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In most instances, the landlord either fails to respond to your discovery at all or poses multiple objections with evasive responses, solely to frustrate your efforts to get the information to which you are entitled. We expect this.

You start with a "meet and confer" letter, asking for the information. This is a legal requirement if they have given any response at all.

Then you have a motion to compel their response, and in the case of a request for admissions, a motion to "deem admitted" those requests which they failed to answer.

They will file some Opposition to your motion and you will then file a Reply to their Opposition.

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