UD-106 Form Interrogatories—Unlawful Detainer

Source: https://www.courts.ca.gov/documents/ud106.pdf

DISC-003/UD-106 ATTORNEY OR PARTY WITHOUT ATTORNEY STATE BAR NUMBER: UNLAWFUL DETAINER ASSISTANT NAME: (Check one box): An unlawful detainer assistant FIRM NAME: did did not for compensation give advice or STREET ADDRESS: assistance with this form. (If one did, state the following): CITY: STATE: ZIP CODE: ASSISTANT'S NAME: ATTORNEY FOR (name): ADDRESS: SUPERIOR COURT OF CALIFORNIA, COUNTY OF:

TEL. NO:

COUNTY OF REGISTRATION:

SHORT TITLE: REGISTRATION NO.: EXPIRES (DATE): FORM INTERROGATORIES—UNLAWFUL DETAINER CASE NUMBER: Asking Party: Answering Party: Set No.:

Sec. 1. Instructions to All Parties (c) Each answer must be as complete and straightforward as (a) These are general instructions. For time limitations, the information reasonably available to you permits. If an requirements for service on other parties, and other details, interrogatory cannot be answered completely, answer it to see Code of Civil Procedure sections 2030.010-2030.410 the extent possible. and the cases construing those sections. (d) If you do not have enough personal knowledge to fully answer an interrogatory, say so, but make a reasonable (b) These interrogatories do not change existing law relating to and good faith effort to get the information by asking other interrogatories nor do they affect an answering party's right persons or organizations, unless the information is equally to assert any privilege or objection. available to the asking party. Sec. 2. Instructions to the Asking Party (e) Whenever an interrogatory may be answered by referring to a document, the document may be attached as an (a) These interrogatories are designed for optional use in exhibit to the response and referred to in the response. If unlawful detainer proceedings. the document has more than one page, refer to the page (b) There are restrictions that generally limit the number of and section where the answer to the interrogatory can be interrogatories that may be asked and the form and use of found. the interrogatories. For details, read Code of Civil (f) Whenever an address and telephone number for the same Procedure sections 2030.030–2030.070. person are requested in more than one interrogatory, you (c) In determining whether to use these or any interrogatories, are required to furnish them in answering only the first you should be aware that abuse can be punished by interrogatory asking for that information. sanctions, including fines and attorney fees. See Code of (g) Your answers to these interrogatories must be verified, Civil Procedure section 128.7. dated, and signed. You may wish to use the following form (d) Check the box next to each interrogatory that you want the at the end of your answers: answering party to answer. Use care in choosing those interrogatories that are applicable to the case. I declare under penalty of perjury under the laws of the State of California that the foregoing answers are true and correct. (e) Additional interrogatories may be attached. Sec. 3. Instructions to the Answering Party (DATE) (SIGNATURE) (a) An answer or other appropriate response must be given to each interrogatory checked by the asking party. Failure to Sec. 4. Definitions respond to these interrogatories properly can be punished by sanctions, including contempt proceedings, fine, Words in BOLDFACE CAPITALS in these interrogatories are attorneys fees, and the loss of your case. See Code of Civil defined as follows: Procedure sections 128.7 and 2030.300. (a) PERSON includes a natural person, firm, association, (b) As a general rule, within five days after you are served organization, partnership, business, trust, corporation, or with these interrogatories, you must serve your responses public entity. on the asking party and serve copies of your responses on all other parties to the action who have appeared. See (b) PLAINTIFF includes any PERSON who seeks recovery of Code of Civil Procedure sections 2030.260–2030.270 for the RENTAL UNIT whether acting as an individual or on details. someone else's behalf and includes all such PERSONS if more than one.

Form Approved for Judicial Council of California Optional Use FORM INTERROGATORIES—UNLAWFUL DETAINER §§ 2030.010-2030.410,Code of Civil Procedure,2033.710 DISC-003/UD-106 [Rev. January 1, 2014] www.courts.ca.gov

DISC-003/UD-106 (c) LANDLORD includes any PERSON who offered the 70.2 Is PLAINTIFF an owner of the RENTAL UNIT? If so, RENTAL UNIT for rent and any PERSON on whose behalf state: the RENTAL UNIT was offered for rent and their (a) the nature and percentage of ownership interest; successors in interest. LANDLORD includes all PERSONS (b) the date PLAINTIFF first acquired this ownership who managed the PROPERTY while defendant was in interest. possession. 70.3 Does PLAINTIFF share ownership or lack owner- (d) RENTAL UNIT is the premises PLAINTIFF seeks to ship? If so, state the name, the ADDRESS, and the nature recover. and percentage of ownership interest of each owner. (e) PROPERTY is the building or parcel (including common 70.4 Does PLAINTIFF claim the right to possession other areas) of which the RENTAL UNIT is a part. (For example, than as an owner of the RENTAL UNIT? If so, state the if PLAINTIFF is seeking to recover possession of basis of the claim. apartment number 12 of a 20-unit building, the building is the PROPERTY and apartment 12 is the RENTAL UNIT. If 70.5 Has PLAINTIFF'S interest in the RENTAL UNIT PLAINTIFF seeks possession of cottage number 3 in a changed since acquisition? If so, state the nature and five- cottage court or complex, the court or complex is the dates of each change. PROPERTY and cottage 3 is the RENTAL UNIT.) 70.6 Are there other rental units on the PROPERTY? If so, (f) DOCUMENT means a writing, as defined in Evidence state how many. Code section 250, and includes the original or a copy of 70.7 During the 12 months before this proceeding was handwriting, typewriting, printing, photostating, photo- filed, did PLAINTIFF possess a permit or certificate of graphing, electronically stored information, and every other occupancy for the RENTAL UNIT? If so, for each state: means of recording upon any tangible thing and form of (a) the name and ADDRESS of each PERSON named on communicating or representation, including letters, words, the permit or certificate; pictures, sounds, or symbols, or combinations of them. (b) the dates of issuance and expiration; (g) NOTICE TO QUIT includes the original or copy of any (c) the permit or certificate number notice mentioned in Code of Civil Procedure section 1161 70.8 Has a last month's rent, security deposit, cleaning fee, or Civil Code section 1946, including a 3-day notice to pay rental agency fee, credit check fee, key deposit, or any rent and quit the RENTAL UNIT, a 3-day notice to perform other deposit been paid on the RENTAL UNIT? If so, for conditions or covenants or quit, a 3-day notice to quit, and each item state: a 30-day notice of termination. (a) the purpose of the payment; (h) ADDRESS means the street address, including the city, (b) the date paid; state, and zip code. (c) the amount; Sec. 5. Interrogatories (d) the form of payment; (e) the name of the PERSON paying;The following interrogatories have been approved by the Judicial (f) the name of the PERSON to whom it was paid;Council under section 2033.710 of the Code of Civil Procedure (g) any DOCUMENT which evidences payment and thefor use in unlawful detainer proceedings: name, ADDRESS, and telephone number of each CONTENTS PERSON who has the DOCUMENT; 70.0 General (h) any adjustments or deductions including facts. 71.0 Notice 70.9 State the date defendant first took possession of the 72.0 Service RENTAL UNIT. 73.0 Malicious Holding Over 70.10 State the date and all the terms of any rental 74.0 Rent Control and Eviction Control agreement between defendant and the PERSON who 75.0 Breach of Warranty to Provide Habitable Premises

RENTAL UNIT. 73.0 Malicious Holding Over
70.10 State the date and all the terms of any rental 74.0 Rent Control and Eviction Control
agreement between defendant and the PERSON who 75.0 Breach of Warranty to Provide Habitable Premises
rented to defendant. 76.0 Waiver, Change, Withdrawal, or Cancellation of Notice
to Quit 70.11 For each agreement alleged in the pleadings:

77.0 Retaliation and Arbitrary Discrimination (a) identify all DOCUMENTS that are part of the 78.0 Nonperformance of the Rental Agreement by Landlord agreement and for each state the name, ADDRESS, 79.0 Offer of Rent by Defendant and telephone number of each PERSON who has the DOCUMENT; 80.0 Deduction from Rent for Necessary Repairs (b) state each part of the agreement not in writing, the 81.0 Fair Market Rental Value name, ADDRESS, and telephone number of each PERSON agreeing to that provision, and the date that70.0 General part of the agreement was made; [Either party may ask any applicable question in this section.] (c) identify all DOCUMENTS that evidence each part of 70.1 State the name, ADDRESS, telephone number, and the agreement not in writing and for each state the relationship to you of each PERSON who prepared or name, ADDRESS, and telephone number of each assisted in the preparation of the responses to these PERSON who has the DOCUMENT; interrogatories. (Do not identify anyone who simply typed or (d) identify all DOCUMENTS that are part of each reproduced the responses.) modification to the agreement, and for each state the name, ADDRESS, and telephone number of each PERSON who has the DOCUMENT (see also §71.5); DISC-003/UD-106 [Rev. January 1, 2014] FORM INTERROGATORIES—UNLAWFUL DETAINER Page 2 of 7

DISC-003/UD-106 (e) state each modification not in writing, the date, and the (b) state the names, ADDRESSES, and telephone name, ADDRESS, and telephone number of the numbers of all PERSONS who have knowledge of the PERSON agreeing to the modification, and the date facts; the modification was made (see also §71.5). (c) identify all DOCUMENTS that support the facts and state the name, ADDRESS, and telephone number of (f) identify all DOCUMENTS that evidence each each PERSON who has each DOCUMENT. modification of the agreement not in writing and for each state the name, ADDRESS, and telephone 71.3 List all rent payments and rent credits made or number of each PERSON who has the DOCUMENT claimed by or on behalf of defendant beginning 12 months (see also §71.5). before the NOTICE TO QUIT was served. For each payment or credit state: 70.12 Has any PERSON acting on the PLAINTIFF'S behalf (a) the amount; been responsible for any aspect of managing or (b) the date received; maintaining the RENTAL UNIT or PROPERTY? If so, for (c) the form in which any payment was made; each PERSON state: (d) the services performed or other basis for which a credit (a) the name, ADDRESS, and telephone number; is claimed; (b) the dates the PERSON managed or maintained the (e) the period covered; RENTAL UNIT or PROPERTY; (f) the name of each PERSON making the payment or (c) the PERSON'S responsibilities. earning the credit; (g) the identity of all DOCUMENTS evidencing the 70.13 For each PERSON who occupies any part of the payment or credit and for each state the name, RENTAL UNIT (except occupants named in the complaint ADDRESS, and telephone number of each PERSON and occupants' children under 17) state: who has the DOCUMENT. (a) the name, ADDRESS, telephone number, and 71.4 Did defendant ever fail to pay the rent on time? If so, birthdate; for each late payment state: (b) the inclusive dates of occupancy; (a) the date; (c) a description of the portion of the RENTAL UNIT (b) the amount of any late charge; occupied; (c) the identity of all DOCUMENTS recording the payment (d) the amount paid, the term for which it was paid, and and for each state the name, ADDRESS, and the person to whom it was paid; telephone number of each PERSON who has the (e) the nature of the use of the RENTAL UNIT; DOCUMENT. (f) the name, ADDRESS, and telephone number of the 71.5 Since the beginning of defendant's tenancy, has person who authorized occupancy; PLAINTIFF ever raised the rent? If so, for each rent (g) how occupancy was authorized, including failure of the increase state: LANDLORD or PLAINTIFF to protest after discovering (a) the date the increase became effective; the occupancy. (b) the amount; (c) the reasons for the rent increase; 70.14 Have you or anyone acting on your behalf obtained (d) how and when defendant was notified of the increase; any DOCUMENT concerning the tenancy between any (e) the identity of all DOCUMENTS evidencing the occupant of the RENTAL UNIT and any PERSON with an increase and for each state the name, ADDRESS, and ownership interest or managerial responsibility for the telephone number of each PERSON who has the RENTAL UNIT? If so, for each DOCUMENT state: DOCUMENT. (a) the name, ADDRESS, and telephone number of each [See also section 70.11 (d) - (f).] individual from whom the DOCUMENT was obtained; 71.6 During the 12 months before the NOTICE TO QUIT (b) the name, ADDRESS, and telephone number of each was served was there a period during which there was no individual who obtained the DOCUMENT; permit or certificate of occupancy for the RENTAL UNIT? If so, for each period state: (c) the date the DOCUMENT was obtained; (a) the inclusive dates; (d) the name, ADDRESS, and telephone number of each

cy for the RENTAL UNIT? If so, for each period state: (c) the date the DOCUMENT was obtained; (a) the inclusive dates; (d) the name, ADDRESS, and telephone number of each (b) the reasons. PERSON who has the DOCUMENT (original or copy). 71.7 Has any PERSON ever reported any nuisance or 71.0 Notice disturbance at or destruction of the RENTAL UNIT or [If a defense is based on allegations that the 3-day notice or 30- PROPERTY caused by defendant or other occupant of the day NOTICE TO QUIT is defective in form or con-tent, then either RENTAL UNIT or their guests? If so, for each report state: party may ask any applicable question in this section.] (a) a description of the disturbance or destruction; (b) the date of the report; 71.1 Was the NOTICE TO QUIT on which PLAINTIFF (c) the name of the PERSON who reported; bases this proceeding attached to the complaint? If not, (d) the name of the PERSON to whom the report was state the contents of this notice. made; (e) what action was taken as a result of the report; 71.2 State all reasons that the NOTICE TO QUIT was (f) the identity of all DOCUMENTS evidencing the report served and for each reason: and for each state the name, ADDRESS, and (a) state all facts supporting PLAINTIFF'S decision to telephone number of each PERSON who has each terminate defendant's tenancy; DOCUMENT. DISC-003/UD-106 [Rev. January 1, 2014] FORM INTERROGATORIES—UNLAWFUL DETAINER Page 3 of 7

DISC-003/UD-106 71.8 Does the complaint allege violation of a term of a 73.0 Malicious Holding Over rental agreement or lease (other than nonpayment of rent)? [If a defendant denies allegations that defendant's continued If so, for each covenant: possession is malicious, then either party may ask any applicable (a) identify the covenant breached; question in this section. Additional questions in section 75.0 may (b) state the facts supporting the allegation of a breach; also be applicable.] (c) state the names, ADDRESSES, and telephone 73.1 If any rent called for by the rental agreement is numbers of all PERSONS who have knowledge of the unpaid, state the reasons and the facts upon which the facts; reasons are based. 73.2 Has defendant made attempts to secure other (d) identify all DOCUMENTS that support the facts and state the name, ADDRESS, and telephone number of premises since the service of the NOTICE TO QUIT or since the service of the summons and complaint? If so, for each PERSON who has each DOCUMENT. each attempt: 71.9 Does the complaint allege that the defendant has (a) state all facts indicating the attempt to secure other been using the RENTAL UNIT for an illegal purpose? If so, premises; for each purpose: (b) state the names, ADDRESSES, and telephone (a) identify the illegal purpose; numbers of all PERSONS who have knowledge of the (b) state the facts supporting the allegations of illegal use; facts; (c) state the names, ADDRESSES, and telephone (c) identify all DOCUMENTS that support the facts and numbers of all PERSONS who have knowledge of the state the name, ADDRESS, and telephone number of facts; each PERSON who has each DOCUMENT. 73.3 State the facts upon which PLAINTIFF bases the (d) identify all DOCUMENTS that support the facts and allegation of malice. state the name, ADDRESS, and telephone number of each PERSON who has each DOCUMENT. 74.0 Rent Control and Eviction Control 74.1 Is there an ordinance or other local law in this [Additional interrogatories on this subject may be found in jurisdiction which limits the right to evict tenants? If your sections 75.0, 78.0, 79.0, and 80.0.] answer is no, you need not answer sections 74.2 through 72.0 Service 74.6. [If a defense is based on allegations that the NOTICE TO QUIT 74.2 For the ordinance or other local law limiting the right to was defectively served, then either party may ask any applicable evict tenants, state: question in this section.] (a) the title or number of the law; 72.1 Does defendant contend (or base a defense or make (b) the locality. any allegations) that the NOTICE TO QUIT was defectively 74.3 Do you contend that the RENTAL UNIT is exempt served? If the answer is "no", do not answer from the eviction provisions of the ordinance or other local interrogatories 72.2 through 72.3. law identified in section 74.2? If so, state the facts upon which you base your contention. 72.2 Does PLAINTIFF contend that the NOTICE TO QUIT 74.4 Is this proceeding based on allegations of a need to referred to in the complaint was served? If so, state: recover the RENTAL UNIT for use of the LANDLORD or the landlord's relative? If so, for each intended occu-pant (a) the kind of notice; state: (b) the date and time of service; (a) the name; (c) the manner of service; (b) the residence ADDRESSES from three years ago to (d) the name and ADDRESS of the person who served it: the present; (e) a description of any DOCUMENT or conversation (c) the relationship to the LANDLORD; between defendant and the person who served the (d) all the intended occupant's reasons for occupancy; notice. (e) all rental units on the PROPERTY that were vacated within 60 days before and after the date the NOTICE 72.3 Did any person receive the NOTICE TO QUIT referred TO QUIT was served. to in the complaint? If so, for each copy of

ce. (e) all rental units on the PROPERTY that were vacated within 60 days before and after the date the NOTICE 72.3 Did any person receive the NOTICE TO QUIT referred TO QUIT was served. to in the complaint? If so, for each copy of each notice 74.5 Is the proceeding based on an allegation that the state: LANDLORD wishes to remove the RENTAL UNIT from (a) the name of the person who received it; residential use temporarily or permanently (for example, to (b) the kind of notice; rehabilitate, demolish, renovate, or convert)? If so, state: (c) how it was delivered; (a) each reason for removing the RENTAL UNIT from (d) the date received; residential use; (e) where it was delivered; (b) what physical changes and renovation will be made to the RENTAL UNIT; (f) the identity of all DOCUMENTS evidencing the notice and for each state the name, ADDRESS, and (c) the date the work is to begin and end; telephone number of each PERSON who has the (d) the number, date, and type of each permit for the DOCUMENT. change or work;

DISC-003/UD-106 [Rev. January 1, 2014] FORM INTERROGATORIES—UNLAWFUL DETAINER Page 4 of 7

DISC-003/UD-106 (e) the identity of each DOCUMENT evidencing the (g) the response made to the notice; intended activity (for example, blueprints, plans, (h) the efforts made to correct the conditions; applications for financing, construction contracts) and (i) whether the PERSON who gave notice was an the name, ADDRESS, and telephone number of each occupant of the PROPERTY at the time of the PERSON who has each DOCUMENT. complaint. 74.6 Is the proceeding based on any ground other than 75.4 During the period beginning 36 months before the those stated in sections 74.4 and 74.5? If so, for each: NOTICE TO QUIT was served to the present, was the (a) state each fact supporting or opposing the ground; RENTAL UNIT or PROPERTY (including other rental units) (b) state the names, ADDRESSES, and telephone inspected for dilapidations or defective conditions by a numbers of all PERSONS who have knowledge of the representative of any governmental agency? If so, for each facts; inspection state: (c) identify all DOCUMENTS evidencing the facts and (a) the date; state the name, ADDRESS, and telephone number of (b) the reason; each PERSON who has each DOCUMENT. (c) the name of the governmental agency; (d) the name, ADDRESS, and telephone number of each75.0 Breach of Warranty to Provide Habitable Premises inspector;[If plaintiff alleges nonpayment of rent and defendant bases his defense on allegations of implied or express breach of warranty to (e) the identity of each DOCUMENT evidencing each provide habitable residential premises, then either party may ask inspection and the name, ADDRESS, and telephone any applicable question in this section.] number of each PERSON who has it. 75.5 During the period beginning 36 months before the 75.1 Do you know of any conditions in violation of state or NOTICE TO QUIT was served to the present, did local building codes, housing codes, or health codes, PLAINTIFF or LANDLORD receive a notice or other conditions of dilapidation, or other conditions in need communication regarding the condition of the RENTAL of repair in the RENTAL UNIT or on the PROPERTY that UNIT or PROPERTY (including other rental units) from a affected the RENTAL UNIT at any time defendant has governmental agency? If so, for each notice or been in possession? If so, state: communication state: (a) the type of condition; (a) the date received; (b) the kind of corrections or repairs needed; (b) the identity of all parties; (c) how and when you learned of these conditions; (c) the substance of the notice or communication; (d) how these conditions were caused; (d) the identity of each DOCUMENT evidencing the notice (e) the name, ADDRESS, and telephone number of each or communication and the name, ADDRESS, and PERSON who has caused these conditions. telephone number of each PERSON who has it. 75.2 Have any corrections, repairs, or improvements been 75.6 Was there any corrective action taken in response to made to the RENTAL UNIT since the RENTAL UNIT was the inspection or notice or communication identified in rented to defendant? If so, for each correction, repair, or sections 75.4 and 75.5? If so, for each: improvement state: (a) identify the notice or communication; (a) a description giving the nature and location; (b) identify the condition; (b) the date; (c) describe the corrective action; (c) the name, ADDRESS, and telephone number of each (d) identify each DOCUMENT evidencing the corrective PERSON who made the repairs or improvements; action and the name, ADDRESS, and telephone (d) the cost; number of each PERSON who has it. (e) the identity of any DOCUMENT evidencing the repairs

ncing the corrective PERSON who made the repairs or improvements; action and the name, ADDRESS, and telephone (d) the cost; number of each PERSON who has it. (e) the identity of any DOCUMENT evidencing the repairs 75.7 Has the PROPERTY been appraised for sale or loan or improvements; during the period beginning 36 months before the NOTICE (f) if a building permit was issued, state the issuing TO QUIT was served to the present? If so, for each agencies and the permit number of your copy. appraisal state: 75.3 Did defendant or any other PERSON during 36 (a) the date; months before the NOTICE TO QUIT was served or during (b) the name, ADDRESS, and telephone number of the defendant's possession of the RENTAL UNIT notify the appraiser; LANDLORD or his agent or employee about the condition (c) the purpose of the appraisal; of the RENTAL UNIT or PROPERTY? If so, for each (d) the identity of each DOCUMENT evidencing the ap- written or oral notice state: praisal and the name, ADDRESS, and telephone (a) the substance; number of each PERSON who has it. (b) who made it; 75.8 Was any condition requiring repair or correction at the (c) when and how it was made; PROPERTY or RENTAL UNIT caused by defendant or other occupant of the RENTAL UNIT or their guests? If so, (d) the name and ADDRESS of each PERSON to whom it state: was made; (a) the type and location of condition; (e) the name and ADDRESS of each person who knows (b) the kind of corrections or repairs needed; about it; (c) how and when you learned of these conditions; (f) the identity of each DOCUMENT evidencing the notice (d) how and when these conditions were caused; and the name, ADDRESS, and telephone number of (e) the name, ADDRESS, and telephone number of each each PERSON who has it; PERSON who caused these conditions; DISC-003/UD-106 [Rev. January 1, 2014] FORM INTERROGATORIES—UNLAWFUL DETAINER Page 5 of 7

DISC-003/UD-106 (f) the identity of each DOCUMENT evidencing the repair (b) when it was made; (or correction) and the name, ADDRESS, and (c) whether it was written or oral; telephone number of each PERSON who has it. (d) by whom and to whom; [See also section 71.0 for additional questions.] (e) the name and ADDRESS of each person who knows about it;76.0 Waiver, Change, Withdrawal, or Cancellation of Notice to (f) whether all promised repairs, alterations, or im-Quit provements were completed or services provided; [If a defense is based on waiver, change, withdrawal, or (g) the reasons for any failure to perform;cancellation of the NOTICE TO QUIT, then either party may ask (h) the identity of each DOCUMENT evidencing theany applicable question in this section.] agreement or promise and the name, ADDRESS, and 76.1 Did the PLAINTIFF or LANDLORD or anyone acting telephone number of each PERSON who has it. on his or her behalf do anything which is alleged to have been a waiver, change, withdrawal, or cancellation of the 78.2 Has PLAINTIFF or LANDLORD or any resident of the NOTICE TO QUIT? If so: PROPERTY ever committed disturbances or interfered with (a) state the facts supporting this allegation; the quiet enjoyment of the RENTAL UNIT (including, for (b) state the names, ADDRESSES, and telephone example, noise, acts which threaten the loss of title to the numbers of all PERSONS who have knowledge of property or loss of financing, etc.)? If so, for each these facts; disturbance or interference, state: (a) a description of each act; (c) identify each DOCUMENT that supports the facts and (b) the date of each act; state the name, ADDRESS, and telephone number of each PERSON who has it. (c) the name, ADDRESS, and telephone number of each PERSON who acted; 76.2 Did the PLAINTIFF or LANDLORD accept rent (d) the name, ADDRESS, and telephone number of each which covered a period after the date for vacating the PERSON who witnessed each act and any RENTAL UNIT as specified in the NOTICE TO QUIT? If DOCUMENTS evidencing the person's knowledge; so: (e) what action was taken by the PLAINTIFF or (a) state the facts; LANDLORD to end or lessen the disturbance or (b) state the names, ADDRESSES, and telephone interference. numbers of all PERSONS who have knowledge of the 79.0 Offer of Rent by Defendant facts; [If a defense is based on an offer of rent by a defendant which (c) identify each DOCUMENT that supports the facts and was refused, then either party may ask any applicable question in state the name, ADDRESS, and telephone number of this section.] each PERSON who has it. 79.1 Has defendant or anyone acting on the defendant's behalf offered any payments to PLAINTIFF which77.0 Retaliation and Arbitrary Discrimination PLAINTIFF refused to accept? If so, for each offer state: [If a defense is based on retaliation or arbitrary discrimination, (a) the amount; then either party may ask any applicable question in this section.] (b) the date; (c) purpose of offer; 77.1 State all reasons that the NOTICE TO QUIT was (d) the manner of the offer; served or that defendant's tenancy was not renewed and (e) the identity of the person making the offer; for each reason: (f) the identity of the person refusing the offer; (a) state all facts supporting PLAINTIFF'S decision to (g) the date of the refusal; terminate or not renew defendant's tenancy; (h) the reasons for the refusal. (b) state the names, ADDRESSES, and telephone 80.0 Deduction from Rent for Necessary Repairs numbers o

(g) the date of the refusal;
terminate or not renew defendant's tenancy; (h) the reasons for the refusal.
(b) state the names, ADDRESSES, and telephone
80.0 Deduction from Rent for Necessary Repairs numbers of all PERSONS who have knowledge of the
facts; [If a defense to payment of rent or damages is based on claim of
retaliatory eviction, then either party may ask any applicable (c) identify all DOCUMENTS that support the facts and question in this section. Additional questions in section 75.0 may state the name, ADDRESS, and telephone number also be applicable.] of each PERSON who has it. 80.1 Does defendant claim to have deducted from rent any

78.0 Nonperformance of the Rental Agreement by Landlord amount which was withheld to make repairs after communication to the LANDLORD of the need for the[If a defense is based on nonperformance of the rental repairs? If the answer is "no", do not answer interrogatories agreement by the LANDLORD or someone acting on the 80.2 through 80.6. LANDLORD'S behalf, then either party may ask any applicable 80.2 For each condition in need of repair for which aquestion in this section.] deduction was made, state: 78.1 Did the LANDLORD or anyone acting on the (a) the nature of the condition; LANDLORD'S behalf agree to make repairs, alterations, or (b) the location; improvements at any time or provide services to the (c) the date the condition was discovered by defendant; PROPERTY or RENTAL UNIT? If so, for each agreement (d) the date the condition was first known by LANDLORD state: or PLAINTIFF; (a) the substance of the agreement;

DISC-003/UD-106 [Rev. January 1, 2014] FORM INTERROGATORIES—UNLAWFUL DETAINER Page 6 of 7

DISC-003/UD-106 (e) the dates and methods of each notice to the 81.0 Fair Market Rental Value LANDLORD or PLAINTIFF of the condition; [If defendant denies PLAINTIFF allegation on the fair market (f) the response or action taken by the LANDLORD or rental value of the RENTAL UNIT, then either party may ask any PLAINTIFF to each notification; applicable question in this section. If defendant claims that the fair (g) the cost to remedy the condition and how the cost was market rental value is less because of a breach of warranty to determined; provide habitable premises, then either party may also ask any (h) the identity of any bids obtained for the repairs and applicable question in section 75.0.] any DOCUMENTS evidencing the bids. 81.1 Do you have an opinion on the fair market rental value of the RENTAL UNIT? If so, state: 80.3 Did LANDLORD or PLAINTIFF fail to respond within a reasonable time after receiving a communica-tion of a need (a) the substance of your opinion; for repair? If so, for each communication state: (b) the factors upon which the fair market rental value is based; (a) the date it was made; (c) the method used to calculate the fair market rental (b) how it was made; value. (c) the response and date; 81.2 Has any other PERSON ever expressed to you an (d) why the delay was unreasonable. opinion on the fair market rental value of the RENTAL 80.4 Was there an insufficient period specified or actually UNIT? If so, for each PERSON: allowed between the time of notification and the time (a) state the name, ADDRESS, and telephone number; repairs were begun by defendant to allow LANDLORD or (b) state the substance of the PERSON'S opinion; PLAINTIFF to make the repairs? If so, state all facts on (c) describe the conversation or identify all DOCUMENTS which the claim of insufficiency is based. in which the PERSON expressed an opinion and state the name, ADDRESS, and telephone number of each PERSON who has each DOCUMENT. 80.5 Does PLAINTIFF contend that any of the items for which rent deductions were taken were not allowable under 81.3 Do you know of any current violations of state or local law? If so, for each item state all reasons and facts on building codes, housing codes, or health codes, conditions which you base your contention. of dilapidation or other conditions in need of repair in the RENTAL UNIT or common areas that have affected the 80.6 Has defendant vacated or does defendant anticipate RENTAL UNIT at any time defendant has been in vacating the RENTAL UNIT because repairs were possession? If so, state: requested and not made within a reasonable time? If so, (a) the conditions in need of repair; state all facts on which defendant justifies having vacated (b) the kind of repairs needed; the RENTAL UNIT or anticipates vacating the RENTAL UNIT. (c) the name, ADDRESS, and telephone number of each PERSON who caused these conditions.

DISC-003/UD-106 [Rev. January 1, 2014] FORM INTERROGATORIES—UNLAWFUL DETAINER Page 7 of 7 For your protection and privacy, please press the Clear This Form button after you have printed the form. Print this form Save this form Clear this form