MEET-AND-CONFER LETTER

Regarding Deficient Discovery Responses

[LAW FIRM NAME] [Street Address], [City], California [ZIP] Telephone: (213) 555-0100 | Facsimile: (213) 555-0101

April 2, 2026

VIA EMAIL AND U.S. MAIL

[DEFENSE COUNSEL NAME — STATE BAR NO. ######] [Defense Firm Name] [Street Address], [City], California [ZIP]

Re: Cruz v. Bright Horizon Property Management LLC Court: Los Angeles County Superior Court Case No.: 24STUD09342 (FICTIONAL) Subject: Meet-and-Confer Regarding Deficient Responses to Plaintiffs’ RFP Set One (Nos. 4–9) and SROG Set One (Nos. 12–17)

Dear Counsel:

I write on behalf of Plaintiffs Juan Cruz and Lucia Cruz pursuant to California Code of Civil Procedure § 2016.040 and Local Rule 3.26 to meet and confer regarding Defendant Bright Horizon Property Management LLC’s (“Bright Horizon”) responses to Plaintiffs’ Request for Production of Documents, Set One (“RFP Set One”) and Special Interrogatories, Set One (“SROG Set One”), served [February 19, 2026] and responded to [March 20, 2026]. Defendant’s responses to the requests identified below are deficient and must be supplemented. This letter constitutes our good-faith effort to resolve these disputes without court intervention.

I. DEFICIENT RESPONSES TO RFP SET ONE — NOS. 4 THROUGH 9

RFP No. 4 — HVAC Service and Maintenance Records

Defendant’s response asserts a general objection that the request is “overbroad and unduly burdensome” without any substantive explanation. Defendant produced no documents. HVAC maintenance records for the unit and the building system are directly relevant to Plaintiffs’ claims of breach of the implied warranty of habitability and negligence. Defendant’s boilerplate objection, standing alone, is legally insufficient. See Sinaiko Healthcare Consulting, Inc. v. Pacific Healthcare Consultants (2007) 148 Cal.App.4th 390, 409. Defendant must produce all responsive documents or provide a verified statement that, after a diligent search, no such documents exist.

RFP No. 5 — Mold Inspection and Remediation Records

Defendant responded with an objection that the request seeks “proprietary business information” and produced no documents. Mold inspection and remediation records are not proprietary business information; they are operational records directly relevant to whether Defendant undertook reasonable steps to repair the conditions about which Plaintiffs complained. This objection is not well-founded. CCP § 2031.310(b)(1) requires that any claim of privilege be stated with specificity, identifying the specific documents claimed and the applicable privilege or protection. Defendant has failed to do so. Defendant must produce all responsive records or provide a compliant privilege log within the time specified below.

RFP No. 6 — Written Communications with Plaintiffs

Defendant responded that it is “investigating” and “reserves the right to supplement.” This is not a proper response. A responding party must respond completely to each request as of the date of the response. CCP § 2031.210. Defendant must produce all written communications with Juan and Lucia Cruz — including emails, texts, letters, and maintenance work-order records — or confirm that none exist.

RFP No. 7 — Los Angeles Housing Department Notices and Correspondence

Defendant produced a single two-page document — the September 2025 LAHD notice of violation — without any accompanying internal communications responding to or acknowledging that notice. Responsive documents plainly include Defendant’s internal communications concerning the notice, any response submitted to LAHD, and any remediation plan or timeline prepared in response. Defendant’s production is incomplete.

RFP No. 8 — Tenant Complaints at Subject Property (2023–Present)

Defendant objected on privacy grounds and produced no documents. While Plaintiffs acknowledge that third-party tenant privacy interests exist, Defendant has not proposed any reasonable accommodation (e.g., redaction of tenant names) that would permit production of relevant habitability complaint records. Defendant must produce responsive records in redacted form identifying the date, nature, and resolution of each complaint, or propose an alternative accommodation within the time stated below.

RFP No. 9 — Insurance Policies and Claims Documentation

Defendant objected on the grounds of relevance and attorney-client privilege. Insurance policies are discoverable in habitability cases because they may reflect the scope of Defendant’s knowledge of property conditions and available remediation resources. The attorney-client privilege does not protect insurance policy documents themselves. Defendant must produce its applicable general liability and property insurance policy or policies and identify any claims made on those policies in connection with the subject property.

II. DEFICIENT RESPONSES TO SROG SET ONE — NOS. 12 THROUGH 17

SROG No. 12 — Identity of All Persons with Knowledge of HVAC Condition

Defendant identified only its property manager, [Name Withheld], without providing the required contact information for that person or identifying any contractors, maintenance technicians, or other agents who inspected or attempted to repair the HVAC unit. CCP § 2030.230 requires a complete response identifying all persons with knowledge. Defendant must supplement.

SROG No. 13 — Dates of All Inspections of the Subject Unit (2023–Present)

Defendant’s response states “Defendant will respond when information becomes available.” This is not a valid response. CCP § 2030.220 requires that each interrogatory be answered as completely as information permits. Defendant must provide a supplemental verified response with all inspection dates within Defendant’s knowledge.

SROG No. 14 — Identity of Mold Remediation Contractor

Defendant responded “none known.” If Defendant performed no mold remediation following the LAHD notice of violation, that fact must be stated explicitly in a verified response. If a contractor was engaged, Defendant must identify the contractor and dates of engagement. The current response is ambiguous and insufficient.

SROG No. 15 — Steps Taken to Repair Water Intrusion Following First Written Notice

Defendant’s response recites only that “Defendant took appropriate steps to maintain the property in compliance with applicable law.” This is a non-responsive narrative answer that does not answer the interrogatory. Defendant must identify with specificity each remedial step taken, the date of each step, and the person who performed it.

SROG Nos. 16 and 17 — Knowledge of Children’s Respiratory Symptoms and Medical Expenses

Defendant objected on grounds of “speculation” and “lack of personal knowledge.” Knowledge of tenant children’s documented health conditions reported in writing is a proper subject of interrogatories directed to the corporate defendant. Defendant must provide a verified response stating whether it was ever informed of the children’s symptoms, and if so, the date and manner in which it received that information.

III. DEMAND AND DEADLINE

Plaintiffs are prepared to file a motion to compel further responses under CCP § 2030.300 (interrogatories) and § 2031.310 (document production) if these deficiencies are not cured. However, consistent with our obligation to meet and confer in good faith, we request that Defendant serve verified supplemental responses and produce all withheld documents no later than April 17, 2026 (fifteen calendar days from the date of this letter).

If we do not receive complete supplemental responses by that date, we will proceed with filing a motion to compel and will seek sanctions pursuant to CCP §§ 2030.300(d) and 2031.310(h). We remain available to meet and confer by telephone at a mutually convenient time before that date.

Sincerely,

[ATTORNEY NAME — STATE BAR NO. ######] Counsel for Plaintiffs Juan Cruz and Lucia Cruz [LAW FIRM NAME]

cc: File

This document is a fictional representation created for portfolio purposes only. All names, case numbers, and factual details are invented.