Lishner, Laurence H - Laurence Lishner Law Offices in Los Angeles, CA

Michael Howard added information

Re: Eviction Proceedings Howard v Kandace & Audrey; Site Address Hithe 5039 W. 64th Street Los Angeles 90056 LASC # 14U14598

I have reviewed the filing papers you provided me along with limited portions of defendant’s response. Tenant is a former paralegal and will argue any defect in the complaint invalidates it. I have been to the court before. I know that to be the case as I have lost cases because of defects in the filling.

Tenant’s in their response, which I am not fully apprised of, have indicted defects in the complaint. Upon reviewing the paper you provided me I noted the following which is of concern to me.
1. Page 2 of Complaint at line 6 states tenants entered into rental agreement on 8/01/05.
a. My concern is tenants agreement was entered into on or about 5/15/2012
2. Page 2 of Complaint at line 18 states $7010 became due for rent from 8/01/14 till 12/01/14
a. My concern is tenants tendered a check (although less than rental amount for $1100 on 9/20/2014.
3. Your Proof of Service Judicial form POS-010 dated Nov 17, 2014 at line 2 states you served document including General Order dated July 23, 2013
a. My concern is that the General Order of the Court in current use is filed May 14, 2014

Further I do not have the complete response of the defendants’ by which they have noted their response and defects in the complaint. Please provide the following:
1. Supporting documents referred to in Defendant’s Answer –Unlawful Detainer Judicial Council Form UD-105 specifically the MC-025 forms they filled out as noted in items 4 and 5 of the UD-105 they filled on 11/21/2014
2. Additionally I will need a True & Correct conformed copy of any other forms you filled regarding the unlawful detainer including:
a. Judicial Council form UD-100 or such document that is representative of the requirements of said form

Thank you for your attention to these matters,

Michael Howard owner and landlord.