DEFENDANT/TENANT S INTERROGATORIES (Residential Nonpayment of Rent Case)

Transcription

1 SUPERIOR COURT OF THE DISTRICT OF COLUMBIA CIVIL DIVISION, LANDLORD AND TENANT BRANCH BLDG. B, 510 4th STREET, N.W., RM. 110 Washington, D.C Telephone (202) Plaintiff/Landlord v. L&T. Defendant/Tenant DEFENDANT/TENANT S INTERROGATORIES (Residential Nonpayment of Rent Case) Instructions to Defendant/Tenant: 1. Use these questions or interrogatories to get information from Plaintiff/Landlord that you need to prepare for trial. 2. These interrogatories are to be served in a nonpayment of rent case only. For cases involving other lease violations, use Defendant/Tenant s Interrogatories (Residential Notice to Quit case). 3. Check only those interrogatories you want Plaintiff/Landlord to answer and that are relevant to this case. You cannot check more than 10 without permission of the Court. 4. You must serve a copy of these interrogatories by hand or by mail on Plaintiff/Landlord s attorney, if there is one. If not, you must serve them on Plaintiff/Landlord. Plaintiff/Landlord has 30 days to answer these interrogatories in writing. 5. Do not file these interrogatories with the Court. 6. Keep a copy of the completed form for your records. Instructions to the Plaintiff/Landlord: 1. For any box that is checked by Defendant/Tenant, you must answer fully and under oath each of the questions or interrogatories. You do not need to answer questions that are not checked. If you object to an interrogatory that Defendant/Tenant has checked, you must state the reason why you object. 2. Where a document would provide the answer, you may attach a copy of the document.

2 3. When a question asks you to identify a person, state the person s full name, home address and business address. 4. You have 30 days after the date these interrogatories were served on you to answer. Your answers must be in writing. It is best to use this form when responding. If you choose not to, you must type out the questions with the answers. If this form does not provide enough space for you to fully answer any interrogatory, you may attach additional sheets of paper. If you attach additional sheets of paper, be certain to identify which interrogatory you are answering. 5. You must serve your written answers, signed as being true and correct under penalty of perjury, on Defendant/Tenant by mail or in person. Do not file this form or your answers with the Court. 6. Keep a copy of the completed form for your records. Please answer the following interrogatories: 1. List all amounts you claim Defendant/Tenant owes you, stating whether each amount is rent, late fees or other charges (specify what type); the amount; and what month it is for (use a separate sheet if necessary) or attach a copy of your rent ledger or rent records. 2. List all payments you have received from Defendant/Tenant for the past months, or attach a copy of your receipts or records of payments. 2

3 3. If you checked the box on the Complaint stating that you served a Notice to Quit as required by law, state when, how and on whom you served the notice. 4. If you checked the box on the Complaint stating that the Notice to Quit was waived in writing, describe the writing in which Defendant/Tenant waived the notice, or attach a copy of the writing. 5. List all increases in the rent and the rent ceiling for the past (three, unless otherwise stated) years for Defendant/Tenant s unit, stating the amount of the increase(s) and the date(s) it was taken. 3

4 6. If you claim you are exempt from rent control, state your exemption number or attach a copy of your claim of exemption. 7. If you do not claim you are exempt from rent control, have you registered with the Rental Accommodations and Conversion Division? If so, state your registration number or attach a copy of your registration. If not, why have you not registered? 8. Why have you not repaired the housing code violations described in Defendant/Tenant s Answer In A Residential Non-Payment of Rent Case? 9. If you claim that you have cured, fixed or abated any of the housing code violations described in Defendant/Tenant s Answer, or have attempted to do so, 4

5 list each one your fixed or tried to fix, and when, or attach all records showing the repairs or the attempt to repair. 10. If you claim that any of the housing code violations described in Defendant/Tenant s Answer were created or caused by Defendant/Tenant or the occupants of the premises, list which violations were caused by Defendant/Tenant or occupant and when, or attach records showing the damage done by Defendant/Tenant or occupant. 11. If you contend that you could not repair any of the housing code violations described in Defendant/Tenant s Answer because you could not gain access, describe the dates you tried to gain access, how you tried to gain access and what happened, or attach all records showing when and how you tried to gain access. 5

6 12. Identify each person whom you expect to call as an expert witness at trial in this matter, and for each, state the subject matter on which the expert is expected to testify, state the substance of the facts and opinions to which the expert is expected to testify, and set forth the grounds for each opinion. 13. Identify (name, address and phone number) all people who are not experts, but who have knowledge of the rent you claim is owed or the conditions of the apartment. 14. Other: 6

7 Defendant/Tenant Address Phone Number Date CERTIFICATE OF SERVICE REQUIRED: You must serve each party from whom you want a response to these discovery requests. If a party has a lawyer, you must serve the lawyer instead of the party. I hereby certify that a copy of these Interrogatories was (check one) hand-delivered mailed to Plaintiff/Landlord or Plaintiff/Landlord s Lawyer on the following date:, 20 at the following address:. _ Signature of person who hand-delivered or mailed a copy of Defendant/Tenant s Interrogatories 7

8 VERIFICATION OF DEFENDANT/TENANT S ANSWERS TO PLAINTIFF/LANDLORD S INTERROGATORIES I have read my answers and/or objections to Plaintiff/Landlord s Interrogatories and declare under penalty of perjury that all the foregoing information is true and correct to the best of my knowledge and belief. Defendant/Tenant Address Phone Number Executed this day of,20. 8