Discovery Strategy For Msj

Summary

In a breach of lease case, crafting special interrogatories can help gather evidence for a Motion for Summary Judgment (MSJ). Consider asking about compliance with Los Angeles Rent Stabilization Ordinance (LARSO) notice requirements, knowledge of notice postings, and documentation of late fees. Additional questions can focus on instances of waived late fees, tenant complaints, and communications regarding alleged breaches or retaliation. Tailor these questions to uncover evidence that supports your case strategy and addresses potential landlord retaliation.

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can you create more questions regarding retaliation and late fees
Here are a few additional special interrogatories you might consider regarding retaliation and late fees:
*. Interrogatory No. *: Describe any instances where you have waived or altered late fees for this tenant or other tenants, and explain the circumstances of each instance.
*. Interrogatory No. *: Detail any complaints or grievances filed by the tenant regarding the property or management practices in the last two years.
*. Interrogatory No. *: Provide all written communications with the tenant concerning alleged breaches of lease, including any mentions of retaliation.
*. Interrogatory No. *: State any changes in the tenant’s rental terms or conditions after the alleged breach of lease was reported.
*. Interrogatory No. *: Describe your policy and practice for addressing tenant complaints about landlord retaliation, if any, and provide examples.
These questions aim to gather information that might demonstrate a pattern of retaliation or inconsistent application of late fees. Tailor them as needed for your case.