vagle v archstone communities carpet painting security deposit cleaning lawsuit.pdf

8/12/2019 Vagle v Archstone Communities carpet painting security deposit cleaning lawsuit.pdf

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Exhibit 2

Case 2:14-cv-03476-RGK-AJW Document 1-2 Filed 05/06/14 Page 1 of 113 Page ID #:36


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ATTORNEY OR PARTY \MTHOUT ATTORNEY Name, S ta te Ea r numbe, and address :ChristopherJ. Healey, SBN 105798Jaikaran Singh, SBN 201355McKENNA LONG ALDRIDGE LLP600 West Broadway, Suite 2600San Diego, CA 92101

TELEPHONE NO.: 619 236-1414 FAX NO . Optional : 619 232-8311E-MAIL ADDRESS Optional : chealeymckennalon g.com I jsinghmckennalong.com

ATTORNEY FO R Name : Archstone Communities LLC; ASN Warner Center, LLC;and Archstone Long Beach LPSUPERIOR COURT OF CALIFORNIA, COUNTY OF LOS ANGELESSTREET ADDRESS: 600 South Commonwealth Avenue

MAILING ADDRESS:CITYANDZIPCODE: Los Angeles, CA 90005

BRANCH NAME: Central Civil WestPLAINTIFF/PETITIONER: JENNIFER VAGLE and GEORGE PONCE, et al.

FOR COURT USE ONLYCM-180

DEFENDANT/RESPONDENT: ARCHSTONE COMMUNITIES LLC, et al.CASE NUMBER:BC480931NOTICE OF STAY OF PROCEEDINGS JUDGE: Hon. William F. HighbergerDEPT.: 307

To the court and to all parties:Declarant name : Jaikaran Singha. is the party the attorney for the party who requested or caused the stay.b. LI is the plaintiff or petitioner LI the attorney for the plaintiff or petitioner. The party who requested the stayhas no t appeared in this case or is not subject to the jurisdiction of this court.

2. This case is stayed as follows:a. With regard to all parties.b. LI With regard to the following parties specify by name and party designation :

3. Reason for the stay:a. Automatic stay caused by a filing in another court. Attach a copy of the Notice of Commencement of Case, thebankruptcy petition, or other document showing that the stay is in effect, and showing the court, case number;debtor; and petitioners.b. Order of a federal court or of a higher California court. Attach a copy of the court orderc. LI Contractual arbitration under Code of Civil Procedure section 1281.4. Attach a copy of the order directingarbitration.d. LI Arbitration of attorney fees and costs under Business and Professions Code section 6201. Attach a copy of the

clients request for arbitration showing filing and service.e. LI Other: declare under penalty of perjury under the laws of the State of California that thEDate: December 6, 2013

Jaikaran_SinghTYPE OR PRINT NAME OF DECLARANT

, gelofi

Form Adopted for Mandatoy UseJudicial Council of California NOTICE OF STAY OF PROCEEINGSCM-180 [Rev. January 1,20071

Cat Rules of Court , rule 3.650www.courfinfo.ca gov

American LegalNet, Inc.www.FormsWorkflow.com

54676039

Dec 09 201

12:47PM

EXHIBIT 2Page 36



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CHRISTOPHER J. HEALEY SBN 105798)[email protected] JAIKARAN SINGH SBN 201355)[email protected] McKENNA LONG ALDRIDGE LLP600 West Broadway, Suite 26004 San Diego, CA 92101-3372Telephone: 619.236.14145 Facsimile: 619.232.83116 Attorneys for DefendantsARCHSTONE COMMUNITIES LLC, ASN WARNER CENTER, LLC7 and ARCHSTONE LONG BEACH LP8 SUPERIOR COURT OF THE STATE OF CALIFORNIA9

COUNTY OF LOS ANGELES1011 JENNIFER VAGLE, on behalf of herself and Case No. BC48093 12 all others similarly situated,13 Plaintiff, PROOF OF SERVICE14 v.

Assigned for All Purposes to:15 ARCHSTONE COMMUNITIES, LLC, a Hon. William F. HighbergerDelaware limited liability corporation, ASN Dept. 30716 WARNER CENTER, LLC, a Delawarelimited liability corporation, and17 ARCHSTONE LONG BEACH LP, aDelaware limited liability corporation, and18 DOES through 100, inclusive,19 Defendants.2021 I, Maria E. Valentino, declare under penalty of perjury that I am over the age of eighteenyears, that I am not a party to the above-referenced action, and that I am employed in the State of22 California, County of San Diego, where the within-mentioned service occurred. My business2324 address is 600 West Broadway, Suite 2600, San Diego, California 92101; telephone number 619)236-1414.25 On December 9, 2013, I caused to be served the following document s :26

NOTICE OF STAY OF PROCEEDINGS2728

LONG SAN DIEGO PROOF OF SERVICE

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23

45678910111213141516171819202122232425262728

LONG LLPSAN DIEGO

on the interested parties in this action by:LEXISNEXIS SERVICE LIST VIEWABLE ONLINE

XX BY ELECTRONIC SERVICE: Complying with Code of Civil Procedure 1010, I causedsuch document s to be Electronically Filed and Served through the LexisNexis System forthe above-entitled case. Upon completion of transmission of said document s), a filingreceipt is issued to the filing party acknowledging receipt, filing and se rv ic e by theLexisNexis system. A copy of the LexisNexis filing receipt page will be maintained withthe original document s in our office.I declare under penalty of perjury under the laws of the State of California that the

foregoing is true and correct.Executed at San Diego, California on December 9, 2013.

USW 80375757010

2

Maria E. Val

PROOF OF SERVICEEXHIBIT 2Page 38



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CRISOHER J. AY (SBN 105798)[email protected]

2 JAIKARA SIN SBN 203)jsig@mckenalong:com

3 cKA LO & ADG LP600 West oadway, Sue 2600

4 San Dego, CA 920-3372elepoe 69236414

Fasme 69232831

6 Atoeys r DendantsARCHSTON COMUITIES LLC,ASN WARNERCNTR LLC

7 ad ARCHSTO LONG BEACH LP

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JNIER VAG ad OR OC2 o bealf of emseves ad a oes

smaly saed;3

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ARCHSTON COMUNIS, LLC, a6 eaware med iay copoao, AS

WARNER CTER LC a Deawae7 med aiy cooao adARCHSONE OG BACH L a

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Case o C48093

Assged r A uoses too. Wm gegeDep 30

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NOTICE O ADVERS PRTY OF EMVAL D CU


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54621640

Nov 26 201

02:13PM

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1 R x Pais sq SBN 96567}Al ade R. Wheee Esq. BN 239541)

2 Kity Szeo s (SB 25 8lj6Jo M. ickfod s (SB 80929)R EX PARRIS AW FRM343364 0h Sreet West

4 Lanase, Caiia 93534Teephone: 661) 949-2595

5 Fasme: 661 949-7546 Atoeys Painis and the Putatve Cass

7

8SUPEIO COUT OF THE STATE OF CAIFONI

9

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FO THE CONTY OF LOS ANGELES - CENTAL CIVIL WEST ORTHOUS

NIF VAGL and GOG2 POC on behaf of themseves and a

ohes simiary siuaed;13

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Paintis

AHSO COUITIS LL a6 Dewae imited iabiity ooation, AS7 WAR CE LC a Deaware

imied iabiity oroaton and8 RCHSO LOG CH LP a

Deawae imied artnershi and DOS 19 though 00 incusive

20

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Dendants.

Case o 48093

OTICE OF ULNGS ROM OVMBER 25JOIT TATUS ONERENC Eury Tria Dae one SeComaint Fied Mah 4 0

NOICE OF RULIGS FOMNOVEMBE5, 0 JOT SATU OFEECE


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1 I. INTRODUCTION

2 Dendant ASN Waer Center, LLC's motion to compel should be granted r a single,

3 undeniable reason - the specic identities of current and rmer residents who have ctual

4 inrmation relevant to this case is not attoey work product. Given that dendant seeks cts,

5 like te names of percipient witnesses, that are separate om any observation, evaluation, legal

6 research, strategy, or thought process of plaintifs counsel, the attoey work product privilege

7 does not apply.

8 In an efrt to sidestep this critical point, plainti argues that because her attorneys have

9 interviewed these individuals, their identities are now somehow protected as conditional work

10 product. But the attoey work product doctrine does not apply simply because inrmation is

11 obtained by or transmitted to an attoey. Rather, the inrmation has to reect an attorney's

12 analysis. The identities of current and rmer residents with inrmation relevant to this case is

13 not "work product createdby plaintis counsel.

14 In addition, inaccordance with the Court's suggestion om the November 1, 2013 hearing,

15 dendant has served plainti with special interrogatories that ask her to identify persons who

16 have knowledge of the cts upon which she bases her claims. Code of Civil Procedure Section

17 2017(a) expressly authorizes the use of discovery r purposes of obtining the identity and

18 location of persons having knowledge of any discoverable matter .... Cal. Civ.Proc.Code

19 2017(a). Similarly, Calirnia case law has consistently held this inrmation to be broadly and

20 routinely discoverable. Ci of Long Beach v. Superior Court (1976) 64 Cal.App.3d 65, 74 (citing

21 numerous Caliia cases).

22 Accordingly, the Court should order plainti to provide ctual responses specically

23 identifying the names, current addresses and current telephone numbers of the current and rmer

24 residents who she knows has inrmation relevant to this case.

25

26

27

28

1EFEA'S EPLY MEMAM SPP F M MPEL


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1 II.

2

3

DEFENDANT IS ENTITLED TO KNOW THE IDENTITIES OF WITNESSES

A. The Names, Current Addresses and Current Telephone Numbers of Currentand Former Residents with Relevant Inrmation is Not Attorney WorkProduct

4 Plainti has the initial burden to demonstrate that the inrmation sought by dendant is

5 atoey work product Fellows v. Superior Court (1980 ) 108 CalApp3d 55, 67("The party

6 claiming the attoey's work-product priilege has the initial burden of establishing that the matter

7 sought to be disclosed comes within the concept of an attoey's work product)Plainti argues

8 that the identities of current and rmer residents is conditional work product because plaintifs

9 counsel devoted signicant eort to track down potential witnesses and made a judgment as to

10 whether to take their statement (See PsOppBrf, p 3, IL 3-5) But as Fellows instructs, "[a]n

11 atoey's conditional' work product consists of material that is of a derivative or interpretative

12 nature h dm, h, d bk, , d, d d,

1 3 d x myd by y yz vdy m." d at

14 68 (Emphasis added ) "Material that is considered of a nonderivative or noninteretative nature

15 and that is vdy h does not constitute the attoey's work product d at 69.

16 (Emphasis added) "Major categories of nonderivative evidentiary material excluded om the

17 concept of an attoey's work product include ...m b v

18 h h m, h mb, dd, d " d

19 (Emphasis added); see also Ci of Long Beac 64 CalApp3d at 73 ("A list of persons with

20 knowledge of the relevant cts is quite dierent in its eect; it does not, of itself, reveal the

21 strategy of the attoey)It is precisely this type of witness inrmation that dendant is seeking

22 to discover here Given that the names, current addresses and current telephone numbers of

2 3 current and rmer residents with inrmation relevant to this case is not attoey work product,

24 plaintifs resal to provide this inrmation is improper

25 Plaintifs opposition, however, attempts to steer the Cour into believing that the identities

26 of current and rmer residents are not discoverable because her counsel has interviewed these

27 individuals Plainti ignores the ct that the work product doctrine does not apply simply

28 because an attoey obtains or uncovers relevant ctual inrmation Ci of Long Beac 64

2DEFENDANT'S REPY MEMORANDUM IN SUPPORT OF MOTON TO COMPE


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1 Cal.pp.3d at 72 ("Inrmation regarding events provable at trial, or the identity and location of

2 physical evidence, cannot be brought within the work product privilege simply by transmitting it

3 to the attoey.); Smith v. Superior Court (1961) 189 Cal.App.2d 6, 12 ("Even if the names and

4 addresses of the witnesses were known only to the attoeys, they would have to be disclosed on a

5 proper interrogatory addressed to the party.). The mere ct that plainti interviewed some of the

6 current and rmer residents does not mean that their identities (as evidentiary cts) are now

7 somehow work product, regardless of the efr involved to identi these individuals as witnesses.

8 Instead, as Felows and other cases illustrate, there is a clear distinction between attoey

9 work product, which is derived om an attoey's impressions, thoughts, conclusions, opinions

10 and legal research (i.e. "diagrams, charts, audit reports of books, papers, or records, and ndings,

11 opinions and reports of experts employed by a attoey to analyze evidentiary material ), and

12 evidentiary cts, like the names of percipient witnesses. Felows, 108 Cal.App.3d at 67-69; Ci

13 of Long Beach, 6 4 Cal.App.3d at 7 3; Cal. Civ. Proc. Code 2018 (indicating that work product

1 4 privilege only protects an attoey's impressions, thoughts, conclusions, opinions or legal

15 research); Cal. Civ. Proc. Code 2017(a) ("Discovery may be obtained of the identity and

16 location of persons having knowledge of any discoverable matter....").

17 Citing Nacht & Lewis Architects, Inc. v. Superior Court (1996) 47 Cal.App.4th 21 4,

18 plainti contends that fher responses identifying current and rmer residents with inrmation

19 relevant to this case would violate work product protection by revealing who plainti interviewed.

20 Plaintifs reliance on Nacht & Lewis Architects is misplaced, as the cts of this case are

21 distinguishable. Nacht & Lewis Architects involved a direct request r a list of individuals who

22 dendants' counsel interviewed. 47 Cal.App.4th at 216. Dendants objected on work product

23 grounds and plainti led a motion to compel. Id at 217. In sustaining dendants' work product

24 objection, the appellate court determined that the "[c]ompelled production of a list of potential

25 witnesses interviewed by opposing counsel would necessarily reect counsel's evaluation of the

26 case by revealing which witnesses or persons who claimed knowledge of the incident [already

27 idented by defendants' response to form interrogatory No. ] counsel deemed impoant

28 enough to interview. Id (Emphasis added.)

3DEFENDANT'S REPLY MEMORANDUM IN SUPPORT OF MOTION TO COMPEL


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1 Unlike the discovery requests in Nacht & Lewis Architects dendant's Form Interrogatory

2 12.1does not request the names of persons "who provided plainti with inrmation or "who

3 plainti interviewed. Instead, it permissibly asks plainti to identi percipient witnesses with

4 inrmation relevant to this case. Cal.Civ.Proc.Code 2 017(a )("Discovery may be obtained of

5 the identity and location of persons having knowledge of any discoverable matter....").

6 Plaintifs resal to provide this inrmation is inexplicable given that this exact same inrmation

7 was, in ct, provided in Nacht & Lewis Architects in response to the very same Form

8 Interrogatory 12. that plainti here reses to make complete. Plaintifs construction of Nacht

9 & Lewis Architects would lead to the absurd result that any discoverable inrmation would

10 somehow become protected work product simply by lling into the attoey's hands. This is not

11 the law.

12 Given that dendants Form Interrogatory 12.1seeks the identities of current and rmer

13 residents who plainti understands has cts perinent to the claims and denses asserted in this

14 lawsuit, this inrmation is clearly discoverable. As the case law makes abundantly clear, the

15 identities of "prospective or potential witnesses is discoverable, ctual inrmation that is

16 evidentiary in nature, and is not attoey work product.See e.g, Fellows, 108Cal.App.3d at 69.

17 ccordingly, the Cour should order plainti to provide rther responses specically identifying

18 the current and rmer residents who she knows has inrmation relevant to this case.1

19 B " d v B ff dvd d

2 0 Given that dendant relied on the standard denition of "incident, the Cour has raised

2 1 the issue of whether the term "incident in Form Interrogatory 12.1covers only Vagles own

2 2 tenancy or whether it is more broad. This denition does, in ct, cover plaintifs entire claim

2 3 given that it is broadly dened by the Judicial Council of Calirnia as including "the

2 4 circumstances and events surrounding the alleged accident, inju, or other occurrence or

2 5 breach of contract giving rise to this action or proceeding. (Emphasis added.) It would be

26

2 7

2 8

It is almost axiomatic that the names and addresses of witnesses is discoverable inrmation.Gonzalez v. Superior Court(19 9 5) 33Cal.App.4th 1539, 1546; Smith v. Superior Court(1961)189 Cal.App.2d 6, 11-12.

4DEEDT' REPY MEMODUM I UPPORT O MOTIO TO OMPE


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1 nonsensical r judicially approved rm interrogatories to cover only a small action of

2 plaintifs case.

3 For Interrogatory 121 asks plainti to identi witnesses that she (either personally or

4 through her counsel) knows to have knowledge of cts relevant to the case. Thus if plainti

5 knows the identities of witnesses with relevant inrmation beyond the Waer Center apartment

6 comunity such as current and rer residents at other apartment communities she has an

obligation to provide their naes current addresses and current telephone numbers in response to

8 Form Interrogatory 121 There is no signicant burden placed on plainti to provide inrmation

9 that she already knows.

10 In addition despite any extreely narrow interpretation of the term incident" plainti

11 still has an obligation to identify current and rmer residents within her personal experience In

12 this anner plainti specically alleges that aer her lease expired she spoke to individuals

13 who also leased apartent units managed by Dendant Archstone all of who were charged r

14 apartent cleaning and painting and carpet cleaning/replaceent at the end of their tenancies even

15 though they le their apartment units clean and in the sae condition it was at the inception of

16 their tenancies subject to reasonable wear and tear." (Third Amended Complaint i 22) Yet

1 plainti reses to specically identify even these current or rmer residents who are clearly

18 witnesses in the case.

19 II. FORM INTERROGATORY 7.

20 As raised in more detail in dendant's oving brief plaintifs response to For

21 Interrogory 1 1 contains insufcient cts as to what plainti did to clean her apartment nd

22 how she cleaned her apartent to be able to reach the conclusion that se le it in the same

23 condition as it was in at the inception of her residency. Plainti has now agreed to supplement

24 her response to For Inteogatory 11 as it relates to Requests r Adission Nos. 2, 3, 5, 6, ,

25 8, 9, and 11 Given that plainti has not yet served this suppleental response dendant reserves

26 the right to seek rther responses to this discovery request pending its receipt and revew of

2 plaintis suppleental responses.

28

5DEFENDANT'S REPLY MEMORANDUM I SUPPORT OF MOTION TO COMPEL


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1 III. CONCLUSION

2 For the regoing reasons, plaintif should identif the current and rmer residents she

3 rerences in her responses to Form Interrogatory 121 by stating their names, current addresses,

4 and current telephone numbers. In addition, to the extent there are any other witnesses that

5 plainti has conveniently le out of her response, she should supplement her response to Fo

6 Interrogatory12.1by identifyingalwitnesses that she knows to have inrmation relevant to this

7 entire case Finally, dendant reserves the right to seeka rther response to Form Interrogatory

8 17.1once it receives and reviewsplaintifs anticipatedsupplemental response.

9

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DATED: November 21, 2013

usw 804056126.1

6

F' RPY MMRM PPR F M MP


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1 CHRISTOPHER J HEALEY (SBN 105798chealey@mckennalongco

2 JAIKARA SINGH (SBN 201355)[email protected]

3 McKENNA LOG&

ALDRDGE LLP600 es Broadway Suie 26004 San Diego Califia 92101-3372

elephone 61923614145 Facsiile 6192328311

6 Atoeys r DendanASN aer Cener, LLC

7

NOV 21 03

Shern fCat, Lxcu\10O!i/l

8

9

SUPEIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF LOS ANGELES

10

11 ENNIFER VAGLE and GEORGE PONCEon behal o themselves and all others

12 similarly siuated;

13 Planifs

14 v

15 ARCHSTONE COMMUITIES, LLC aDelaware limited liability corporation ASN

16 WARNER CENTER LLC, a Delaware

limited liability corporaion, and AS LONG17 BEACH HARBOR, LLC a Delaware liitedliability corporaion and DOES 1 throgh

18 100 inclusive

19 Dendants.

20

21

22

23

24

25

26

27

28

Case No BC480931

ASN WANER CENTER, LLC'S NOTICEOF LODGMENT IN SUPPORT OFREPLY MEMOANDU OF POINTSAND AUTHORITIES IN SUPPORT OFDEFENDANTS MOTION TO COPEFURTHER DISCOVERY RESPONSES

Date November 25, 2013

Tie: 2:30 pmDept: 307

i h: = B , frDep 307 i Trial Dae None Set Comlaint Filed March 14 2012

NOTICE OF LODGMEN


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1 PLEASE TAKE NOTICE that dendant ASN Waer Center LLC hereby lodges with

2 the Court the llowing exhibits in support of its Reply Memorandum of Points and Authorities to

3 Defendants' Motion to Compel Furher Discovery Responses:

4

5

6

7

8

Exhibit D scriptionA Dendant ASN Waer Center LLC's First Set of Requests r Admissions

to Plainti Jeir Vagle

B Plainti Jennir Vagle's Objections and Responses to Dendant ASNWaer Center LLC's Requests r Admissions

9 DATED: November 2 1, 20 13

101 1

12

13

14

15

16

17

18

19

20

2 1

22

23

24

25

26

27

28

s 804072575.l

1NOTICE OF LODGMENT


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EXHIBIT "A


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PAU ASTIGS LLPHOAD M PRIVETTE (S# 1376)

NIOLAS BEGKIS S# 53588)BET ELER SB# 883)

3 515 Souh Fowe SreeTweny-Ff Floor

4 os Angeles A 9008Telephone: 3) 6836000

5 Facsile 3 67005

6 Aoeys enntAS WANE EE

8

9

SPEIOR OT OF TH STA TE OF AFOIA

OUY OF LOS ANGEES

10

1 EFER VAGE on bealf of esel all oher slaly suae

13

Pla

vs

AS WANER ENTE, LL a15 ele e la oporato ad

DOES throh 100 nlsive6

7

8

9

1

3

4

5

6

8

Defenants.

PROPOUDNG PARTY

RESPOG PATY

SET NO

ASE NO 8093

DEFENAT AS WANER CENER,LC'S IRST SET O EQUSTS ORAMSSONS TO PA JRVAGE

DEFEAT AS ARNE ENTR L

PLATIFF JEIFER VAGLE

OE

ASN AN C LCS ST S OF QSS O ASSO O LAT


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TO PANTF TO H TOYS O CO:

Pusunt to Calia Code of Civil Proede setion 2033010, et seq,

3 endant AS Wer Ceter LLC (AS Wer Ceter reqests h Plinti

enr Vagle 'Pnf) nswe these eests r Admssios sepely d lly in

5 wrg ad de oath d hat the nswes be sgned and veried by Pnti nd seed

6 n AS Waer enter wtn hit das ae seie heeof.

7 R Q S OR ADSSON8 R QU FOR ADSON N :9 di tha YO APT at ACHSTO WAR C

1 was prossional leaned pro to he neption of YOUR eny (As used erein he

tems "PAINTF O YOUR nd YOUSELF sha en Plainti Jenni

1 agle an of he gens epesentaives atoeys vesgaors nd any othe

13 peson or enty atg o on herbehalf As used hee the er RCSTO

1 WA CT shal ean the Arhsoe Waer Cener apartent ople

1 loaed at 1200 Kiidge Stee Woodland Hls Cala 9303 and referened in

16 pagraph 19 of YO COPLANT s used heein "COPAINT sh e

7 YO Seod mended Coplit led i this aon on Otobe 25 202 s sed

8 een the er PATT shal e he aprtment un YOU lesed t

19 ACSTO W C and rerened n paagrphs 9 nd 22 of YO

2 COLAIT)

R U S OR ADM NO dit h YOU did not lee YO APTNT at CTO

3 WA CNTR n the sme odition as tas n t the inepton of tenn

4 exlusve of ordny wear and tear

5 QU S FOR ADON NO 26 Adm tht YOU did no eu YO APTT t CTO

27 WA CTR o he se level of leanlness tha was in at he nepio of

8 YO enan

ASN WARNE CTR, L'S FIRST ST OF QUSS F ADMSSONS TO PAF


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R U S OR ADMSSO NO 42 mit tat YOU d nt pssinally clan YOUR PRMN at

3 RCTOE WRNER CETE at t cnclsin f YOR tnancy

QU S OR ADSSO NO t tat cti f $8000 YOUR scity pit y N

Wa Cnt nt imnt csts f aamnt clanin tat as

7 ncsay t t OR PMENT at CON WER CENER t t

8 sam lvl f clanlinss tat it was in at t inctin f YOUR tnancy

9 QU S OR ADMSSO NO 6 it tat capt i YOU PTENT at CON

WRER CENR as DIRTY DED a h cnclsi f YO tanc

1 (sued erei, the term DIRTY"sall eantat YOUR PARTMENT wa not

13 retued to the ame level of cleanliness that it wa inat the nception of YOUR tenacy,

1 incli but no imite tostans, irt gime an ilew. ue eei te e

"DMGE sall ean thaYOUR APARENT wassbject to damages exclusive

16 of oinary wea antea inc1ing but not imited o maks, nicks rip an holes.)

17 R QU S FOR ADSSO NO 18 dit tat t ctin f $6000 YOR city it y N

19 Wan Cnt sntd imsmnt csts f capt clain tat a ncsay

0 t t t capt in YOR PTNT at CTOE WRNER CENTER t

sam lvl clanlinss tat it as i a t inctin f YOUR tnancy

2 QU S OR ADMSSON NO. 823 mit tat t wal in YOU PRTMET at RC TO WER

CETE w DIRY GED at t cclin f YOUR tnancy

25 R U ST OR ADMSSON NO dmit tat t ctin f $ 14227 OUR city it y

27 Wan Cnt nt imsn csts f aitin ta a ncay

8

3

ASN A CET, LL'S IRS S O QUSS FO ADMSSOS PJ!F


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retute was o YOUR PRTT at RCHSO WER CENT t te

same eve o cleaniness and/or condton as they ere at the ncepton YR tenancy.

R Q S FOR ADSSON NO mit that YO dd not conduct an nvestgaton regardng te

5 ssteatc poic[es] and procedure[s] rerenced n pararaph 26 o O

6 COMLINT bere n te COPAT

7 R Q ST FO SSON NO dmit tat YO have no fcts andor evdence to sppo te aegaton that

9 AS Wer Cete as a "poc and procede awas chargng r aprment

O ceaning and pantn and capet ceaning or repaceent at the end o every tenac

1 egardess o the actua conditon o the apaent uit rerenced n paragraphs 26 and

2 27 YOR COMPNT

3 R Q S FOR ADSSON NO dmit that YO have never had n COUICATOS wth ther ex-

tenants o the RCHSTOE DES refrenced n pagraph 24 o YOU

6 COANT CONCERG EFE O EG TO te ssteatc

17 poces ad procedure[s] rerenced in paragraph 6 o OR COM (s

sed erein COUNCOS" l n nd o o rmo

9 xg r o y on omur o n or o of

2 o d phrases REFR or REATE TO or "COC a

21 gven subject maer sha mean cnstutes contas, ebodes comprses refects

identes states reates to, rers to deas wth, coents on, responds to descres

3 anazes evdences dscsses or s in any wa pernent to that sbject, drecty or

4 indrect n hoe or in pa.)

2 R QU ST FOR ADSSO NO 326 Admit tat YO have no cts and evidence to sppo the aegaton tat

the RCHSO DOES, ether recty or through ter coporate aates ave een

engaged n the busness owning deveopng managng antainng and easngOusw

AS A C S S O SS O ASS10S O F


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EXHIBIT 2Page 6


approxmately70 lti-unt apatmt coplexes throughout the State of Caliia,

2 icudig ut ot ied to the premses aleged owed endat AS WAE

3 CETER LC rereced in paragah 8 and 1 of YOR COMLANT

4 R U T FOR ADN NO 45 Admit that YOU have o cts ad/or evdence to uppo the aegato that

6 the ARCHSTONE DOES and endant ASN WANER CENTER, LLC are the aet,

7 parers, successor or emploees o each other reeced paraph 9 o YO

COMPLANT

9 R QU OR ADON NO. 5 Admit hat O have o cts aor evdece to upport the aegatio that

the ARCSTOE OES ad edant AS WNER CENTER, LLC . . doin

the thgs comaned of heren [acted] wth the curse and cope o such aecy,

3 paershp succeio, or empomet rerenced paragraph 9 o YO

4 COMPANT

5 R QU T FOR ADON NO 66 Adt that Y have o cts ad/or evdence to upport the aegato that

17 there a ut o owerhip bewee the CHSTOE DOES and edant AS

WAER CENTER C rerenced in paragraph 10 o YOR COLAINT.

19 R QU T FOR ADON NO 2 Adt that O have o ct ad/or evidence to uppo the aegato that

2 "each of the CSTOE DOES' Caa apamet compees, cudg edat

ASN WANER CENTER, LC, nder the same Achtoe aner and ogo

3 rerenced in paragaph of YO COJLANT

4 R QU FOR AON NO. 8:5 Adit that YO have no cts and/or evdece to ppot the aegatio that

6 the RCSTONE DOES have bee eag the resdeta ut at ther Caia

7 apament coexes ncdg Dendat ASN WANER ENTER LLC pursuat to

7403109.2 5-

ASN WAE CER, LLC'S FIRS SE F RQUESS FO ADMSSS PLAT


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stanaze leases an fms efene in paagahs 1 and o OU

COMLAN

R QUEST FOR ADMSSON NO. Admi ha YOU have no fs ad/o eiene to suppo the allegation that

"te ARCHSO DOS hae been leasng he esena unts pusuant o

6 staized leases and ms [at] pohibi an at all maeial imes hae pohibted,

haging f parment leaning and paning and ape leaning/epaemen i, a te end

8 othe enan, te enant eus he apament unit lean and n the same ondiion as t

9 was at the ineption o the enay subje o easonable wea and ea efeed n

paagaph 1 o OU COMLANT.

QUST FO ADMSSON NO 2: Amt hat YOU have no ts an/o eiene o suppo the allegaton a

3 "e ARCHSONE DOES an hei Calia apaen omplees inlung N

WANER CENER, LC, hod hemselves ot as a ay entity alled 'stone

1 efened in paagaph o YU COMLANT

6 REQU ST FOR DMSSO NO 2:7 Amit tha OU have no fts an/o eviene to suppo the alegaion hat

8 "the emloyees a e ARCHSTONE DOES Caliia apamen ompexes, inluding

19 the employees a ASN WAER CETER LLC e unimly raine and employed by

0 e ARCHSTONE DOES eene in paagaph 7 o YOUR COMLAN

4

5

6

7

8W# -6

AS W CER, LC' S IRS SE OF REQUESS OR DMISSS O PITJF


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I R Q ST O ASSON NO 22 Admit thatYOUhave no fcts and/or eidece to suppor he alegaon hat

3 "theARCHSTONEDOSmontor ad egulatetheir employees attheir Calfia

apament compexes, includngher employees at ASN WARR CENTER LC, to

sur h cmpy w hr m pcs d pcurs rc

6 rrph 8 OUR COMPAT

7

0

13

14

15

6

7

19

0

3

25

6

7

DATED Jur 31 203

LEGA_US_

A HASTIGS LPHOWA M PRVETTEICOAS J. BGAKS

yL Attorey AS WAR CTER C

-7-

A A NT C lR O U OR AO O P


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PROOF OF SERVCE

STATE O ALFOA ss

3 ITY OF OS ANGES A OT OFLS AGLES

4

5 I am emploed n he o os Angees and out o Los geles, aeo ala a oer e age o , and ot a part o he wtn acon. My bsnss

6 adress s Sot loer Steet Twent- Floor Los ngels aa 90071.-

7

9

0

1

5

6

7

9

0

3

4

5

6

7

8

On Janar I seve e egog docuen(s) descibed s:

DEFEDANT ASN WANER ENTER, LLC'S FIRS SE OF REQUT FORADMSSONS TO PLAINFF JENNIFER VGLE

on te nteresed pares as llows

R Rex Pis, Esq. (rparrs@eparscom)Aleander R Wheee Esqawheee@reparisco)Ky Szeto s kszeto@epariso)R Re aris Law Fi43364 0th tree WestLanase Caifa oe: (66) 949595 66 949754

LEXIS NEIS FLE & SERVE:

By posting drecl he LexNe Fe ad Serve webe ahtp://fleaderve eisnex.com

I declare de penalt o perjr nde te laws o the Sate o alfaa te aboe s re and corec

Exected on anuar at os geles ala

PROOF EVICE


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EXHIBIT "B


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R Rex Parris, Esq SBN 96567)Alexander R Wh r, Esq. SBN 239541)

2 Kit Szeto, Esq (SBN 258 1 6)Joh M. Bickfrd Esq SBN 280929)

3 R. REX pAIS L w IRM43364 10th Street West4 Lancaster, Caliia 93534Telehone 661) 949-2595

5 Facsmile (61949-75246

Attorneys r Plaintif and the Putative Class7

8

9SUPERIOR COURT OF THE STATE OF CALIFORNIA

FOR THE COUNTYOF LOS ANGELES - CIVIL WEST COURTHOUSE

10

11 JENNIER VAGLE, on behal o hersel andall others similarly situated;

Plaintif,

v.

12

13

14ASN WANER CENTER, LLC, a Delaware

15 limited liabili corporation, and Does 1through 100 inclusive;

16

17

18

19

20

21

22

23

24

25

26

27

28

Dendants

Case No: BC48093 1

LSS CTION

LINTIFF JNNIF VGL'SBCTIONS ND ESPONSS TOFNDANT ASN WN NT,'S QUESTS FO DMISSIN(T N)

Assigned r All Purposes to theonorabl William F Highberger,Department 307]

PLAINTIFF'S OBJECINS AND RESNSES T EFENDANT WANE ENTE, 'S

EQUESTS F DMISSIN (ET ONE)


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3

ROOUNDING ARTY:

RESONDG ARTY:

SET NO:

Dendant ASN Wae Cente, LLC

laintif Jenni Vagle

One

4 laintif Jenni Vagle ("lainti) heeby objects and esponds to Dendant

ASN Wae Cente, LLC ("Dendant) Requests Admission (Set One) as fllows:

6

7 PRELMNRY STTEMENT

8 laintif has not completed he ctual nd legal investigation, discovey o tial

9 pepaation. laintif expessly eseves the ight to continue discovey and investigation

1 heein additional infmation that might be esponsive to these Requests

11 Accodingly, the objections and esponses set fth below epesent only infmation

1 cuently known to laintif fllowing a easonable investigation in the time allowed f

13 laintif to espond to Dendants Requests The objections and esponses set th

I4 below do not peclude lainti fom late elying on documents and infmation

1 discoveed pusuant to subsequent investigation o discovey which, i known at this

16 time, would have been included in these objections and esponses

17 The fllowing objections and esponses ae made without waiving and while

18 peseving: (a) the ight to aise in any subsequent poceeding o at the tial o this o any

19 othe action all questions o authenticity, fundation, elevancy, mateiality, pivilege,

and evidentiay admissibility o any infmation o document identied o poduced in

1 esponse to the nstant Requests; (b) the ight to object on any gound to the use o

intoduction into evidence o any infmation o document in any subsequent poceeding

3 o at the tial o this o any othe action on any gound; and ( c) the ight to object on any

24 gound at any time to additional discovey

6

7

8 / / / /

PAINTIFFS OBJCTINS AN SNSS T FNANT WAN NT S

USTS F MISSIN (T ON)


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GENERAL OBJECTIONS

2 The fllowing General Objections are made with respect to each and every

3 Request, and are incorporated into each Specic Objection set rth below, regardless o

4 whether they are explicitly mentioned in a given Specifc Objection Notwithstanding

5 these General Objections, without waiving them and consistent with them, laintif will

6 respond to Dendant's Requests, to the extent not objected to, in accordance with

7 Califia Civil Procedure Code sections 2033.210 et seq

8 1 lainti objects to each and every Request to the extent it seeks

9 infrmation protected by the attorney-client privilege, the attoey workproduct

10 doctrine, the privilege fr settlement discussions and ofers o compromise, and any other

11 privilege or immunity recognized by this court

12 2 lainti objects to each and every Request to the extent that it contains

13 terms or phrases that are undened and are, therefre, vague, ambiguous, and capable o

14 various interpretations

15 3 lainti has not completed its ctual and legal investigation Accordingly,

16 the answers and objections set frth below relate only to infrmation currently nown

17 fllowing a reasonable search in responding to these Requests

18

19 R QU STS FOR ADMISSION20 R QU ST FOR ADMISSION NO. 1:21 Admit that YOR AARTMENT at ARCHSTONE WARNER CENTER was

22 prossionally cleaned prior to the inception o YOR tenancy (As used herein, the

23 terms "LAINTIFF, "YOU, "YOUR and "YORSELF shall mean laintif Jennifr

24 Vagle and any o her agents, representatives, attoeys, investigators, an any other

25 person or entity acting fr or on her behal As used herein, the term "ARCHSTONE

26 WARNER CENTER shall mean the Archstone Waer Center apartment complex

27 located at 2 1200 Kittridge Street, Woodland Hills, Califia 91303, and refrenced in

28 paragraph 19 o YOUR COMLAINT As used herein "COMLAINT shall mean

2

PLAINTIFF'S OBJECTINS AND RESNSES T EFENDANT WANE ENTE, s

EQUESTS F DMISSIN (ET ONE)


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YOR Second Amended Complaint led in this action on Octobe 25 20 12 As used

heein the tem "AARTMENT shall mean the apatment unit YO leased at

3 ARCHSTONE WARNER CENTER and efenced in paagaphs 19 and 22 o YOUR

4 COMLAINT)

6 RESPONSE TO R QU ST OR ADMSSON NO :7 In addition to the going Geneal Objections lainti objects to this Request on

8 the gounds that it is compound ovely boad as to both time and scope budensome

9 oppessive not easonably paticulaied haassing and seeks inmation that is neithe

1 elevant no easonably calculated to lead to the discovey o admissible evidence

11 lainti fthe objects to this Request on the gounds that it is vague and ambiguous as

1 to the tem "possionally cleaned lainti also objects to this Request to the extent it

13 seeks inmation which is potected fom discovey by the attoeyclient pivilege

14 wok poduct doctine and/o any othe applicable pivilege potection o immunity

1 ecognied in case law o coned by statute and to the extent that it infinges upon

16 laintis ight to pivacy Finally lainti objects to this Request as it seeks

17 inmation aleady in Dendant's possession custody o contol

18 Subject to and notwithstanding these objections and the egoing Geneal

19 Objections consistent with them without waiving any o them and to the extent that this

Request should be intepeted as equesting only elevant and nonpivileged inmation

1 laintifesponds as llows A easonable inquiy conceing the matte in the

paicula equest has been made and the inmation known o eadily obtainable is

3 insucient to enable that paty to admit o deny that the apatment was "pofssionally

24 cleaned."

!Ill

6 IIII

7 IIII

8 ////

3

PLAINTIFF'S BJECTINS AND ESNSES T EFENDANT WANE ENTE 'S

EQESTS F DMISSIN (ET ONE)


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REUEST FOR DMSSON NO 2: Admt that YOU dd not leave YOUR AARTMENT at ARCHSTONE

3 WANER CENTER n te same condton as t was n at the ncepton o YOUR

4 tenancy, exclusve o odnay wea and tea

5

6 RSPONS TO REUEST FOR DMSSON NO. 2:7 In addton to the fgong Geneal Objectons, lant objects to ths Request on

8 the gounds that t s compound, ovely boad as to both tme and scope, budensome,

9 oppessve, not easonably patculazed, haassng, and seeks nmaton that s nethe

10 elevant no easonably calculated to lead to the dscovey o admssble evdence

11 lantf also objects to ths Request to the extent t seeks nmaton whch s potected

1 fom dscovey by the attoeyclent pvlege, wok poduct doctne, and/o any othe

13 applcable pvlege, potecton, o mmunty ecognzed n case law o coned by

14 statute, and to the extent that t nfnges upon lants ght to pvacy lant

15 the objects to ths Inteogatoy to the extent t mples that lant has the buden o

16 poo as to the easonableness o the amount Defndant wthheld fom he secuty

17 depost (See Cvl Code, 19505, subd () ["In any acton unde ths secton, the

18 landlod o the landlods successos n nteest shall have the buden o poo as to the

19 easonableness o the amounts clamed o the authoty pusuant to ths secton to deman

0 addtonal secuty deposts]) Fnally, lantf objects to ths Request as t seeks

1 nmaton aleady n Defndants possesson, custody, o contol

Subject to and notwthstandng these objectons and the fegong Geneal

23 Objectons, consstent wth them, wthout wavng any o them, and to the extent that ths

4 Request should be ntepeted as equestng only elevant and nonpvleged nmaton,

25 lantf esponds as llows: Deny

6 !Ill

7 I I II

8 II II

4

PLANTS OBETNS ND RESNSES T EENDANT WARNER ENTER S

UESTS R DMSSN (ET NE)


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EXHIBIT 2Page 7


QU ST FO DMSSON NO : Admit that YOU did not etu YOUR AARTMENT at ARCHSTONE

3 WARNER CENTER to the same level o cleanliness that it was in at the inception o

4 YOUR tenancy

6 ESPONSE TO QU ST FO DMSSON NO :7 In addition to the going Geneal Objections, lainti objects to this Request on

8 the gounds that it is compound, ovely boad as to both time and scope, budensome,

9 oppessive, not easonably paticulaied, haassing, and seeks inmation that is neithe


11 lainti the objects to this Request on the gounds that it is vague and ambiguous as

1 to the tem "possionally cleaned lainti also objects to this Request to the extent it

13 seeks ination which is potected fom discovey by the attoneyclient pivilege,

14 wok poduct doctine, and/o any othe applicable pivilege, potection, o immunity

1 ecognied in case law o confed by statute, and to the extent that it infinges upon

16 laintis ight to pivacy lainti the objects to this Inteogatoy to the extent it

17 implies that lainti has the buden o poo as to the easonableness o the amount

18 Defndant withheld fom he secuity deposit (See Civil Code, 19505, subd ( ["In

19 any action unde this section, the landlod o the andlod's successos in inteest shall

0 have the buden o poo as to the easonableness o the amounts claimed o the authoity

1 pusuant to this sction to demand additional secuity deposits]) Finally, lainti

objects to this Request as it seeks inmation aleady in Deendant's possession,

3 custody, o contol

24 Subject to and notwithstanding these objections and the egoing Geneal

Objections, consistent with them, without waiving any o them, and to the extent that this

6 Request should be intepeted as equesting only elevant and nonpivileged inmation,

27 laintif esponds as llows Deny.

8 ////

PLAINTIFF' OJECTIN AND ENE T EFENDANT WANE ENTE '

EQUET F DMIIN (ET ONE)


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U ST FO ADMSSO O 4: Admitthat YOU did notprofssionally cleanYOUR APARTMENT at

3 ARCHSTONE WARNERCENTERat the conclusiono YOURtenancy.

4

ESPOSE TO QU ST FO ADMSSO O 4:6 In addition to the frgoingGeneral Objections, Plaintiobjects tothis Request on

7 the grounds that it is compound, overly broad as to both time and scope, burdensome,

8 oppressive, not reasonably particularized, harassing, and seeks infrmation that is neither

relevant nor reasonably calculated to lead to the discovery o admissible evidence.

1 Plaintif frther objects to this Request on the grounds that it is vague and ambiguous as

11 to the term "prossionally cleaned. Plainti also objects to this Request to the extent it

1 seeks infrmation which is protected fom discovery by the attoey-client privilege,

13 work product doctrine, and/or any other applicable privilege, protection, or immunity

14 recognized in case law or conrred by statute, and to the extent that it infinges upon

1 Plainti's right to privacy. Additionally, Plaintif objects to this Request to the extent it

16 implies that a tenant must hire a "profssional to clean and paint his/her aparment in

17 order to receive a fll refnd o his/her security deposit. Plainti frther objects to this

18 Interrogatory to the extent it implies that Plaintif has the burden o proo as to the

19 reasonableness o the amount Dendant withheld fom her security deposit. (See Ciil

Code, 19505, subd. () ["In any action under this section, the landlord or the landlord's

1 successors in interest shall have the burden o proo as to the reasonableness o the

amounts claimed or the authority pursuant to this section to demand additional security

23 deposits].) Finally, Plaintif objects to this Request as it seeks infrmation already in

24 Dendants possession, custody, or control.

Subject to and notwithstanding these objections and the fregoing General

6 Objections, consistent with them, without waiving any o them, and to the extent that this

27 Request should e interpreted as requesting only releant and non-priileged inrmation,

8 Plaintif responds as fllows: Admit.

6

PLAINIFF' OECIN AND ENE EFENDAN WANE ENE, '

EQUE F DMIIN (E ONE)


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QU ST FO DSSON NO : Admit that the deduction o $80.00fomYOUR security deposit by ASN Waer

3 Center represented reimbursement r costs o apartment cleaning thatwas necessary to

4 retu YOUR APARTMENT at ARCHSTONE WARNERCENTER tothesame level of

5 cleaniness that it was in at the inception o YOUR tenancy

6

7 RESPONSE TO QU ST FO DSSON NO :8 In addition to the rgoing General Objections, Plainti objects to this Reuest on

9 the grounds that it is compound, overy broad as to both time and scope, burdensoe,

10 oppressive, not reasonably particularized, harassing, and sees inrmation that is neither

11 relevant nor reasonably calcuated to lead to the discovery o admissible evidence

1 Plainti also objects to this Reuest to the extent it sees infrmation which is protected

13 fom discovery by the attoeyclient privilege, wor product doctrine, and/or any other

14 applicable priviege, protection, or immunity recognized in cas aw or conrred by

I 5 statute, and to the extent that it infinges upon Plaintis right to privacy. Painti

16 frther objects to this Reuest to the extent it implies that Plainti has the burden o

17 proo as to te reasonableness o the amount Dendant withheld fom her security

18 deposit. (See Civil Code, 19505, subd. ( ["In any action under this section, the

19 landlord or the landlords successors in interest shal have the burden o proo as to the

0 reasonabeness o the amounts caimed or the authority pursuant to this section to dean

1 additional security deposits]. Finally, Plainti objects to this Reuest as it sees

infrmation already in Dendants possession, custody, or control

3 Subject to and notwithstanding these objections and the fregoing General

4 Objections, consistent with them, without waiving any o the, and to the extent that this

5 Reuest shoud be interpreted as reuesting only relevant and non-privileged infrmation,

6 Plainti responds as llows Deny

7 /

8 ////

7

PLAINTIS OECTINS AND ESNSES T EENDANT WANE ENTE S

QUESTS DMSSIN (ET ONE)


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R U ST OR AMSSON NO 6: Admit that the carpet in YOUR AARTMENT at ARCHSTONE WARNER

3 CENTER as DIRTY or DAMAGED at the conclusion o YOUR tenancy. (As used

4 herein the term "DIRTY shall mean that YOUR AARTMENT as not retued to the

5 same level o cleanliness that it as in at the inception o YOUR tenancy including but

6 not limited to stains dirt grime and milde. As used herein the term "DAMAGED

7 shall mean that YOUR AARTMENT as subect to damages exclusive o ordinary

8 ear and tear including but not limited to marks nicks rips and holes.

9

l0 RESPONSE TO R QU ST OR AMSSON NO 6:11 In addition to the frgoing General Obections lainti obects to this Request on

1 the grounds that it is compound overly broad as to both time and sope burdensome

13 oppressive not reasonably particularized harassing and seeks infrmation that is neither

14 relevant nor reasonably calculated to lead to the discovery o admissible evidence.

15 laintif also obects to this Request to the extent it seeks infrmation hich is protected

16 fom discovey by the attoey-client privilege ork product doctrine and/or any other

17 applicable privilege protection or immunity recognized in case la or conrred by

18 statute and to the extent that it ininges upon laintis right to privacy. lainti

19 fther obects to this Request to the extent it implies that lainti has the burden o

0 proo as to the reasonableness o the amount Dendant ithheld fom her security

1 deposit. (See Civil Code 19505, subd () "In any action under this section the

landlord or the landlord's successors in interest shall have the burden o proo as to the

3 reasonableness o the amounts claimed or the authority pursuant to this section to deman

4 additional security deposits]. Finally laintif obects to this Request as it seeks

5 inrmation already in Dendants possession custody or control.

6 Subect to and notithstanding these obections and the fregoing General

7 Obections consistent ith them ithout aiving any o them and to the extent that this

8 ////

8

PLAITFFS OBECTINS AND SNSES T EFENDANT WANE ENTE S

QUESTS F DMSSN (ET ONE)


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EXHIBIT 2Page 74


Reuest shuld be interpreted as reuesting nly relevant and nnprivileged infrmatin

Plainti respnds as fllws: Deny

3

4 R Q ST OR DSSON NO 7:5 Admit that the deductin $6000 fm YOUR security depsit by ASN Waer

6 Center represented reimbursement fr csts carpet cleaning that was necessary t

7 retu the carpet in YOUR APARTMENT at ARCSTONE WAER CENTER t the

8 same level cleanliness that it was in at the inceptin YO tenancy

9

10 SONSE TO R Q ST OR DSSON NO 11 In additin t the rging General Objectins, Plainti bjects t this euest n

1 the grunds that it is cmpund, verly brad as t bth time and scpe, burdensme,

13 ppressive, nt reasnably particularied, harassing, and seeks infrmatin that is neither

14 relevant nr reasnably calculated t lead t the discvery admissible evidence

15 Plaintif als bjects t this Reuest t the extent it seeks infratin which is prtected

16 m discvery by the atteyclient privilege, wrk prduct dctrine, and/r any ther

17 applicable privilege, prtectin, r immunity recgnied in case law r cnfrred by

18 statute, and t the extent that it infinges upn Plaintis right t privacy. Plainti

19 frther bjects t this Reuest t the extent it implies that Plainti has the burden

0 pr as t the reasnableness the amunt Deendant withheld fm her security

1 depsit. (See Civil Cde, 19505, subd (I) ["In any actin under this sectin, the

landlrd r the landlrd's successrs in interest shall have the brden pr as t the

3 reasnableness the amunts claimed r the authrity pursuant t this sectin t deman

4 additinal security depsits]) inally, Plainti bjects t this Reuest as it seeks

5 inrmatin already in Dendants pssessin, custdy, r cntrl

6 Subject t and ntwithstanding these bjectins and the freging General

7 Objectins, cnsistent with them, withut waiving any them, and t the extent that this

8 /

9

PLAIIFF'S OBJECIS AD ESSES EFEDA WAE EE 'S

EQESS F DMSSI (E OE)


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Request sould be interpreted as requesting only relevant and non-privileged infrmation

Plaintif responds as fllows Deny

4 Q T FO DMON NO :5 Admit that the walls in YOUR APARTMENT at ARHSTONE WARNER

6 ENTER were DIRTY or DAMAGED at the conclusion o YOUR tenancy.

7

8 REPONE TO Q T FO DMON NO : In addition to the rgoing General Objections Plainti objects to this Request on

10 te grounds that it is compound overly broad as to both time and scope burdensome

11 oppressive not reasonably particularized harassing and seeks infrmation that is neither

1 relevant nor reasonably calculated to lead to the discovery o admissible evidence

1 Plaintif also objects to this Request to the extent it seeks infrmation which is protected

14 fom discovery by the attoeyclient privilege work product doctrine and/or any other

15 applicable privilege protection or immunity recognized in case law or confrred by

16 statute and to te extent that it infinges upon Plaintis right to privacy. Plaintif

17 rther objects to this Request to the extent it implies that Plaintif has te burden o

18 proo as to the reasonableness o the amount Dendant witheld fom her security

1 deposit (See ivil ode 19505, subd. ( ["In any action under this section the

0 landlord or the landlord's successors in interest shall have the burden o proo as to the

1 reasonableness o the amounts claimed or te authority pursuant to tis section to deman

additional security deposits Finally Plaintif objects to this Request as it seeks

23 infrmation already in Dendant's possession custody or control

4 Subject to and notwithstanding these objections and the regoing General

5 Objections consistent with tem without waiving any o them and to the extent that this

6 Request should be interpreted as requesting only relevant and non-privileged infrmation

27 Plaintif responds as fllows Deny

8 ////

0

PLAINTIS OBJECTINS AND ESNSES T EENDANT WANE ENTE S

EQUESTS DMISSIN (ET ONE)


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EXHIBIT 2Page 76


QUST FO DMSSON NO 9: Admit that the deductionof$142.27 omYOUR security deposit by ASN Waer

3 Centerrepresented reimbursement fr costso paintingthat was necessaryto retuthe

4 walls o YOUR APARTMENT at ARCSTONE WANER CENTER to the sameevel

5 o cleaniness and/or condition as they were at the inception o YOUR tenancy

6

7 SPONS TO QUST FO DMSSON NO 9:8 In additionto the rgoing General Objections, Paintif objects to this Request on

9 the grounds that it is compound overly broad as to both time and scope burdensome

10 oppressive not reasonaby particularized harassing and seeks inrmation that is neither

11 relevant nor reasonably calcuated to lead to the discovery o admissible evidence

1 Plaintif aso objects to this Request to the extent it seeks inrmation which is protected

13 fom discovery by the attoey-cient priviege work product doctrine and/or any other

14 appicable privilege protection or immunity recognized in case law or conrred by

15 statute and to the extent that it infinges upon Plaintis right to privacy Plaintif

16 frther objects to this Request to the extent it implies that Painti has the burden o

17 proo as to the reasonabeness o the amount Deendant withheld fom her security

18 deposit See Civi Code 9505 subd (I) ["In any action under this section the

19 landlord or the andlords successors in interest shal have the burden o proo as to the

0 reasonabeness o the amounts claimed or the authority pursuant to this section to deman

1 additional security deposits] Finally Paintif objects to this Request as it seeks

inrmation already in Defndants possession custody or control


24 Objections consistent with them without waiving any o them and to the extent that this

25 Request shoud be interpreted s requesting only reevant and non-privileged inrmation

6 Plaintif responds as lows: Deny

7 /

8 I

11

PLANTFF OCTN AND N T FNDANT WAN NT

QUT F DMIN T ON)


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QU ST FO DMSSON NO : Admit that YOU did not conduct any investigation regarding the "systematic

3 polic[ies] and procedure[s] reerenced in paragraph 26 o YOUR COMPLANT befre

4 fling the COMPLANT

5

6 ESPONSE TO QU ST FOR DMSSON NO :7 n addition to the rgoing General Obections, Plaintif obects to this Request on

8 the grounds that it is compound, overly broad as to both time and scope, burdensome,

9 oppressive, not reasonably particularized, harassing, and seeks infrmation that is neither

10 relevant nor reasonably calculated to lead to the discovery o admissible evidence

11 Plainti also obects to this Request to the extent it seeks infrmation which is protected

1 fom discovery by the attoey-client privilege, work product doctrine, and/or any other

13 applicable privilege, protection, or immunity recognized in case law or confrred by

14 statute, and to the extent that it infinges upon Plaintis right to privacy Finally,

15 Plaintif obects to this Request as it seeks infrmation already in Defndant's possession,

16 custody, or control

17 Subect to and notwithstanding these obections and the fregoing General

18 Obections, consistent with them, without waiving any o them, and to the extent that this

19 Request should be interpreted as requesting only relevant and non-privileged infrmation,

0 Plaintif responds as fllows: Deny

1

QU ST FO DMSSON NO :3 Admit that YOU have no fcts and/or evidence to support the allegation that ASN

4 Waer Center has a "policy and procedure o always charging fr apartment cleaning

25 and painting and carpet cleaning or replacement at the end o every tenancy, regardless f6 the actual condition o the apartment unit refrenced in paragraphs 26 and 27 o YOUR

7 COMPLANT

8 ////

1

PAINTIFFS OBJECINS AND ESNSES EFENDAN ANE ENE 'S

EQUESS F DMISSIN (E ONE)


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SPONS O QUS FOR AMSSON NO 11: In addition to the going Geneal Objections, Plaintif objects to this Request on

the gounds that it is compound, ovely boad as to both time and scope, budensome,

4 oppessive, not easonably paticulaized, haassing, and seeks inmation that is neithe


6 Plainti also objects to this Request to the extent it seeks inmation which is potected

7 om discovey by the attoeyclient pivilege, wok poduct doctine, and/o any othe

8 applicable pivilege, potection, o immunity ecognized in case law o confed by

9 statute, and to the extent that it infinges upon Plainti's ight to pivacy. Finally,

0 Plaintif objects to this equest as it seeks inmation aleady in Dendant's possession,

custody, o contol.

Subject to and notwithstanding these objections and the egoing Geneal

13 Objections, consistent with them, without waiving any o them, and to the extent that this

14 Request should be intepeted as equesting only elevant and nonpivileged inmation,

I5 Plaintif esponds as llows Deny

16

7 RQUS FOR AMSSON NO 12: 8 Admit that YOU have neve had any COMMUNICATIONS with "othe ex-

9 tenants o the ARCHSTONE DOES eenced in paagaph 24 o YOUR

0 COMPLAINT CONCERNG, REFERRING OR RELATING TO the "systematic

polic[ies] and pocedue[s] eenced in paagaph 26 o YOUR COMPLAINT. (As

used heein, "COMMUNICATIONS shall mean and e to all ms o inmation

exchanged, eithe witten, oal, by telephone, fcsimile, compute o any othe mode o

4 tansmission. As used heein, the phases "REFER o RELATE TO o

5 "CONCEING a given subject matte shall mean constitutes, contains, embodies,

6 compises, eects, identifes, states, elates to, efs to, deals with, comments on,

7 esponds to, descibes, analyzes, evidences, discusses o is in any way petinent to that

8 subject, diectly o indiectly, in whole o in pat)

PLAINTFFS OBJECTINS AN ESNSES T EFENANT WANE ENTE S

QESTS F MSSIN (ET ONE)


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RESPONSE TO R QU ST FOR ADMISSION NO. 12:2 In addition to the rgoing eneral Objections, Plainti objects to this Request on

3 the grounds that it is comound, overly broad as to both time and scoe, burdensome,

4 oressive, not reasonably articularized, harassing, and seeks inrmation that is neither

5 relevant nor reasonably calculated to lead to the discovery of admissible evidence

6 Plainti also objects to this Request to the extent it seeks inrmation which is rotected

7 om discovery by the attoey-client rivilege, work roduct doctrine, and/or any other

8 alicable rivilege, rotection, or immunity recognized in case law or conrred by

9 statute, and to the extent that it ininges uon Plaintifs right to rivacy inally,

0 Plainti objects to this Request as it seeks inrmation already in Dendant's ossession,

custody, or control


13 Objections, consistent with them, without waiving any o f them, and to the extent that this

14 Request should be interreted as requesting only relevant and non-rivileged inrmation,

15 Plainti resonds as llows: Deny

6

7 R QU ST FOR ADISSION NO. 13:8 Admit that YOU have no cts andor evidence to suort the allegation that "the

9 ARCHSTONE DOES, either directly or trough their cororate aliates, have been

20 engaged in the business of owning, develoing, managing, maintaining, and leasing

2 aroximately 70 multi-unit aartment comlexes throughout the State of Caliia,

22 including but not limited to the remises allegedly owned by Dendant ASN WAER

23 CENTER, LLC rerenced in aragrahs 8 and 11 of YOUR COMPLAINT

24

25 RESPONSE TO R QU ST FOR ADMISSION NO. 13:26 In addition to the rgoing eneral Objections, Plainti objects to this Request on

27 the grounds that it is comound, overly boad as to both time and scoe, burdensome,

28 oressive, not reasonably aricularized, harassing, and seeks inrmation that is neither

4

PLAINTFF'S OBJECTNS AND RESNSES T EFENDANT WARNE ENTER, SEQUESTS F DMSSN (ET ONE)


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relevant nor reasonably calculated to lead to the discovery of admissible evidence

2 Plainti also objects to this Request to the extent it seeks infrmation which is protected

3 fom discovery by the attoey-client privilege, workproduct doctrine, and/or any other

4 alicable rivilege rotection or immunity recognized in case law or conrred by

5 statute and to the extent that it ininges uon Plaintifs right to rivacy inally

6 Plainti objects to this Request as it seeks inrmation already in Dendants ossession

7 custody or control

8 Subject to and notwithstanding these objections and the regoing eneral

9 Objections consistent with them without waiving any of them and to the extent that this

0 Request should be interreted as requesting only relevant and nonrivileged inrmation

Plainti resonds as llows: Deny

2

3 R U ST FOR ADMISSION NO. :4 Admit that YO have no cts andor evidence to suort the allegation that the

5 ARCHSTONE DOES and Dendant ASN WARNER CENTER LLC are the agents

6 artners successors or emloyees of each other rerenced in aragrah 9 of YOR

7 COPLAINT

8

9 RESPONSE TO R QU ST FOR ADMISSION NO. 20 In addition to the rgoing eneral Objections Plainti objects to this Request on

2 the grounds that it is comound overly broad as to both time and scoe burdensome

22 oressive not reasonably articularized harassing and seeks inrmation that is neither



25 om discovery by the attoey-client rivilege work roduct doctrine andor any other

26 alicable rivilege rotection or immunity recognized in case law or conrred by

27 statute and to the extent that it ininges uon Plaintifs right to rivacy inally

28

5

PLAINTIFF'S OJECTINS AND ESNSES T EFENDANT WAN E NTE, SEQUESTS F DMISSIN (T ONE)


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lainti objects tothis Request as it seeks infmation aleady inDendant's possession,

2 custody, o contol.

3 Subject to and notithstanding these objections and the egoing eneal

4 Objections, consistent ith them, ithout aiving any of them, and to the extent that this

5 Request should be inteeted as equesting only elevant and non-ivileged inmation,

6 lainti esonds as llos Deny

7

8 R QU ST FOR ADISSION NO. :9 Admit that YOU have no cts and/o evidence to suot the allegation that "the

0 ARCHSTONE DOES and Dendant ASN WARNER CENTER, C . . . in doing the

. things comlained of heein, [acted] ithin the couse and scoe of such agency,

2 atneshi, succession, o emloyment eenced in aagah 9 of YOUR

3 COMAINT.

4

15 RESPONSE TO R QU ST FOR ADISSION NO :6 In addition to the going eneal Objections, lainti objects to this Request on

7 the gounds that it is comound, ovely boad as to both time and scoe, budensome,

8 oessive, not easonably aticulaized, haassing, and seeks inmation that is neithe

9 elevant no easonably calculated to lead to the discovey of admissible evidence.

20 lainti also objects to this Request to the extent it seeks inmation hich is otected

2 om discovey by the attoeyclient ivilege, ok oduct doctine, and/o any othe

22 alicable ivilege, otection, o immunity ecognized in case la o coned by

23 statute, and to the extent that it ininges uon laintifs ight to ivacy. inally,

24 lainti objects to this Request as it seeks inmation aleady in Dendants ossession,

25 custody, o contol.

26 Subject to and notithstanding these objections and the egoing eneal

27 Objections, consistent ith them, ithout aiving any of them, and to the extent that this

28 I I I I

6

PTFFS OBJECTS D RESSES T EFEDT WRE ETER 'SEUESTS F DMSS (ET OE)


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EXHIBIT 2Page 82


Request should be interpreted as requesting only relevant and nonprivileged inrmation

2 Plainti responds as llows: Deny

3

4 R QU ST FOR ADMISSION NO. 6:5 Admit that YU have no cts and/or evidence to support the allegation that there

6 is a unity of ownership between the ARCHSTNE DES and Dendant ASN

7 WANER CENTER LLC referenced in paragraph 10 of YUR CMPLAT.

8

9 RESPONSE TO R QU ST FOR ADMISSION NO. 6:0 In addition to the rgoing eneral bjections Plainti objects to this Request on

the grounds that it is compound overly broad as to both ime and scope burdensome

2 oppressive not reasonably particularized harassing and seeks inrmation that is neither


4 Plainti also objects to this Request to the extent it seeks inrmation which is prtected

5 om discovery by the attoeyclient privilege work product doctrine and/or any other

6 appicable privilege protection or immunity recognized in case law or conrred by

7 statute and to te extent that it ininges upon Plaintifs right to privacy inally

8 Plainti objects to this Request as it seeks inrmation already in Dendants possession

9 custody or control.

20 Subject to and notwithstanding these objections and the regoing eneral

2 bjections consistent with them without waiving any of them and to the extent that this

22 Request should be interpreted as requesting only relevant and non-privileged inrmation

23 Plainti responds as llows Deny

24

25 R QU ST FOR ADMISSION NO. 7:26 Admit that YU have no cts and/or evidence to support the allegation that "each

27 of the ARCHSTNE DES Caliia apartment complexes including Dendant ASN

28 / / / /

7

PLAINTIFFS OBECTINS AND RSNSES T EENDANT WARNER ENTER, 'S

QESTS FR DMISSIN ET ONE)


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EXHIBIT 2Page 83


WARNER CENTER LLC y under the same Archstone banner and logo rerenced

2 in aragrah 12 of YOUR COMPLAINT

3

4 RESPONSE TO R QU ST FOR DMISSION NO. 175 In addition to the rgoing eneral Objections Plainti objects to this Request on

6 the grounds that it is comound overly broad as to both time and scoe burdensome

7 oressive not reasonably articularized harassing and seeks inrmation that is neither


9 Plainti also objects to this Request to the extent it seeks inrmation hich is rotected

0 om discovery by the attoeyclient rivilege ork roduct doctrine and/or any other

alicable rivilege rotection or immunity recognized in case la or conrred by

2 statute and to the extent that it ininges uon Plaintifs right to rivacy Finally

3 Plainti objects to this Request as it seeks inrmation already in Dendants ossession

4 custody or control

5 Subject to and notithstanding these objections and the regoing eneral

6 Objections consistent ith them ithout aiving any of them and to the extent that this

7 Request should be interreted as requesting only relevant and nonrivileged inrmation

8 Plainti resonds as llos Deny

9

20 R U ST FOR DMISSION NO. 182 Admit that YOU have no cts and/or evidence to suort the allegation that "the

22 ARCHSTONE DOES have been leasing the residential units at their Caliia aarment

23 comlexes including Dendant AS WANER CENTER LLC ursuant to

24 standardized leases and rms rerenced in aragrahs 14 and 20 of YOUR

25 COMPLAINT

26 /Ill

27 !Ill

28 !Ill

8

PAFF'S OBJECS AD ESSES EFEDA WAE EE, S

EQUESS F DMSS (E OE


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RESPONSE O QU S FOR ADMISSION NO 182 In addition to the rgoing General Ojection Plainti oject to thi Requet on

3 the ground that iti compound overlyroad a tooth timeand cope urdenome

4 oreive not reaonaly aricularized haraing and eek inrmation that i neither

5 relevant nor reaonaly calculated to lead to the dicovery of admiile evidence

6 Plainti alo oject to thi Requet to the extent it eek inrmation hich i rotected

7 om dicovery y the attoey-client rivilege ork roduct doctrine and/or any other

8 alicale rivilege rotection or immunity recognized in cae la or conrred y

9 tatute and to the extent that it ininge uon Plaintif right to rivacy inally

, 10 Plainti oject to thi Requet a it eek inrmation already in Dendant' oeion

1 1 cutody or control

12 Suject to and notithtanding thee ojection and the regoing eneral

13 Ojection conitent ith them ithout aiving any of them and to the extent that thi

14 Requet hould e interreted a requeting only relevant and non-rivileged inrmation

15 Plainti reond a llo: Deny

16

17 R QU S FOR ADMISSION NO. 1918 Admit that YOU have no ct and/or evidence to uort the allegation that "the

19 ARCHSTONE DOES have een leaing the reidential unit . uruant to tandardized

20 leae and rm [that] rohiit and at all material time have rohiited charging

2 1 r aartment cleaning and aining and caret cleaning/relacement if at the end of the

22 tenancy the tenant retu the aartment unit clean and in the ame condition a it a at

23 the incetion of the tenancy uject to reaonale ear and tear rerenced in aragrah

24 4 of YOUR COMPLAINT

25

26 SPONSE O R QU S FOR ADMISSION NO. 1927 In addition to the rgoing eneral Ojection Plainti oject to thi Requet on

28 the ground that it i comound overly road a to oth time and coe urdenome

19

PLNFFS OBJECNS ND ESNSES EFENDN WNE ENE SEQUESS F DSSN (E ONE)


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EXHIBIT 2Page 85


oressive, not reasonably articularized, harassing, and seeks inrmation that is neither



4 om discove by the attoey-client rivilege, work roduct doctrine, and/or any other



7 Plainti objects to this Request as it seeks inrmation already in Dendant's ossession,

8 custody, or control


0 Objections, consistent with them, without waiving any of them, and to the extent that this

Request should be interreted as requesting only relevant and nonrivileged inrmation,

2 Plainti resonds as llows Deny

3

4 R QU ST FOR ADMISSION NO :5 Admit that OU have no cts and/or evidence to suort the allegation that the

6 ARCHSTONE DOES and their Caliia aartment comlexes, including ASN

7 WAER CENTER, LLC, hold themselves out as a unitary entity called Archstone

8 rerenced in aragrah 15 of YOUR COMPLAINT

9

20 RESPONE TO R QU ST FOR ADMISSION NO :2 In addition to the rgoing General Objections, Plainti objects to this Request on

22 the grounds that it is comound, overly broad as to both time and scoe, burdensome,

23 oressive, not reasonably articularized, harassing, and seeks inrmation that is neither



26 om discovery by the attoeyclient rivilege, work roduct doctrine, and/or any other



20

PLAINTS JECTNS AND ESNSES T EENDANT WANE ENTE SEQUESTS DMISSIN (ET NE)


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Plainti object to thi Reqet a it eek inrmation already in Dendant poeion,

2 ctody, or control

3 Sbject to and notwithtanding thee objection and the regoing eneral

4 Objection, conitent with them, withot waiving any of them, and to the extent that thi

5 Reqet hold be interpreted a reqeting only relevant and non-privileged inrmation,

6 Plainti repond a llow: Deny

7

8 R QU ST FOR DMISSION NO :9 Admit that YOU have no ct and/or evidence to pport the allegation that "the

0 employee at the ARCHSTONE DOES Caliia apartment complexe, inclding the

employee at ASN WANER CENTER, LLC, are nirmly trained and employed by

2 the ARCHSTONE DOES rerenced in paragraph 17 of YOUR COMPLANT

3

4 RESPONSE TO R QU ST FOR DMISION NO :5 In addition to the rgoing eneral Objection, Plainti object to thi Reqet on

6 the grond that it i compond, overly broad a to both time and cope, brdenome,

7 oppreive, not reaonably particlarized, haraing, and eek inrmation that i neither

8 relevant nor reaonably calclated to lead to the dicovery of admiible evidence

19 Plainti alo object to thi Reqet to the extent it eek inrmation which i protected

20 om dicovery by the attoey-client privilege, work prodct doctrine, and/or any other

2 applicable privilege, protection, or immnity recognized in cae law or conrred by

22 tatte, and to the extent that it ininge pon Plaintif right to privacy inally,

23 Plaintif objects to this Request as it seeks inrmation already inDendant's possession,

24 custody, or control.

25 Sbject to and notwithtanding thee objection and the regoing eneral

26 Objection, conitent with them, withot waiving any of them, and to the extent that thi

27 Reqet hold be interpreted a reqeting only relevant and nonprivileged inrmation,

28 Plainti repond a llow: Deny

2

PLAINIS OBECINS AND ESNSES EENDAN WANE ENE 'S

EQESS DMISSIN E ONE)


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EXHIBIT 2Page 87


R ST FOR ADMISSION NO. 22:2 Admit that YOU have no cts and/or evidence to suort the allegation that "the

ARCHTONE DOE monitor and regulate their emloees at their Caliia aartment

4 comlexes, including their emloees at AN WANER CENTER, LLC, to ensure that

5 the coml with their unirm olicies and rocedures rerenced in aragrah 18 of

6 YOUR COMPLAINT

7

8 RESPONSE TO R Q ST FOR ADMISSION NO. 22:9 In addition to the rgoing eneral Ojections, Plainti ojects to this Request on

0 the grounds that it is comound, overl road as to oth time and scoe, urdensome,

I oressive, not reasonal aricularized, harassing, and seeks inrmation that is neither

I2 relevant nor reasonal calculated to lead to the discover of admissile evidence.

I Plainti also ojects to this Request to the extent it seks inrmation which is rotected

4 om discover the attoeclient rivilege, work roduct doctrine, and/or an other

5 alicale rivilege, rotection, or immunit recognized in case law or conrred

6 statute, and to the extent that it ininges uon Plaintifs right to rivac inall,

7 Plainti ojects to this Request as it seeks inrmation alread in Dendant's ossession,

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