'Honest Civilized MD Tenant' vs 'Deny-All' Greedy Landlord : david v Goliath ! Bible(psalm18) :David wins because He is Righteous !.
Just to be clear, I am detailing my side of story:
99.9% of our communications were done via TEXTINGS WITH PHOTO EVIDENCES.
THEREFORE,
THEY CAN'T LIE AS THEY HAVE BEEN !
("Deny-All" Landlord vs Smart Asshole Tenant)
c). on the same day, apt manager threatened me citing " we had a group meeting against you, everybody hates you!"... I had no clue since I always say "Hi Neighbor" since I don't know their names and they were focusing on their own life,not interested in meeting a new tenant. All Latinos tenants are like that in this buildings
So, my case manager came over and video taped all of our texting exchange,and found apt manager is a PATHOLOGICAL LIAR !!!
THEREFORE, I EXPECT MY APT MANAGER'S SUPERVISOR ( now knows as Steve Amona or Pirooza Amona)(WHO SENT A KOREAN REALTOR WHO RIDICULED ME KNOWING WE HAVE A MEDIATION MEETING TOMORROW WILL LIE AND DENY EVERYTHING!
Housing discrimination under California law:
It is illegal for a landlord to discriminate or harass you because of race, color, religion, sex, sexual orientation, marital status, national origin, ancestry, familial status, source of income, or any disability (Civil Code Section 51),or whether you have persons under the age of 18 living in your household. (42 United States Code Sections 3601-3631; California Landlord Tenant Practice Sections 2.22-2.25 (CEB 2011)). With the exception of source of income, the landlord may not ask you questions in writing or orally about your race, color, religion, sex, sexual orientation, marital status, national origin, ancestry, familial status, any disability, or whether you have persons under the age of eighteen living in your household (Government Code Section 12955(b)). Further, the landlord may not ask about your immigration or citizenship status. Civil Code Section 1940.3(b)).
Additionally, A landlord can establish reasonable standards for the number of people per square feet in a rental unit, but the landlord cannot use overcrowding as a pretext for refusing to rent to tenants with children if the landlord would rent to the same number of adults.
If you’ve been the subject of housing discrimination, you may have several legal remedies. There are also a number of resources available to help ,such as The National Fair Housing Allowance, The California Department of Fair Housing and Employment and The US Department of Housing and Urban Development).
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|  Thu, Oct 21, 2021, 12:54 PM | | ||
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A sample letter to advise a landlord of a violation of LA city anti harassment protections is attached to this e-mail which also cites 789.3 of the civil code. For additional assistance on renters protections you can contact the “Housing community investment department” at https://housing.lacity.org/
WHAT IS A MOTION TO COMPEL?
A motion to compel asks the court to enforce a request for information relevant to a case. Here is a general sequence of events leading up to the filing of a motion to compel:
- The lawsuit officially begins when the Plaintiff initiates a civil action against the Defendant.
- Discovery requests: parties submit requests for evidence, documents, and other relevant information from the opposition. Each party is required to respond to requests by a specified deadline.
- One of the parties does not cooperate, refusing to answer requests for discovery appropriately, or fails to respond by the deadline.
- “Meet and confer”: an informal attempt is made to resolve disputes about the discovery request.
- The requesting party files a motion to compel discovery responses if the opposing party continues to deny the discovery request.
HOW ARE MOTIONS FILED?
To file a motion for order compelling discovery, you’ll usually need to prepare the following (depending on the local court’s rules):
- Motion: A request to the court to issue an order to compel discovery.
- Points and Authorities: Supporting documentation for the motion detailing the submitted request for discovery, the opposing side’s failure to comply, and an explanation of why the discovery is relevant to the case.
- Notice of hearing: A written notice provided to the opposing side informing that the motion to compel has been filed with the court, including the date and time of Motion day.
After preparing the documentation, the originals are then submitted to the court. The opposing side will receive copies of the documents as well.
ABOUT COMPELLING DISCOVERY
Discovery is a key step in the legal process, allowing each party to request specific information from the other party. Each side reviews propounded discovery, using it to build their case.
If one side neglects to respond to requests for discovery by the deadline, the requesting party may choose to file a motion to compel discovery. Other situations may warrant a motion to compel, including incomplete responses, skipped questions, or an outright refusal to answer.
Before a party resorts to filing a motion to compel, the court often expects the requesting side provides a “good faith effort” to obtain a response from the opposition. This effort, commonly referred to as a “meet and confer,” can be an in-person meeting, but may sometimes also take form in a written notice. If the opposition requests a reasonable extension of time, the requesting party would be expected to permit this, “in good faith.”
DIFFERENT CATEGORIES OF “DISCOVERY”
Each party will propound discovery relevant to the case from the opposing side. There are different categories of discovery, which include:
- Requests for Production of Documents: These include specific documents or tangible items (as in video or audio recordings, bank statements, tax documents, letters, emails, etc.).
- Deposition: An in-person interview under oath occurring outside of court.
- Interrogatories: Written questions sent to the other party. All responses are written and are under oath.
- Request for Admissions: A written request for specific facts to be provided. Again, all responses are written and provided under oath.
- Subpoena: A court summons requiring a witness to appear for deposition or court or for a person or entity to produce documents.
POSSIBLE OUTCOMES FOLLOWING A MOTION TO COMPEL DISCOVERY
On Motion day, both sides present their case before the court:
- The requesting party tells the judge why the requested Discovery is pertinent to the case. They demonstrate that the “good faith” attempt was made to resolve the issue before filing the motion to produce.
- The opposing side presents the rationale for any objections to the discovery request.
The judge will either deny the motion to compel, order the opposition to provide the discovery by a deadline, or will grant in part and deny in part the motion, and will only require some of the discovery to be provided. Other sanctions may also be applied, including payment of attorney’s fees or monetary fines.
If the opposition continues to disregard the court order to compel, the requesting party may submit a second “motion to dismiss for failure to comply with the court’s order to provide discovery.”
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Lawsuit offers Needful Education for Idiot Apt Manager/Landlord !
Education is Expensive, However,
Think Under-Education will lead to Unnecessary Crimes to Other Innocent Good People !!
It is a Fact that Under-Educated People tend to get Upset for Petty Un-pleasant Words and Demand Highest Level of Respect !
That is Maria Llamas !
she got upset after endless denials/mis-handling property management/send Threat Team,,, my words of IDIOT prompted her to call 911 and contact my Case Manager( who is my Housing Advocate),Terrorizing my Door without any justification etc, However, She lied to Detective/StepUp Case Manager/LAC DCBA Mediator that SHE & Other Tenants feel UNSAFE WITH ME !
SHE COMES OVER TO CLEAN OUR HALLWAY ALL THE TIME , I didn't see her afraid of running into me.. AND SHE INVITED ME TO HER HOME. WHEN I INDEED VISITED HER HOME 4 LA CITY ATTY'S MEDIATION (SINCE SHE DIDN'T KNOW HOW TO USE LAPTOP AND ZOOM MEETING),SHE TRUSTED ME 100%. She is a Pathological Liar in desperate Defense of our Greedy Ignorant Criminal Landlord's Interests !!
On Recent Her Invitation to her home BBQ Party, (since I did not respond to that Invitation),she texted me "I am calling Police", "they are coming now"(that was a lie)..
Her Apt looks like a Plastic Dead-Dog-Walking Living Space! very uncomfortable minimal decoration/furniture arrangement etc.
In my opinion, Maria Llamas can only collect Rents ,and also she confessed to me that our Landlord allowed her to do only that Duty...!! Otherwise, It is her Supervisor's Duty (now known as 'Steve' Pirooz Amona) who never took care of my legitimate numerous complaints (except only one: my Upstairs one of unit had a HUGE DOG ,when barking,this whole building was shaking ,all day long !
All she cares is Rent ! Money works with this IDIOT !!
when I continued complaining about Upstair's Stomping on my Ceiling disturbing my Insomnia, She responded "They paid Rent,Leave them alone"
( I never ever contact my upstairs nor confronted with Nuisance Issues at all,none of time)
On Another Occasion, I reported "Illegal Personal Property in Public Area" via Texting about Big Storage of BBQ Table etc Setup in front of Apt Unit near our Trash Dumpster.
Maria Llamas' Texting: "they have been paying Rent without any problem over last 20y, Look what You did to them"
Maria Llamas can't be a Live-in Apt Manager , not trained enough as a property manager ,not honest enough,not be able to solve & deflate Any Disputes/Nuisances etc...
I AM 100% SURE ABOUT THIS .EXPERIENCED THROUGH NUMEROUS TIMES OVER LAST 8-9 MONTHS' RESIDENCY IN MY APT!!
MARIA LLAMAS IS AN IDIOT !! MUST BE RESTRAINED WITH ELDER ABUSE RESTRAINT ORDER ! BET TZDEK ORG IS HELPING ME TO FILE THAT MOST PUNISHABLE RESTRAINT ORDER WHETHER SHE IS A PROPERTY MANAGER OR NOT.
I HAVE WON TRO AGAINST MY FORMER APT MANAGER BEFORE IN LA CITY !
--VERY AGGRESSIVE TYPICAL 'LATINA' TEMPER !
DR #2120-15348
| Tue, Nov 30, 2021, 9:59 AM | | ||
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Los Angeles City Dispute Resolution Program - Mediation Confirmation
| Fri, Nov 12, 2021, 2:58 PM | | ||
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Your mediation is confirmed for Tuesday, November 23, 2021 at 10:00 a.m. via Zoom. Attached are documents for your review prior to the mediation. In a separate email you will receive all three documents (via Adobe Sign); please sign all three documents before the mediation. After all signatures have been acknowledged a copy of the document will automatically be sent to you.
For online mediation, please ensure that you are in a private area. A place where there are no distractions or interruptions by other individuals who are not privy to the meeting. Mediation is a confidential and good-faith process- should any party exhibit (without notice) that the meeting is not private, the mediation will be terminated.
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The Dispute Resolution Program of the Los Angeles City Attorney’s Office CONFIDENTIALITY AGREEMENT All parties, and the Dispute Resolution Program of the Office of the Los Angeles City Attorney, agree that the provisions of California Evidence Code §§ 1115-1123 and 703.5, as printed on the back of this form apply to this mediation. THIS CONFIDENTIALITY AGREEMENT ("AGREEMENT") EXTENDS TO ALL PRESENT AND FUTURE CIVIL, JUDICIAL, QUASI-JUDICIAL, ARBITRAL, ADMINISTRATIVE OR OTHER PROCEEDINGS. The participants' sole purpose in participating in mediation is to resolve their dispute, in whole or in part. ANY WRITTEN AGREEMENT PREPARED DURING OR AT THE CONCLUSION OF THE MEDIATION IS NOT SUBJECT TO DISCLOSURE, BINDING, ENFORCEABLE, AND ADMISSIBLE to prove the existence of and/or to enforce the agreement under California Code of Civil Procedure §664.6, unless both parties agree. The mediator is serving as a neutral intermediary and facilitator and may not act as an advocate for any party. THE MEDIATOR'S STATEMENTS DO NOT CONSTITUTE LEGAL ADVICE TO ANY PARTY. ACCORDINGLY, THE PARTIES ARE STRONGLY ENCOURAGED TO SEEK LEGAL ADVICE FROM THEIR OWN COUNSEL if they feel it is necessary. Criminal prosecutions are not covered by this Agreement. So, if you state you have committed a crime or that you plan to commit a crime, we will report you to the proper authorities. steve noh steve noh (Nov 12, 2021 18:40 PST) ______________________________________________ Print Name and Sign Maria llamas (Nov 13, 2021 16:10 PST) ______________________________________________ Print Name and Sign ______________________________________________ Print Name and Sign ______________________________________________ Print Name and Sign Nov 12, 2021 ________________ Date Nov 13, 2021 ________________ Date ________________ Date ________________ Date CALIFORNIA EVIDENCE CODE §703.5. Judges, arbitrators or mediators as witnesses; subsequent civil proceeding. No person presiding at any judicial or quasi-judicial proceeding, and no arbitrator or mediator, shall be competent to testify, in any subsequent civil proceedings, as to any statement, conduct, decision, or ruling, occurring at or in conjunction with the prior proceeding, except as to a statement or conduct that could (a) give rise to criminal contempt, (b) constitute a crime, (c) be the subject of investigation by the State Bar or Commission on Judicial Performance §1115. For purposes of this chapter: (a) "Mediation" means a process in which a neutral person or persons facilitate communication between the disputants to assist them in reaching a mutually acceptable agreement. (b) "Mediator" means a neutral person who conducts a mediation. "Mediator" includes any person designated by a mediator either to assist in the mediation or to communicate with the participants in preparation for a mediation. (c) "Mediation consultation" means a communication between a person and a mediator for the purpose of initiating, considering, or reconvening a mediation or retaining the mediator. §1118. An oral agreement "in accordance with Section 1118" means an oral agreement that satisfies all of the following conditions: (a) The oral agreement is recorded by a court reporter, tape recorder, or other reliable means of sound recording. (b) The terms of the oral agreement are recited on the record in the presence of the parties and the mediator, and the parties express on the record that they agree to the terms recited. (c) The parties to the oral agreement expressly state on the record that the agreement is enforceable or binding or words to that effect. (d) The recording is reduced to writing and the writing is signed by the parties within 72 hours after it is recorded. §1119. Except as otherwise provided in this chapter: (a) No evidence of anything said or any admission made for the purpose of, in the course of, or pursuant to, a mediation or a mediation consultation is admissible or subject to discovery, and disclosure of the evidence shall not be compelled, in any arbitration, administrative adjudication, civil action, or other noncriminal proceeding in which, pursuant to law, testimony can be compelled to be given. (b) No writing, as defined in Section 250, that is prepared for the purpose of, in the course of, or pursuant to, a mediation or a mediation consultation, is admissible or subject to discovery, and disclosure of the writing shall not be compelled, in any arbitration, administrative adjudication, civil action, or other noncriminal proceeding in which, pursuant to law, testimony can be compelled to be given. (c) All communications, negotiations, or settlement discussions by and between participants in the course of a mediation or a mediation consultation shall remain confidential. §1120. (a) Evidence otherwise admissible or subject to discovery outside of a mediation or a mediation consultation shall not be or become inadmissible or protected from disclosure solely by reason of its introduction or use in a mediation or a mediation consultation. (b) This chapter does not limit any of the following: (1) The admissibility of an agreement to mediate a dispute. (2) The effect of an agreement not to take a default or an agreement to extend the time within which to act or refrain from acting in a pending civil action. (3) Disclosure of the mere fact that a mediator has served, is serving, will serve, or was contacted about serving as a mediator in a dispute. §1121. Neither a mediator nor anyone else may submit to a court or other adjudicative body, and a court or other adjudicative body may not consider, any report, assessment, evaluation, recommendation, or finding of any kind by the mediator concerning a mediation conducted by the mediator, other than a report that is mandated by court rule or other law and that states only whether an agreement was reached, unless all parties to the mediation expressly agree otherwise in writing, or orally in accordance with Section 1118. §1122. (a) A communication or writing, as defined in Section 250, that is made or prepared for the purpose of, or in the course of, or pursuant to, a mediation or a mediation consultation, is not made inadmissible, or protected from disclosure, by provisions of this chapter if either of the following conditions is satisfied: (1) All persons who conduct or otherwise participate in the mediation expressly agree in writing, or orally in accordance with Section 1118, to disclosure of the communication, document, or writing. §1123. A written settlement agreement prepared in the course of, or pursuant to, mediation, is not made inadmissible, or protected from disclosure, by provisions of this chapter if the agreement is signed by the settling parties and any of the following conditions are satisfied: (a) The agreement provides that it is admissible or subject to disclosure, or words to that effect. (b) The agreement provides that it is enforceable or binding or words to that effect. The Dispute Resolution Program of the Los Angeles City Attorney’s Office AGREEMENT TO MEDIATE 1. All parties agree that everything said and everything written during this proceeding will remain confidential and that no party will subpoena any staff or volunteer, or anything written by them, for any purpose in any legal proceeding, whether it is civil or criminal. 2. All parties understand that a mutual Agreement reached shall not be enforceable in court and/or admissible as evidence in any judicial or administrative proceeding unless there is a provision that clearly states the parties agree to such enforcement. The mutual Agreement must be signed to be enforceable/admissible. All parties understand that this does not mean that the judge or the hearing officer has to admit the Agreement into evidence or has to enforce it. All parties understand that this only means that they hope that the judge or the hearing officer will do these things. This agreement is entered into voluntarily by: steve noh steve noh (Nov 12, 2021 18:40 PST) Name___________________________ Maria llamas (Nov 13, 2021 16:10 PST) Name___________________________ Name___________________________ Name___________________________ Nov 12, 2021 Date____________ Nov 13, 2021 Date_____________ Date____________ Date ____________
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