any PETS kept by YOU at the UNIT. ("PETS" shall 6 mean any domesticated or tamed animal.) 7 RESPONSE TO SPECIAL INTERROGATORY NO. 3: 8 Objection; this request is vague, ambiguous, overbroad, burdensome, and 9 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 10 407. Objection; the requested inspection request is not described with specificity. Objection; 11 this request violates the attorney-client and or attorney work product privileges and judicial 12 doctrines; all in direct violation of California Code of Civil Procedure§ 2017.010 and§ 13 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 14 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 15 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 16 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 17 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not 18 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may 19 be shown to compel such evasive inspection See Columbia Broadcasting System, Inc. v. 20 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil 21 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See 22 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request 23 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 24 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, 25 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and 26 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to 27 the meaning of this interrogatory, Responding Party responds as follows: 28 None. 6 PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES Doc1D:97e29dc27d9f13620c3c6aa6a97509a743965e a 1 SPECIAL INTERROGATORY NO. 4: 2 State, if any, the COMMERICAL ACTIVITY conducted by YOU at the UNIT. 3 ("COMMERICAL ACTIVITY'' shall mean an activity intended for exchange in the market to 4 earn an economic profit.) 5 RESPONSE TO SPECIAL INTERROGATORY NO. 4: 6 Objection; this request is vague, ambiguous, overbroad, burdensome, and 7 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 8 407. Objection; the requested inspection request is not described with specificity. Objection; 9 this request violates the attorney-client and or attorney work product privileges and judicial 10 doctrines; all in direct violation of California Code of Civil Procedure§ 2017.010 and§ 11 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 12 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 13 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 14 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 15 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not 16 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may 17 be shown to compel such evasive inspection See Columbia Broadcasting System, Inc. v. 18 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil 19 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See 20 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request 21 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 22 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, 23 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and 24 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to 25 the meaning of this interrogatory, Responding Party responds as follows: 26 None. 27 Ill 28 Ill 7 PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES Doc1D:97e29dc27d9f13620c3c6aa6a97509a743965e a 1 SPECIAL INTERROGATORY NO. 5: 2 State, if any, the ILLEGAL ACTIVITY conducted by YOU at the UNIT. ("ILLEGAL 3 ACTIVITY" shall mean an activity carried out for illegal purposes under United States Law, 4 California State Law, and/or under any other applicable law(s).) 5 RESPONSE TO SPECIAL INTERROGATORY NO. 5: 6 Objection; this request is vague, ambiguous, overbroad, burdensome, and 7 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 8 407. Objection; the requested inspection request is not described with specificity. Objection; 9 this request violates the attorney-client and or attorney work product privileges and judicial 10 doctrines; all in direct violation of California Code of Civil Procedure§ 2017.010 and§ 11 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 12 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 13 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 14 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 15 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not 16 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may 17 be shown to compel such evasive inspection See Columbia Broadcasting System, Inc. v. 18 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil 19 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See 20 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request 21 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 22 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, 23 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and 24 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to 25 the meaning of this interrogatory, Responding Party responds as follows: 26 None. 27 Ill 28 Ill 8 PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES Doc1D:97e29dc27d9f13620c3c6aa6a97509a743965e a 1 SPECIAL INTERROGATORY NO. 6: 2 State, if any, the ILLICIT ACTIVITY conducted by YOU at the UNIT. ("ILLICIT 3 ACTIVITY" shall mean an activity considered to be improper or socially forbidden; they may or 4 may not be illegal but go against social norms and values.) 5 RESPONSE TO SPECIAL INTERROGATORY NO. 6: 6 Objection; this request is vague, ambiguous, overbroad, burdensome, and 7 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 8 407. Objection; the requested inspection request is not described with specificity. Objection; 9 this request violates the attorney-client and or attorney work product privileges and judicial 10 doctrines; all in direct violation of California Code of Civil Procedure§ 2017.010 and§ 11 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 12 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 13 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 14 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 15 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not 16 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may 17 be shown to compel such evasive inspection See Columbia Broadcasting System, Inc. v. 18 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil 19 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See 20 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request 21 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 22 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, 23 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and 24 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to 25 the meaning of this interrogatory, Responding Party responds as follows: 26 None. 27 SPECIAL INTERROGATORY NO. 7: 28 Identify the duration and the dates in which YOU resided at the PROPERTY. 9 PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES Doc1D:97e29dc27d9f13620c3c6aa6a97509a743965e a 1 RESPONSE TO SPECIAL INTERROGATORY NO. 7: 2 Objection; this request is vague, ambiguous, overbroad, burdensome, and 3 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 4 407. Objection; the requested inspection request is not described with specificity. Objection; 5 this request violates the attorney-client and or attorney work product privileges and judicial 6 doctrines; all in direct violation of California Code of Civil Procedure§ 2017.010 and§ 7 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 8 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7, 10. Such protections are also embodied 9 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 10 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 11 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not 12 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may 13 be shown to compel such evasive inspection See Columbia Broadcasting System, Inc. v. 14 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil 15 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See 16 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request 17 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 18 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, 19 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and 20 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to 21 the meaning of this interrogatory, Responding Party responds as follows: 22 In or around April 2018, to the Present. 23 SPECIAL INTERROGATORY NO. 8: 24 State whether you were in possession and control of the UNIT during the entire duration 25 of YOUR lease for the UNIT. 26 RESPONSE TO SPECIAL INTERROGATORY NO. 8: 27 Objection; this request is vague, ambiguous, overbroad, burdensome, and 28 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 10 PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES Doc1D:97e29dc27d9f13620c3c6aa6a97509a743965e a 1 407. Objection; the requested inspection request is not described with specificity. Objection; 2 this request violates the attorney-client and or attorney work product privileges and judicial 3 doctrines; all in direct violation of California Code of Civil Procedure§ 2017.010 and§ 4 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 5 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 6 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 7 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 8 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not 9 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may 10 be shown to compel such evasive inspection See Columbia Broadcasting System, Inc. v. 11 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil 12 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See 13 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request 14 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 15 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, 16 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and 17 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to 18 the meaning of this interrogatory, Responding Party responds as follows: 19 Yes. 20 SPECIAL INTERROGATORY NO. 9: 21 IDENTIFY, if any, any sublease agreement for the UNIT that YOU were a party to. 22 RESPONSE TO SPECIAL INTERROGATORY NO. 9: 23 Objection; this request is vague, ambiguous, overbroad, burdensome, and 24 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 25 407. Objection; the requested inspection request is not described with specificity. Objection; 26 this request violates the attorney-client and or attorney work product privileges and judicial 27 doctrines; all in direct violation of California Code of Civil Procedure§ 2017.010 and§ 28 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 11 PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES Doc1D:97e29dc27d9f13620c3c6aa6a97509a743965e a 1 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 2 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 3 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 4 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not 5 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may 6 be shown to compel such evasive inspection See Columbia Broadcasting System, Inc. v. 7 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil 8 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See 9 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request 10 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 11 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, 12 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and 13 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to 14 the meaning of this interrogatory, Responding Party responds as follows: 15 None. 16 SPECIAL INTERROGATORY NO. 10: 17 IDENTIFY, if any, any contractual agreements regarding the UNIT that YOU were a party 18 to. 19 RESPONSE TO SPECIAL INTERROGATORY NO. 10: 20 Objection; this request is vague, ambiguous, overbroad, burdensome, and 21 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 22 407. Objection; the requested inspection request is not described with specificity. Objection; 23 this request violates the attorney-client and or attorney work product privileges and judicial 24 doctrines; all in direct violation of California Code of Civil Procedure§ 2017.010 and§ 25 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 26 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 27 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 28 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 12 PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES Doc1D:97e29dc27d9f13620c3c6aa6a97509a743965e a 1 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not 2 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may 3 be shown to compel such evasive inspection See Columbia Broadcasting System, Inc. v. 4 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil 5 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See 6 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request 7 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 8 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, 9 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and 10 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to 11 the meaning of this interrogatory, Responding Party responds as follows: 12 The Responding Party contends that there is a written lease agreement that was signed in 13 or around April 2018. 14 SPECIAL INTERROGATORY NO. 11: 15 State all YOUR efforts to maintain the UNIT. 16 RESPONSE TO SPECIAL INTERROGATORY NO. 11: 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. 13 PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES Doc1D:97e29dc27d9f13620c3c6aa6a97509a743965e a 1 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil 2 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See 3 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request 4 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 5 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, 6 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and 7 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to 8 the meaning of this interrogatory, Responding Party responds as follows: 9 The Responding Party consistently communicates concerns to the owners and overseers 10 of the premises approximately every two weeks. Additionally, the Responding Party purchases 11 cockroach repellent products on a monthly basis and strategically deploys these items within the 12 residence in an effort to mitigate the presence of cockroaches. 13 SPECIAL INTERROGATORY NO. 12: 14 State all YOUR efforts to repair the UNIT. 15 RESPONSE TO SPECIAL INTERROGATORY NO. 12: 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 ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil 14 PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES Doc1D:97e29dc27d9f13620c3c6aa6a97509a743965e a 1 Procedure § 2017.010. Objection; this request is equally available to propounding party. See 2 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request 3 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 4 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, 5 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and 6 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to 7 the meaning of this interrogatory, Responding Party responds as follows: 8 None. 9 SPECIAL INTERROGATORY NO. 13: 10 State all modifications made by YOU to the UNIT. 11 RESPONSE TO SPECIAL INTERROGATORY NO. 13: 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 ofLos 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, 15 PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES Doc1D:97e29dc27d9f13620c3c6aa6a97509a743965e a 1 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and 2 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to 3 the meaning of this interrogatory, Responding Party responds as follows: 4 None. 5 SPECIAL INTERROGATORY NO. 14: 6 IDENTIFY all dates on which YOU demanded DEFENDANTS to YOUR COMPLAINT 7 to make repairs in YOUR UNIT as YOU alleged in the COMPLAINT. 8 RESPONSE TO SPECIAL INTERROGATORY NO. 14: 9 Objection; this request is vague, ambiguous, overbroad, burdensome, and 10 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 11 407. Objection; the requested inspection request is not described with specificity. Objection; 12 this request violates the attorney-client and or attorney work product privileges and judicial 13 doctrines; all in direct violation of California Code of Civil Procedure§ 2017.010 and§ 14 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 15 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 16 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 17 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 18 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not 19 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may 20 be shown to compel such evasive inspection See Columbia Broadcasting System, Inc. v. 21 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil 22 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See 23 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request 24 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 25 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, 26 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and 27 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to 28 the meaning of this interrogatory, Responding Party responds as follows: 16 PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES Doc1D:97e29dc27d9f13620c3c6aa6a97509a743965e a 1 Upon information and belief, the Responding Party submitted complaints on a bi- 2 monthly frequency since in or around April 2018, to the Present. 3 SPECIAL INTERROGATORY NO. 15: 4 State each and every date YOU contend that the County of Kem Public Health Department 5 "Health Department," County of Kem Public Works Code Compliance "Code Enforcement," 6 and/or the County of Kem Public Works Building Inspection "Building Department" inspected 7 the UNIT as alleged in the COMPLAINT. 8 RESPONSE TO SPECIAL INTERROGATORY NO. 15: 9 Objection; this request is vague, ambiguous, overbroad, burdensome, and 10 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 11 407. Objection; the requested inspection request is not described with specificity. Objection; 12 this request violates the attorney-client and or attorney work product privileges and judicial 13 doctrines; all in direct violation of California Code of Civil Procedure§ 2017.010 and§ 14 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 15 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7, 10. Such protections are also embodied 16 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 17 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 18 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not 19 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may 20 be shown to compel such evasive inspection See Columbia Broadcasting System, Inc. v. 21 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil 22 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See 23 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request 24 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 25 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, 26 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and 27 without waiving the foregoing, and pursuant to the understanding of the Responding Party as to 28 the meaning of this interrogatory, Responding Party responds as follows: 17 PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES Doc1D:97e29dc27d9f13620c3c6aa6a97509a743965e a 1 After a good faith effort to ascertain the dates, the Responding Party contends that the 2 dates are not readily available, nor ascertainable at the present time, and given the penalty of 3 perjury penalty, the Responding Party will not guess dates for which they have no concrete 4 backing or support thereof. Discovery is on-going, and future litigation and facts will confirm 5 these dates. The Responding Party is not waiving its rights to amend at a future time. 6 SPECIAL INTERROGATORY NO. 16: 7 Do you contend that the DEFENDANT received a citation(s) from the County of Kem 8 Public Health Department for the UNIT? 9 RESPONSE TO SPECIAL INTERROGATORY NO. 16: 10 Objection; this request is vague, ambiguous, overbroad, burdensome, and 11 oppressive. See West v. Pico Furniture Co. v. Superior Court (1961) 56 Cal. 2d 12 407. Objection; the requested inspection request is not described with specificity. Objection; 13 this request violates the attorney-client and or attorney work product privileges and judicial 14 doctrines; all in direct violation of California Code of Civil Procedure§ 2017.010 and§ 15 2018.030, and Evidence Code section 950. See Mitchell v. Superior Court (1984) 37 Cal.3d 591, 16 601; Mack v. Superior Court (1968) 259 Cal.App. 2d 7,10. Such protections are also embodied 17 within Article I, Section 1 of the California Constitution. See also, Soltani-Rastegar v. Superior 18 Court (1989) 208 Cal.App. 3d 424; Garstang v. Superior Court (1995) 39 Cal.App. 4th 19 526; Roberts v. Gulf Oil Corp. (1983) 147 Cal.App. 3d 770, 798. Objection; this request is not 20 reasonably calculated to lead to the discovery of admissible evidence, and no good cause may 21 be shown to compel such evasive inspection See Columbia Broadcasting System, Inc. v. 22 Superior Court ofLos Angeles County (1968) 263 Cal.App. 2d 12, 19; California Code of Civil 23 Procedure§ 2017.010. Objection; this request is equally available to propounding party. See 24 Alpine Mutual Water Co. v. Superior Court (1968) 259 Cal.App. 2d 45. Objection; this request 25 is so overbroad as to constitute oppression. See Romero v. Hern (1969) 276 Cal. 2d 787, 26 794; Britt v. Superior Court (1978) 20 Cal. 3d 844, 860. Objection; this request is uncertain, 27 ambiguous, and confusing. See Deyo v. Kilbourne (1978) 84 Cal. 3d 771, 783. Subject to and 28 Ill 18 PLAINTIFF'S RESPONSES TO DEFENDANT'S AMENDED FIRST SET OF SPECIAL INTERROGATORIES Doc1D:97e29dc27d9f13620c3c6aa6a97509a743965e a 1 withou