ATTORNEY OR PARTY WITHOUT ATTORNEY (Name, State Bar number, and address):

ATTORNEY FOR (Name):
SUPERIOR COURT OF CALIFORNIA, COUNTY OF:

DISC-003/UD-106

        UNLAWFUL DETAINER ASSISTANT
 (Check one box): An unlawful detainer assistant

did

did not for compensation give advice or
assistance with this form. (If one did, state the following): 
ASSISTANT'S NAME:

ADDRESS:

 FORM INTERROGATORIES—UNLAWFUL DETAINER 

TEL. NO.:

COUNTY OF REGISTRATION:

REGISTRATION NO.:

EXPIRES (DATE):

CASE NUMBER:

SHORT TITLE:

Asking Party:

Answering Party:

Set No.:

Sec. 1.  Instructions to All Parties

(a) These are general instructions. For time limitations, 
requirements for service on other parties, and other details, 
see Code of Civil Procedure sections 2030.010-2030.410 
and the cases construing those sections.

(b) These interrogatories do not change existing law 
relating to interrogatories nor do they affect an answering 
party's right to assert any privilege or objection.

Sec.  2.  Instructions to the Asking Party

(a) These interrogatories are designed for optional use 

in unlawful detainer proceedings.

(b) There are restrictions that generally limit the num- 
ber of interrogatories that may be asked and the form and 
use of the interrogatories. For details, read Code of Civil 
Procedure sections 2030.030–2030.070.

(c) In determining whether to use these or any interroga- 
tories, you should be aware that abuse can be punished by 
sanctions, including fines and attorney fees. See Code of 
Civil Procedure section 128.7.

(d) Check the box next to each interrogatory that you 
want the answering party to answer. Use care in choosing 
those interrogatories that are applicable to the case.

(e) Additional interrogatories may be attached.

Sec.  3.  Instructions to the Answering Party

(a) An answer or other appropriate response must be 
given to each interrogatory checked by the asking party. 
Failure to respond to these interrogatories properly can be 
punished by sanctions, including contempt proceedings, 
fine, attorneys fees, and the loss of your case. See Code 
of Civil Procedure sections 128.7 and 2030.300.

(b) As a general rule, within five days after you are served 
with these interrogatories, you must serve your responses on 
the asking party and serve copies of your responses on all 
other parties to the action who have appeared. See Code of 
Civil Procedure sections 2030.260–2030.270 for details.

(c) Each answer must be as complete and straightfor- 
ward as the information reasonably available to you per- 
mits. If an interrogatory cannot be answered completely, 
answer it to the extent possible.

(d) If you do not have enough personal knowledge to 
fully answer an interrogatory, say so, but make a reasona- 
ble and good faith effort to get the information by asking 
other persons or organizations, unless the information is 
equally available to the asking party.

(e) Whenever an interrogatory may be answered by refer- 

ring to a document, the document may be attached as an 
exhibit to the response and referred to in the response. If 
the document has more than one page, refer to the page 
and section where the answer to the interrogatory can be 
found.

(f) Whenever an address and telephone number for the 
same person are requested in more than one interrogatory, 
you are required to furnish them in answering only the first 
interrogatory asking for that information.

(g) Your answers to these interrogatories must be veri- 
fied, dated, and signed. You may wish to use the following 
form at the end of your answers:

I declare under penalty of perjury under the laws of the 
State of California that the foregoing answers are true and 
correct.

(DATE)

(SIGNATURE)

Sec. 4.  Definitions

are defined as follows:

Words in BOLDFACE CAPITALS in these interrogatories 

(a) PERSON includes a natural person, firm, 

association, organization, partnership, business, trust, 
corporation, or public entity.

(b) PLAINTIFF includes any PERSON who seeks recov- 
ery of the RENTAL UNIT whether acting as an individual or 
on someone else's behalf and includes all such PERSONS 
if more than one.

Form Approved for Optional Use 
Judicial Council of California

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Code of Civil Procedure,
 §§ 2030.010-2030.410, 2033.710
www.courts.ca.gov

(c) LANDLORD includes any PERSON who offered the 
RENTAL UNIT for rent and any PERSON on whose behalf 
the RENTAL UNIT was offered for rent and their successors 
in interest. LANDLORD includes all PERSONS who managed 
the PROPERTY while defendant was in possession.

(d) RENTAL UNIT is the premises PLAINTIFF seeks 

interest.

to recover.

(e) PROPERTY is the building or parcel (including com- 

mon areas) of which the RENTAL UNIT is a part. (For 
example, if PLAINTIFF is seeking to recover possession of 
apartment number 12 of a 20-unit building, the building is 
the PROPERTY and apartment 12 is the RENTAL UNIT. If 
PLAINTIFF seeks possession of cottage number 3 in a five- 
cottage court or complex, the court or complex is the 
PROPERTY and cottage 3 is the RENTAL UNIT.)

(f) DOCUMENT means a writing, as defined in Evidence 

Code section 250, and includes the original or a copy of 
handwriting, typewriting, printing, photostating, photo- 
graphing, electronically stored information, and every other 
means of recording upon any tangible thing and form of 
communicating or representation, including letters, words, 
pictures, sounds, or symbols, or combinations of them.

(g) NOTICE TO QUIT includes the original or copy of any 

notice mentioned in Code of Civil Procedure section 1161 
or Civil Code section 1946, including a 3-day notice to pay 
rent and quit the RENTAL UNIT, a 3-day notice to perform 
conditions or covenants or quit, a 3-day notice to quit, and a 
30-day notice of termination.

(h) ADDRESS means the street address, including the 

city, state, and zip code.

Sec.   5.  Interrogatories

The following interrogatories have been approved by the 
Judicial Council under section 2033.710 of the Code of Civil 
Procedure for use in unlawful detainer proceedings:

CONTENTS

70.0 General
71.0 Notice
72.0 Service
73.0 Malicious Holding Over 
74.0 Rent Control and Eviction Control
75.0 Breach of Warranty to Provide Habitable

76.0 Waiver, Change, Withdrawal, or Cancellation

Premises

of Notice to Quit

77.0 Retaliation and Arbitrary Discrimination
78.0 Nonperformance of the Rental Agreement

by Landlord

79.0 Offer of Rent by Defendant
80.0 Deduction from Rent for Necessary Repairs 
81.0 Fair Market Rental Value

70.0 General

[Either party may ask any applicable question in this
section.]

70.1 State the name, ADDRESS, telephone number, 
and relationship to you of each PERSON who prepared 
or assisted in the preparation of the responses to these 
interrogatories. (Do not identify anyone who simply 
typed or reproduced the responses.)

DISC-003/UD-106

70.2 Is PLAINTIFF an owner of the RENTAL UNIT? If
so, state:
(a) the nature and percentage of ownership interest;
(b) the date PLAINTIFF first acquired this ownership

70.3 Does PLAINTIFF share ownership or lack owner- 
ship? If so, state the name, the ADDRESS, and the 
nature and percentage of ownership interest of each 
owner.

70.4 Does PLAINTIFF claim the right to possession 
other than as an owner of the RENTAL UNIT? If so, 
state the basis of the claim.

70.5 Has PLAINTIFF'S interest in the RENTAL UNIT 
changed since acquisition? If so, state the nature and 
dates of each change.

70.6 Are there other rental units on the PROPERTY? 
If so, state how many.

70.7 During the 12 months before this proceeding was 
filed, did PLAINTIFF possess a permit or certificate of 
occupancy for the RENTAL UNIT? If so, for each state:
(a) the name and ADDRESS of each PERSON named

on the permit or certificate;

(b) the dates of issuance and expiration; 
(c) the permit or certificate number

70.8 Has a last month's rent, security deposit, clean-
ing fee, rental agency fee, credit check fee, key deposit, 
or any other deposit been paid on the RENTAL UNIT? 
If so, for each item state:
(a) the purpose of the payment;
(b) the date paid;
(c) the amount;
(d) the form of payment;
(e) the name of the PERSON paying;
(f ) the name of the PERSON to whom it was paid;
(g) any DOCUMENT which evidences payment and the
name, ADDRESS, and telephone number of each
PERSON who has the DOCUMENT;

(h) any adjustments or deductions including facts.

70.9 State the date defendant first took possession of 
the RENTAL UNIT.

70.10 State the date and all the terms of any rental 
agreement between defendant and the PERSON who 
rented to defendant.

70.11 For each agreement alleged in the pleadings:
(a)    identify all DOCUMENTS that are part of the agree-
ment and for each state the name, ADDRESS, and 
telephone number of each PERSON who has the
DOCUMENT;

(b)    state each part of the agreement not in writing, the
name, ADDRESS, and telephone number of each 
PERSON agreeing to that provision, and the date 
that part of the agreement was made;

(c)    identify all DOCUMENTS that evidence each part
of the agreement not in writing and for each state 
the name, ADDRESS, and telephone number of 
each PERSON who has the DOCUMENT;
(d)    identify all DOCUMENTS that are part of each

modification to the agreement, and for each state

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the name, ADDRESS, and telephone number of each 
PERSON who has the DOCUMENT (see also §71.5);

(e)  state each modification not in writing, the date, and

the name, ADDRESS, and telephone number of the 
PERSON agreeing to the modification, and the date 
the modification was made (see also §71.5).
(f)  identify all DOCUMENTS that evidence each

modification of the agreement not in writing and for 
each state the name, ADDRESS, and telephone 
number of each PERSON who has the DOCUMENT 
(see also §71.5).

70.12 Has any PERSON acting on the PLAINTIFF'S
behalf been responsible for any aspect of managing or 
maintaining the RENTAL UNIT or PROPERTY? If so, for 
each PERSON state:
(a)  the name, ADDRESS, and telephone number;
(b)  the dates the PERSON managed or maintained the
       RENTAL UNIT or PROPERTY; 
(c)  the PERSON'S responsibilities.

70.13 For each PERSON who occupies any part of the 
RENTAL UNIT (except occupants named in the com- 
plaint and occupants' children under 17) state:
(a)  the name, ADDRESS, telephone number, and

(b)  the inclusive dates of occupancy;
(c)  a description of the portion of the RENTAL UNIT

birthdate;

occupied;

(d)  the amount paid, the term for which it was paid,
      and the person to whom it was paid;
(e)  the nature of the use of the RENTAL UNIT;
(f)   the name, ADDRESS, and telephone number of the
      person who authorized occupancy;
(g)  how occupancy was authorized, including failure of
      the LANDLORD or PLAINTIFF to protest after  
      discovering the occupancy.

70.14 Have you or anyone acting on your behalf ob- 
tained any DOCUMENT concerning the tenancy bet- 
ween any occupant of the RENTAL UNIT and any PER- 
SON with an ownership interest or managerial respon- 
sibility for the RENTAL UNIT? If so, for each DOCU-
MENT state:
(a)  the name, ADDRESS, and telephone number of
each individual from whom the DOCUMENT was
obtained;

(b)  the name, ADDRESS, and telephone number of
each individual who obtained the DOCUMENT;

(c)  the date the DOCUMENT was obtained;
(d)  the name, ADDRESS, and telephone number of

each PERSON who has the DOCUMENT (original
or copy).

71.0  Notice
[If a defense is based on allegations that the 3-day notice 
or 30- day NOTICE TO QUIT is defective in form or con-
tent, then either party may ask any applicable question in 
this section.]

71.1 Was the NOTICE TO QUIT on which PLAINTIFF 
bases this proceeding attached to the complaint? If not, 
state the contents of this notice.

71.2 State all reasons that the NOTICE TO QUIT was
served and for each reason:
(a) state all facts supporting PLAINTIFF'S decision to 
      terminate defendant's tenancy;

DISC-003/UD-106

(b)   state the names, ADDRESSES, and telephone
       numbers of all PERSONS who have knowledge of
       the facts;
(c)   identify all DOCUMENTS that support the facts and
       state the name, ADDRESS, and telephone number
       of each PERSON who has each DOCUMENT.

71.3 List all rent payments and rent credits made or 
claimed by or on behalf of defendant beginning 12 
months before the NOTICE TO QUIT was served. For 
each payment or credit state:
(a)  the amount;
(b)  the date received;
(c)  the form in which any payment was made;
(d)  the services performed or other basis for which a

credit is claimed;
(e)  the period covered;
(f)   the name of each PERSON making the payment or

earning the credit;

(g)  the identity of all DOCUMENTS evidencing the pay-

ment or credit and for each state the name,
ADDRESS, and telephone number of each PERSON
who has the DOCUMENT.

71.4 Did defendant ever fail to pay the rent on time? 
If so, for each late payment state:
(a)  the date;
(b)  the amount of any late charge;
(c)  the identity of all DOCUMENTS recording the pay-
ment and for each state the name, ADDRESS, and
telephone number of each PERSON who has the 
DOCUMENT.

71.5 Since the beginning of defendant's tenancy, has 
PLAINTIFF ever raised the rent? If so, for each rent 
increase state:
(a)  the date the increase became effective;
(b)  the amount;
(c)  the reasons for the rent increase;
(d)  how and when defendant was notified of the

increase;

(e)  the identity of all DOCUMENTS evidencing the in-

crease and for each state the name, ADDRESS, and 
telephone number of each PERSON who has the
DOCUMENT.

[See also section 70.11 (d) - (f).]

71.6 During the 12 months before the NOTICE TO QUIT 
was served was there a period during which there was 
no permit or certificate of occupancy for the RENTAL 
UNIT? If so, for each period state:
(a) the inclusive dates;
(b) the reasons.

71.7 Has any PERSON ever reported any nuisance or 
disturbance at or destruction of the RENTAL UNIT or 
PROPERTY caused by defendant or other occupant of 
the RENTAL UNIT or their guests? If so, for each report
state;
(a)  a description of the disturbance or destruction;
(b)  the date of the report;
(c)  the name of the PERSON who reported;
(d)  the name of the PERSON to whom the report was

made;

(e)  what action was taken as a result of the report;
(f)   the identity of all DOCUMENTS evidencing the

report and for each state the name, ADDRESS, and 
telephone number of each PERSON who has each 
DOCUMENT.

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71.8 Does the complaint allege violation of a term of 
a rental agreement or lease (other than nonpayment 
of rent)? If so, for each covenant:
(a) identify the covenant breached;
(b) state the facts supporting the allegation of a breach;
(c) state the names, ADDRESSES, and telephone

numbers of all PERSONS who have knowledge of
the facts;

(d) identify all DOCUMENTS that support the facts and
state the name, ADDRESS, and telephone number
of each PERSON who has each DOCUMENT.

71.9 Does the complaint allege that the defendant has 
been using the RENTAL UNIT for an illegal purpose? If
so, for each purpose:
(a) identify the illegal purpose;
(b) state the facts supporting the allegations of illegal

use;

(c) state the names, ADDRESSES, and telephone

numbers of all PERSONS who have knowledge of
the facts;

(d) identify all DOCUMENTS that support the facts and
state the name, ADDRESS, and telephone number 
of each PERSON who has each DOCUMENT.

[Additional interrogatories on this subject may be found 
in sections 75.0, 78.0, 79.0, and 80.0.]

72.0 Service

[If a defense is based on allegations that the NOTICE TO 
QUIT was defectively served, then either party may ask 
any applicable question in this section.]

72.1 Does defendant contend (or base a defense or
make any allegations) that the NOTICE TO QUIT was
defectively served? If the answer is "no", do not answer 
interrogatories 72.2 through 72.3.

72.2 Does PLAINTIFF contend that the NOTICE TO 
QUIT referred to in the complaint was served? If so,
state:
(a) the kind of notice;
(b) the date and time of service;
(c) the manner of service;
(d) the name and ADDRESS of the person who served

it:

(e) a description of any DOCUMENT or conversation

between defendant and the person who served the
notice.

72.3 Did any person receive the NOTICE TO QUIT
referred to in the complaint? If so, for each copy of each
notice state:
(a) the name of the person who received it; 
(b) the kind of notice;
(c) how it was delivered; 
(d) the date received;
(e) where it was delivered;
(f) the identity of all DOCUMENTS evidencing the

notice and for each state the name, ADDRESS, and
telephone number of each PERSON who has the 
DOCUMENT.

DISC-003/UD-106

73.0 Malicious Holding Over
[If a defendant denies allegations that defendant's con- 
tinued possession is malicious, then either party may ask 
any applicable question in this section. Additional questions 
in section 75.0 may also be applicable.]

74.0  Rent Control and Eviction Control

73.1 If any rent called for by the rental agreement is 
unpaid, state the reasons and the facts upon which the 
reasons are based.

73.2 Has defendant made attempts to secure other 
premises since the service of the NOTICE TO QUIT or 
since the service of the summons and complaint? If so,
for each attempt:
(a) state all facts indicating the attempt to secure other

premises;

(b) state the names, ADDRESSES, and telephone

numbers of all PERSONS who have knowledge of
the facts;

(c) identify all DOCUMENTS that support the facts and
state the name, ADDRESS, and telephone number
of each PERSON who has each DOCUMENT.

73.3 State the facts upon which PLAINTIFF bases the 
allegation of malice.

74.1 Is there an ordinance or other local law in this 
jurisdiction which limits the right to evict tenants? If your 
answer is no, you need not answer sections 74.2 
through 74.6.

74.2 For the ordinance or other local law limiting the 
right to evict tenants, state:
(a) the title or number of the law;
(b) the locality.

74.3 Do you contend that the RENTAL UNIT is exempt 
from the eviction provisions of the ordinance or other 
local law identified in section 74.2? If so, state the facts 
upon which you base your contention.

74.4 Is this proceeding based on allegations of a need
to recover the RENTAL UNIT for use of the LANDLORD
or the landlord's relative? If so, for each intended occu- 
pant state:
(a) the name;
(b) the residence ADDRESSES from three years ago to

the present;

(c) the relationship to the LANDLORD;
(d) all the intended occupant's reasons for occupancy;
(e) all rental units on the PROPERTY that were vacated

within 60 days before and after the date the 
NOTICE TO QUIT was served.

74.5 Is the proceeding based on an allegation that the
LANDLORD wishes to remove the RENTAL UNIT from
residential use temporarily or permanently (for exam-
ple, to rehabilitate, demolish, renovate, or convert)? If
so, state:
(a) each reason for removing the RENTAL UNIT from

(b) what physical changes and renovation will be made

residential use;

to the RENTAL UNIT;

(c) the date the work is to begin and end;
(d) the number, date, and type of each permit for the

change or work;

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75.0  Breach  of  Warranty  to  Provide  Habitable  Premises

each inspector;

[If plaintiff alleges nonpayment of rent and defendant bases 
his defense on allegations of implied or express breach of 
warranty to provide habitable residential premises, then 
either party may ask any applicable question in this section.]

(e)

the identity of each DOCUMENT evidencing the in- 
tended activity (for example, blueprints, plans, ap- 
plications for financing, construction contracts) and 
the name, ADDRESS, and telephone number of 
each PERSON who has each DOCUMENT.

74.6 Is the proceeding based on any ground other than 
those stated in sections 74.4 and 74.5? If so, for each: 
(a)  state each fact supporting or opposing the ground; 
(b)  state the names, ADDRESSES, and telephone

numbers of all PERSONS who have knowledge of
the facts;

(c) identify all DOCUMENTS evidencing the facts and 
state the name, ADDRESS, and telephone number 
of each PERSON who has each DOCUMENT.

75.1 Do you know of any conditions in violation of state or 
local building codes, housing codes, or health codes, 
conditions of dilapidation, or other conditions in need
 of repair in the RENTAL UNIT or on the PROPERTY that 
affected the RENTAL UNIT at any time defendant has 
been in possession? If so, state:
(a)  the type of condition;
(b)  the kind of corrections or repairs needed;
(c)  how and when you learned of these conditions;
(d)  how these conditions were caused;
(e)  the name, ADDRESS, and telephone number of
each PERSON who has caused these conditions.

75.2 Have any corrections, repairs, or improvements 
been made to the RENTAL UNIT since the RENTAL 
UNIT was rented to defendant? If so, for each correc-
tion, repair, or improvement state:
(a)  a description giving the nature and location;
(b)  the date;
(c)  the name, ADDRESS, and telephone number of

each PERSON who made the repairs or 
improvements;

(d)  the cost;
(e)  the identity of any DOCUMENT evidencing the

repairs or improvements;

(f)   if a building permit was issued, state the issuing
agencies and the permit number of your copy.

75.3 Did defendant or any other PERSON during 36 
months before the NOTICE TO QUIT was served or dur- 
ing defendant's possession of the RENTAL UNIT notify
the LANDLORD or his agent or employee about the con- 
dition of the RENTAL UNIT or PROPERTY? If so, for
each written or oral notice state:
(a) the substance;
(b) who made it;
(c) when and how it was made;
(d) the name and ADDRESS of each PERSON to whom

(e) the name and ADDRESS of each person who

it was made;

knows about it;

(f) the identity of each DOCUMENT evidencing the

notice and the name, ADDRESS, and telephone 
number of each PERSON who has it;

DISC-003/UD-106

(g)  the response made to the notice;
(h)  the efforts made to correct the conditions;
( i)  whether the PERSON who gave notice was an oc-

cupant of the PROPERTY at the time of the 
complaint.

75.4 During the period beginning 36 months before the 
NOTICE TO QUIT was served to the present, was the 
RENTAL UNIT or PROPERTY (including other rental 
units) inspected for dilapidations or defective conditions 
by a representative of any governmental agency? If so, 
for each inspection state: 
(a)  the date;
(b)  the reason;
(c)  the name of the governmental agency;
(d)  the name, ADDRESS, and telephone number of

(e)  the identity of each DOCUMENT evidencing each

inspection and the name, ADDRESS, and telephone
number of each PERSON who has it.

75.5 During the period beginning 36 months before the 
NOTICE TO QUIT was served to the present, did 
PLAINTIFF or LANDLORD receive a notice or other com- 
munication regarding the condition of the RENTAL UNIT 
or PROPERTY (including other rental units) from a 
governmental agency? If so, for each notice or com- 
munication state:
(a)  the date received;
(b)  the identity of all parties;
(c)  the substance of the notice or communication;
(d)  the identity of each DOCUMENT evidencing the

notice or communication and the name, ADDRESS, 
and telephone number of each PERSON who has it.

75.6 Was there any corrective action taken in response 
to the inspection or notice or communication identified 
in sections 75.4 and 75.5? If so, for each:
(a)  identify the notice or communication; 
(b)  identify the condition;
(c)  describe the corrective action;
(d)  identify each DOCUMENT evidencing the correc-

tive action and the name, ADDRESS, and telephone 
number of each PERSON who has it.

75.7 Has the PROPERTY been appraised for sale or 
loan during the period beginning 36 months before the 
NOTICE TO QUIT was served to the present? If so, for 
each appraisal state:
(a)  the date;
(b)  the name, ADDRESS, and telephone number of the

appraiser;

(c)  the purpose of the appraisal;
(d)  the identity of each DOCUMENT evidencing the ap-
praisal and the name, ADDRESS, and telephone 
number of each PERSON who has it.

75.8 Was any condition requiring repair or correction
at the PROPERTY or RENTAL UNIT caused by defen-
dent or other occupant of the RENTAL UNIT or their
guests? If so, state:
(a)  the type and location of condition;
(b)  the kind of corrections or repairs needed;
(c)  how and when you learned of these conditions; 
(d)  how and when these conditions were caused;
(e)  the name, ADDRESS, and telephone number of
each PERSON who caused these conditions;

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(f)  the identity of each DOCUMENT evidencing the

repair (or correction) and the name, ADDRESS, and 
telephone number of each PERSON who has it.

[See also section 71.0 for additional questions.]

76.0  Waiver, Change, Withdrawal, or Cancellation of
Notice to Quit

[If a defense is based on waiver, change, withdrawal, or 
cancellation of the NOTICE TO QUIT, then either party may 
ask any applicable question in this section.]

76.1 Did the PLAINTIFF or LANDLORD or anyone act- 
ing on his or her behalf do anything which is alleged to 
have been a waiver, change, withdrawal, or cancellation
of the NOTICE TO QUIT? If so:
(a)  state the facts supporting this allegation;
(b)  state the names, ADDRESSES, and telephone

numbers of all PERSONS who have knowledge of
these facts;

(c)  identify each DOCUMENT that supports the facts
and state the name, ADDRESS, and telephone 
number of each PERSON who has it.

76.2 Did the PLAINTIFF or LANDLORD accept rent 
which covered a period after the date for vacating the 
RENTAL UNIT as specified in the NOTICE TO QUIT? If
so:
(a)  state the facts;
(b)  state the names, ADDRESSES, and telephone

numbers of all PERSONS who have knowledge of
the facts;

(c)  identify each DOCUMENT that supports the facts
and state the name, ADDRESS, and telephone 
number of each PERSON who has it.

77.0  Retaliation and Arbitrary Discrimination

[If a defense is based on retaliation or arbitrary discrimina- 
tion, then either party may ask any applicable question in 
this section.]

77.1 State all reasons that the NOTICE TO QUIT was 
served or that defendant's tenancy was not renewed
and for each reason:
(a)  state all facts supporting PLAINTIFF'S decision to
terminate or not renew defendant's tenancy;
(b)  state the names, ADDRESSES, and telephone

numbers of all PERSONS who have knowledge of
the facts;

(c)  identify all DOCUMENTS that support the facts and
      state the name, ADDRESS, and telephone number
      of each PERSON who has it.

78.0  Nonperformance of the Rental Agreement by

Landlord

[If a defense is based on nonperformance of the rental 
agreement by the LANDLORD or someone acting on the 
LANDLORD'S behalf, then either party may ask any ap -
plicable question in this section.]

78.1 Did the LANDLORD or anyone acting on the 
LANDLORD'S behalf agree to make repairs, alterations,
or improvements at any time or provide services to the 
PROPERTY or RENTAL UNIT? If so, for each agreement
state:
(a)  the substance of the agreement;

DISC-003/UD-106

(b)  when it was made;
(c)  whether it was written or oral;
(d)  by whom and to whom;
(e)  the name and ADDRESS of each person who

knows about it;

(f)   whether all promised repairs, alterations, or im-

provements were completed or services provided;

(g)  the reasons for any failure to perform;
(h)  the identity of each DOCUMENT evidencing the

agreement or promise and the name, ADDRESS, 
and telephone number of each PERSON who has it.

78.2 Has PLAINTIFF or LANDLORD or any resident of 
the PROPERTY ever committed disturbances or in- 
terfered with the quiet enjoyment of the RENTAL UNIT 
(including, for example, noise, acts which threaten the 
loss of title to the property or loss of financing, etc.)?
If so, for each disturbance or interference, state:
(a)  a description of each act;
(b)  the date of each act;
(c)  the name, ADDRESS, and telephone number of

each PERSON who acted;

(d)  the name, ADDRESS, and telephone number of
each PERSON who witnessed each act and any
DOCUMENTS evidencing the person's knowledge;

(e)  what action was taken by the PLAINTIFF or

LANDLORD to end or lessen the disturbance or 
interference.

79.0  Offer of Rent by Defendant

[If a defense is based on an offer of rent by a defendant 
which was refused, then either party may ask any ap- 
plicable question in this section.]

79.1 Has defendant or anyone acting on the defen-
dant's behalf offered any payments to PLAINTIFF which 
PLAINTIFF refused to accept? If so, for each offer state: 
(a)  the amount; 
(b)  the date;
(c)  purpose of offer;
(d)  the manner of the offer;
(e)  the identity of the person making the offer; 
(f )  the identity of the person refusing the offer; 
(g)  the date of the refusal;
(h)  the reasons for the refusal.

80.0  Deduction from Rent for Necessary Repairs

[If a defense to payment of rent or damages is based on 
claim of retaliatory eviction, then either party may ask any 
applicable question in this section. Additional questions in 
section 75.0 may also be applicable.]

80.1 Does defendant claim to have deducted from rent 
any amount which was withheld to make repairs after
communication to the LANDLORD of the need for the
repairs? If the answer is "no", do not answer inter- 
rogatories 80.2 through 80.6.

80.2 For each condition in need of repair for which a 
deduction was made, state:
(a)  the nature of the condition;
(b)  the location;
(c)  the date the condition was discovered by defendant;
(d)  the date the condition was first known by

LANDLORD or PLAINTIFF;

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(e)  the dates and methods of each notice to the
LANDLORD or PLAINTIFF of the condition;

(f)   the response or action taken by the LANDLORD or

PLAINTIFF to each notification;

(g)  the cost to remedy the condition and how the cost

was determined;

(h)  the identity of any bids obtained for the repairs and

any DOCUMENTS evidencing the bids.

80.3 Did LANDLORD or PLAINTIFF fail to respond 
within a reasonable time after receiving a communica-
tion of a need for repair? If so, for each communication
state:
(a)  the date it was made; 
(b)  how it was made;
(c)  the response and date;
(d)  why the delay was unreasonable.

80.4 Was there an insufficient period specified or ac- 
tually allowed between the time of notification and the 
time repairs were begun by defendant to allow 
LANDLORD or PLAINTIFF to make the repairs? If so, 
state all facts on which the claim of insufficiency is 
based.

80.5 Does PLAINTIFF contend that any of the items
for which rent deductions were taken were not
allowable under law? If so, for each item state all reasons 
and facts on which you base your contention.

80.6 Has defendant vacated or does defendant an-
ticipate vacating the RENTAL UNIT because repairs
were requested and not made within a reasonable time?
If so, state all facts on which defendant justifies hav-
ing vacated the RENTAL UNIT or anticipates vacating
the rental unit.

DISC-003/UD-106

81.0  Fair Market Rental Value

[If defendant denies PLAINTIFF allegation on the fair market 
rental value of the RENTAL UNIT, then either party may ask 
any applicable question in this section. If defendant claims 
that the fair market rental value is less because of a breach 
of warranty to provide habitable premises, then either party 
may also ask any applicable question in section 75.0.]

81.1 Do you have an opinion on the fair market rental 
value of the RENTAL UNIT? If so, state:
(a)  the substance of your opinion;
(b)  the factors upon which the fair market rental value
is based;
(c)  the method used to calculate the fair market rental
value.

81.2 Has any other PERSON ever expressed to you an 
opinion on the fair market rental value of the RENTAL
UNIT? If so, for each PERSON:
(a) state the name, ADDRESS, and telephone number;
(b) state the substance of the PERSON'S opinion;
(c) describe the conversation or identify all
DOCUMENTS in which the PERSON expressed an 
opinion and state the name, ADDRESS, and
telephone number of each PERSON who has each
DOCUMENT.

81.3 Do you know of any current violations of state or 
local building codes, housing codes, or health codes, 
conditions of delapidation or other conditions in need of 
repair in the RENTAL UNIT or common areas that have 
affected the RENTAL UNIT at any time defendant has 
been in possession? If so, state:
(a)  the conditions in need of repair;
(b)  the kind of repairs needed;
(c)  the name, ADDRESS, and telephone number of
each PERSON who caused these conditions.

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