I. SUMMARY

*1 On September 20, 2022, plaintiffs filed a Motion to Compel Answers, Responses, and Production in Response to Plaintiffs' Interrogatories and Requests for Production (“Motion to Compel”).[1] The Motion to Compel relates to: (1) plaintiff Marbarita Ortega's Interrogatory Nos. 1, 3, 5, 7-8, and 10-11 directed to defendants Nathan Kadisha, Michael Kadisha, K3 Manager LLC (“K3 Manager”), and K3 Holdings, LLC (“K3 Holdings”);[2] (2) plaintiff Southern California Housing Rights Center's (“HRC['s]”) Interrogatory Nos. 5-9 directed to Nathan Kadisha and Michael Kadisha;[3] (3) HRC's Interrogatory Nos. 1-9 directed to K3 Manager and K3 Holdings;[4] (4) HRC's Interrogatory Nos. 11-12 directed to K3 Manager; and (5) HRC's Requests for the Production of Documents (“RFP[s]”) Nos. 1-3, 5-58, 59 (numbering erroneously omitted), and 60-64 (misnumbered 59-63)[5] directed to K3 Manager (collectively “Discovery Requests in Issue”).

*2 On October 18, 2022, the Court held a lengthy hearing on the Motion to Compel and heard argument from counsel. (See Separate Minutes of Hearing on Plaintiffs' Motion to Compel).

Based upon the Court's consideration of the parties' submissions in connection with the Motion to Compel, the arguments of counsel, and the pertinent facts and law, and for the reasons explained at the hearing on the Motion to Compel and detailed below, the Court grants in part and denies in part the Motion to Compel and orders that the supplemental responses/production of documents called for by this Order be provided within fourteen (14) days of the date of plaintiffs' provision to defendants of the list referenced below of 15 properties (including the five properties in which the individual plaintiffs reside/have resided), or on such later date to which the parties may agree in writing that is consistent with the discovery cut-off.

II. BACKGROUND

A. Pleadings/Joint Report/Deadlines/Motion to Dismiss

On February 1, 2022, HRC and 16 individual tenants, including Marbarita Ortega, filed the Complaint (alternatively, “Comp.”), alleging that ten defendants – K3 Holdings, K3 Manager, Western 19 LLC, Oxford 19 LLC, Kenmore 20 LLC, Mariposa 20 LLC, Ave 55 19 LLC, Nathan Kadisha, Michael Kadisha and Angel Escobar engaged in discriminatory housing practices, in violation of state and federal law, by targeting for gentrification apartment buildings specifically occupied by Latinx families in the Koreatown and Highland Park neighborhoods of Los Angeles. (Docket No. 1; Brancart Ex. 28). Defendants consist of two principals (Nathan Kadisha and Michael Kadisha), their alleged holding and management companies (K3 Holdings and and K3 Manager), five individual building LLCs (the remaining entity defendants), and one of their alleged employees/agents (Angel Escobar). (Comp. ¶¶ 21-30). The Complaint alleges that defendants acquired several buildings, unlawfully removed Latinx families from them, renovated the buildings, and ultimately marketed the apartments to a new demographic selected by defendants on the basis of race, color, ethnicity, national origin, familial status, age, disability, or source of income that completely excluded the former Latinx tenants. (Comp. ¶¶ 31-60). The Complaint identifies 30 older apartment buildings occupied by low-income Latinx families in Koreatown and Highland Park neighborhoods that defendants allegedly targeted for acquisition and gentrification since 2019. (Comp. ¶ 34).

Plaintiffs' first claim asserts a violation of the Fair Housing Act (“FHA”), alleging that defendants discriminated against them, among other things, on the basis of race, color, or national origin. (Comp. ¶¶ 72-75) (citing 42 U.S.C. §§ 3604(a)-(e), 3617; 24 C.F.R. §§ 100.60(b)(4)-(b)(5), 100.60(b)(7), 100.65(b)(1)-(b)(2), 100.65(b)(4), 100.65(b)(7), 100.70(a)-(c)(3), 100.75(c)(1)-(c)(3), 100.80(b)(4), 100.400(c)(1)-(c)(2), 100.400(c)(6). Plaintiffs assert both disparate impact and disparate treatment theories of liability. (Comp. ¶ 74) (citing 42 U.S.C. § 3604(c); 24 C.F.R. §§ 100.5, 100.7).

Plaintiffs also bring state law claims for violations of California's Fair Employment and Housing Act (“FEHA”) (second claim) and Unruh Civil Rights Act (third claim); unlawful business practices (fourth claim); tenant harassment (fifth claim); substandard conditions (sixth claim); nuisance (seventh claim); quiet enjoyment (eighth claim); negligence (ninth claim); rent stabilization (tenth claim), unlawful rent (eleventh claim); unlawful construction (twelfth claim); unlawful buyouts (thirteenth claim); and tenant harassment (fourteenth claim). (Comp. ¶¶ 76-115) (citing Cal. Bus. & Prof. Code §§ 17200, 17204-17208; Cal. Civ. Code §§ 51, 52(a), 52(e), 1714, 1940.2, 1940.2(b), 1941-1941.1, 1941.3-1941.5, 1942.4(b), 1942.5(h), 1947.11-1947.11(a), 3281, 3333, 3345, 3479-3481, 3491, 3493, 3501; Cal. Govt. Code §§ 12927(c)(1), 12955, 12955(a), 12955(c)-(d), 12955(f)-(h), 12955(k), 12955.6-12955.8; 12989.2; Cal. Health & Safety Code §§ 17920.10, 17920.3; Cal. Penal Code §§ 484, 518; 2 C.R.R. §§ 12005(1), 12010, 12040-12042, 12161(b)(1)-(b)(2), 12161(b)(5), 12161(b)(11)-(b)(12); LAMC Chap. IV, Art. 5.3; LAMC Chap. XV, Arts. 151-52; LAMC §§ 45.35, 151.10, 151,31(F), 152.07(E)). Plaintiffs seek injunctive and declaratory relief and compensatory, statutory and punitive damages. (Comp. §§ 116-21).

*3 On April 8, 2022 and April 25, 2022, defendants filed their Answers, responding to the allegations in the Complaint and asserting multiple affirmative defenses.[6] (Docket Nos. 32, 43; Brancart Exs. 29-30).

On May 23, 2022, the parties filed a Joint Rule 26(f) Report which, among other things, reflects the parties' agreement that all service may be effected by electronic transmission (e.g., email), and that neither side requested that discovery be conducted in phases. (Docket No. 50; Brancart Decl. ¶¶ 3, 41; Brancart Ex. 1). As to claims of privilege/work product protection, the Joint Rule 26(f) Report reflects the parties' following agreement: “Claims of privilege or work product protection will be logged in accordance with [Fed. R. Civ. P.] Rule 26(b)(5); however, attorney-client communications directly related to this action and internal communications between counsel need not be logged. Privileged or protected materials are subject to clawback in accordance with Fed. R. Evid. 502.” (Docket No. 50; Brancart Ex. 1).

On June 7, 2022, the District Judge issued an Order Re: Jury Trial, which, among other things, set December 19, 2022 as the deadline for initial expert disclosures, January 30, 2023 as the deadline for rebuttal expert disclosures, March 13, 2023 as the non-expert discovery cut-off, and April 3, 2023 as the expert discovery cut-off. (Docket No. 53; Brancart Ex. 21).

On August 12, 2022, Defendants filed a Motion to Dismiss for Lack of Federal Subject Matter Jurisdiction Pursuant to Fed. R. Civ. P. 12(b)(1) and 12(h)(3) (“Motion to Dismiss”), which Plaintiffs opposed. (Docket Nos. 64, 67-69). On September 30, 2022, the District Judge denied the Motion to Dismiss. (Docket No. 75).

B. Pertinent Facts Relating to Discovery Requests in Issue

*4 On June 6, 2022, HRC served via email to defendants' counsel,[7] separate sets of Interrogatory Nos. 1-10 (“the HRC Kadisha Interrogatories”) directed to Michael Kadisha and Nathan Kadisha. (Brancart Decl. ¶¶ 5-6; Brancart Exs. 3-4). (Defendants' responses to the HRC Kadisha Interrogatories were initially due by July 6, 2022. Fed. R. Civ. P. 33(b)(2)).

On June 6, 2022, HRC served via email to defendants' counsel (see supra note 7), separate sets of Interrogatory Nos. 1-10 (“the HRC K3 Interrogatories”) directed to K3 Manager and K3 Holdings. (Brancart Decl. ¶¶ 7-8; Brancart Exs. 5-6). (Defendants' responses to the HRC K3 Interrogatories were initially due by July 6, 2022. Fed. R. Civ. P. 33(b)(2)).

On June 7, 2022, HRC served via email to defendants' counsel (see supra note 7), HRC Interrogatory Nos. 11-12 (“HRC K3 Interrogatory Nos. 11-12”) directed to K3 Manager. (Brancart Decl. ¶ 9; Brancart Ex. 7). (Defendants' responses to the HRC K3 Interrogatory Nos. 11-12 were initially due by July 7, 2022. Fed. R. Civ. P. 33(b)(2)).

On June 11, 2022, HRC served via email to defendants' counsel (see supra note 7), Request for Production Nos. 1-65 (misnumbered 1-64) (“RFP No[s].” or “Document Request[s] [Nos.]”) directed to K3 Manager which included as Exhibit 1, a table listing 28 apartment buildings assertedly purchased by one or more defendants since January 1, 2018 (“RFP Exhibit [or Ex.] 1”).[8] (Brancart Decl. ¶ 14; Brancart Ex. 12). (Defendants' responses to the Document Requests were initially due by July 11, 2022. Fed. R. Civ. P. 34(b)(2)).

On or around July 1, 2022, the attorney at defense counsel's firm responsible for handling the day to day tasks on this case (such as discovery) left defense counsel's firm without calendaring/causing to be calendared, the response deadlines for foregoing discovery. (Maland Decl. ¶ 2). On an unspecified date after such attorney's departure, attorney Kyle Maland assumed the role as the day to day handling attorney. (Maland Decl. ¶ 2).[9]

On July 8, 2022, plaintiff Marbarita Ortega served via email on defendants' counsel (see supra note 7), separate essentially identical sets of Interrogatory Nos. 1-11 (“the Ortega Interrogatories”) directed to Michael Kadisha, Nathan Kadisha, K3 Manager, and K3 Holdings. (Brancart Decl. ¶¶ 10-13; Brancart Exs. 8-13).

*5 On July 15, 2022, plaintiffs' counsel emailed a Local Rule 37-1 meet and confer letter to defendants' counsel based on the asserted failure of the defendants in issue timely to respond to the HRC Kadisha Interrogatories, the HRC K3 Interrogatory Nos. 1-12, and the Document Requests. (Brancart Decl. ¶ 27; Brancart Ex. 22). Attorney Maland – who was not a listed recipient of the foregoing letter – attests that as of July 22, 2022, he was unaware that defendants' deadlines to respond to the HRC Kadisha Interrogatories, the HRC K3 Interrogatory Nos. 1-12 and the Document Requests had already passed and that on July 25, 2022, plaintiffs' counsel advised that there were discovery requests to which no responses were timely served. (Maland Decl. ¶ 3-4). On July 26, 2022, the parties met and conferred/conducted a Local Rule 37-1 conference regarding the foregoing discovery requests. (Brancart Decl. ¶ 28; Brancart Ex. 23). Plaintiffs stated their position that defendants' objections had been waived by the failure timely to respond, but agreed that defendants would have until August 10, 2022, to provide answers and responses and to commence the production of materials responsive to the Document Requests. (Brancart Ex. 23). Defendants indicated that they did not agree that objections had been waived as they assertedly could show good cause for the failure timely to object. (Brancart Ex. 23).

On August 1, 2022, defendants sought an agreement from plaintiffs to stay the case pending a decision on defendants' then anticipated motion to dismiss the case for lack of subject matter jurisdiction (which, as indicated above, was filed on August 12, 2022 and has since been denied). (Maland Decl. ¶ 6; Maland Ex. A). Plaintiffs declined to agree to a stay and defendants did not seek a stay from the court. (Maland Decl. ¶ 6; Brancart Decl. ¶ 36).

On August 10, 2022, Nathan Kadisha served his responses to the HRC Kadisha Interrogatories which consisted entirely of objections. (Brancart Decl. ¶ 15; Brancart Ex. 13). Although it initially appeared that Michael Kadisha did not serve any responses to the HRC Kadisha Interrogatories (see Brancart Decl. ¶ 17), based on the representations of counsel at the hearing on the Motion to Compel, it appears that Michael Kadisha did so respond on August 10, 2022, but that such responses incorrectly reflected that they were provided on behalf of Nathan Kadisha.

Also on August 10, 2022, K3 Manager served its responses to the HRC K3 Interrogatory Nos. 1-12 which consisted entirely of objections. (Brancart Decl. ¶¶ 16, 22; Brancart Exs. 14, 19). Although it initially appeared that K3 Holdings did not serve any responses to the HRC K3 Interrogatories directed to it (i.e., HRC K3 Interrogatory Nos. 1-10) (see Brancart Decl. ¶ 17), based on the representations of counsel at the hearing on the Motion to Compel, it appears that K3 Holdings did so respond on August 10, 2022, but that such responses incorrectly reflected that they were provided on behalf of K3 Manager.

Also on August 10, 2022, K3 Manager served its responses to the Document Requests which consisted entirely of objections, including privilege objections. (Brancart Decl. ¶ 23; Brancart Ex. 20). K3 Manager did not produce any documents responsive to the Document Requests or a privilege log corresponding to responsive documents withheld based upon an assertion of privilege. (Brancart Decl. ¶¶ 24-25).

On August 11, 2022, the Magistrate Judge approved and issued the parties' stipulated Protective Order. (Docket Nos. 60, 63).

On August 15, 2022, plaintiffs' counsel emailed two Local Rule 37-1 meet and confer letters to defendants' counsel – one based on defendants' asserted service of tardy responses consisting entirely of objections to HRC Kadisha Interrogatory Nos. 1-10, HRC K3 Interrogatory Nos. 1-12, and the Document Requests; the other based on the asserted failure of the defendants in issue timely to respond to the Ortega Interrogatories. (Brancart Decl. ¶¶ 29-30; Brancart Exs. 24-25). Notwithstanding the foregoing, Attorney Maland attests that plaintiffs advised defendants that they had failed to serve timely responses to the Ortega Interrogatories two days later – on August 17, 2022 – and that this was the first time he became aware of such discovery requests. (Maland Decl. ¶ 9).

On August 17, 2022, Nathan Kadisha, Michael Kadisha, K3 Manager, and K3 Holdings served essentially identical responses to the Ortega Interrogatories consisting entirely of objections. (Brancart Decl. ¶¶ 18-21; Brancart Exs. 15-18).

*6 Also on August 17, 2022, plaintiffs' counsel emailed a Local Rule 37-1 meet and confer letter to defendants' counsel based on defendants' asserted service of tardy responses consisting entirely of objections to the Ortega Interrogatories. (Brancart Decl. ¶ 31; Brancart Ex. 26).

On August 23, 2022, the parties again met and conferred/conducted a Local Rule 37-1 conference regarding the foregoing discovery requests, among others. (Brancart Decl. ¶ 32; Brancart Ex. 27).

On September 4, 2022, plaintiffs' counsel emailed plaintiffs' portion of the Local Rule 37-2 stipulation and related documents to defendants' counsel and requested that defendants provide their portion by September 13, 2022. (Brancart Decl. ¶ 43).

On September 13, 2022, defendants' counsel requested and was granted an extension of time until September 16, 2022 to provide defendants' portion of the Local Rule 37-2 stipulation and offered to narrow the parties' disputes and provide certain responses to certain of the Discovery Requests in Issue by October 4, 2022. (Blancart Decl. ¶ 44; Maland Decl. ¶ 10; Maland Ex. B). More specifically, defendants' counsel represented that the defendants in issue were agreeable to amending their responses to/producing documents calls for by multiple Document Requests in Issue – RFP Nos. 1-4 (seeking tenant files), RFP No. 6 ([sic] should be 5) (seeking articles of incorporation for defendant entities); RFP Nos. 16-22 (seeking acquisition records for defendant properties from January 1, 2018 to the present); RFP Nos. 23-29 (seeking renovation records for defendant properties from January 1, 2018 to the present; RFP Nos. 30-36 (seeking buyout/relocation records for defendant properties from January 1, 2018 to the present); RFP Nos. 37-42 (seeking advertisement records for defendant properties from January 1, 2018 to the present); RFP No. 50 (seeking tenant information for the named defendant buildings); RFP No. 52 (seeking buyout agreements for the named defendant buildings from January 1, 2018 to the present; RFP No. 54 (seeking eviction records for the named defendant buildings from January 1, 2018 to the present); RFP No. 56 (seeking documents reflecting standards for approving rental applications); RFP No. 58 (seeking documents regarding limiting or preferring a renter based on a protected category); RFP No. 59 (seeking documents regarding or discussing the Los Angeles Tenants Union, tenant organization or tenant union); RFP No. 60 (seeking complaints of discrimination filed with any government entity regarding defendant K3 Management from January 1, 2018 to the present); RFP No. 61 (seeking complaints of discrimination filed with any government agency in which defendants are named as a party from January 1, 2018 to the present); and RFP No. 62 (seeking anti-discrimination training materials). (Maland Decl. ¶ 10; Maland Ex. B). Defendants' counsel further represented that the defendants in issue were agreeable to amending their responses to HRC Kadisha Interrogatory Nos. 1-5 (seeking facts/witnesses supporting affirmative defenses); HRC K3 Interrogatory Nos. 1-4 (seeking facts/witnesses known to date supporting affirmative defenses) and 6 (seeking identity/contact information/dates of involvement for K3's managers and/or members since January 1, 2017); and Ortega Interrogatory Nos. 2 (seeking corporate registration/names of defendant entities), 4 (seeking names/business contact information of real estate agents who represent the parties in the sale of defendant properties), 7, 9 (seeking identity of persons/companies who assisted with the relocation of tenants from defendant properties, if any) and 11 (seeking advertising information, including names/contact information of advertisers, dates of use, names/contact information for publishers). (Maland Decl. ¶ 10; Maland Ex. B).

*7 On September 14, 2022, plaintiffs' counsel emailed defendants' counsel a proposed stipulation by which the parties would essentially agree to the entry of an order compelling defendants to provide the discovery described in defense counsel's September 13, 2022 email by October 4, 2022. (Brancart Decl. ¶ 45; Brancart Ex. 34). Plaintiffs' counsel requested that defendants' counsel either sign/authorize the signing of such proposed stipulation or provide defendants' portion of the Local Rule 37-2 stipulation by September 16, 2022, indicating that no further extensions would be granted. (Brancart Decl. ¶ 45; Brancart Ex. 34). On September 16, 2022, defendants' counsel emailed defendants' portion of the Local Rule 37-2 stipulation to plaintiffs' counsel. (Brancart Decl. ¶ 46).

As the parties were unable to resolve all of their differences regarding the foregoing matters, the instant Motion to Compel followed on September 20, 2022.

On October 17, 2022, defendants Michael Kadisha and Nathan Kadisha served further responses to Ortega Interrogatory Nos. 2, 7, and 11 and HRC Kadisha Interrogatory Nos. 1-5 and defendants K3 Holdings and K3 Manager served further responses to Ortega Interrogatory Nos. 2, 7, and 11 and HRC K3 Interrogatory Nos. 1-4 and 6. (Second Supp. Memo at 1-3 & n.1; Blancart Supp. Decl. ¶¶ 2-4; Blancart Supp. Exs. 1-2).

Defendants in issue have apparently not otherwise produced the discovery described in defense counsel's September 13, 2022 email (which defendants had offered to produce by October 4, 2022).

III. PERTINENT LAW

A. General Discovery Law

Pursuant to Rule 26(b)(1) of the Federal Rules of Civil Procedure, “[p]arties may obtain discovery regarding any nonprivileged matter that is relevant to any party's claim or defense and proportional to the needs of the case, considering the importance of the issues at stake in the action, the amount in controversy, the parties' relative access to relevant information, the parties' resources, the importance of the discovery in resolving the issues, and whether the burden or expense of the proposed discovery outweighs its likely benefit.” Fed. R. Civ. P. 26(b)(1). Information within the foregoing scope of discovery need not be admissible in evidence to be discoverable. Fed. R. Civ. P. 26(b)(1).

Pursuant to Rule 33 of the Federal Rules of Civil Procedure, any party may serve upon any other party written interrogatories within the scope of Rule 26(b). Fed. R. Civ. P. 33(a)(2). A party must respond to interrogatories by answer or objection; the ground for the objection must be stated with specificity. See Fed. R. Civ. P. 33(b)(3)-(4). General or boilerplate objections are improper – especially when a party fails to submit any evidentiary declarations supporting such objections. A. Farber & Partners, Inc. v. Garber (“Farber”), 234 F.R.D. 186, 188 (C.D. Cal. 2006). “Each interrogatory must, to the extent it is not objected to, be answered separately and fully in writing under oath.” Fed. R. Civ. P. 33(b)(3).

A party responding to interrogatories has the option of producing business records where: (1) the answer to the interrogatory may be determined by examining, auditing, compiling, abstracting, or summarizing the records, and (2) the burden of deriving or ascertaining the answer is substantially the same for either party. Fed. R. Civ. P. 33(d). When a party produces business records, the party must “specify[ ] the records that must be reviewed, in sufficient detail to enable the interrogating party to locate and identify them as readily as the responding party could[.]” Id.

Pursuant to Rule 34, any party may serve on any other party a request for the production or inspection of documents within the scope of Rule 26(b) which are in the responding party's possession, custody or control. Fed. R. Civ. P. 34(a). Documents are deemed to be within a party's possession, custody or control if the party has actual possession, custody or control thereof or the legal right to obtain the property on demand. In re Bankers Trust Co., 61 F.3d 465, 469 (6th Cir. 1995), cert. dismissed, 517 U.S. 1205 (1996). Accordingly, a party has an obligation to conduct a reasonable inquiry into the factual basis of its responses to discovery, and based on that inquiry, a party responding to a Rule 34 production request is under an affirmative duty to seek that information reasonably available to it from its employees, agents, or others subject to its control. Farber, 234 F.R.D. at 189 (citations and internal quotation marks omitted).

*8 Unless excused by a protective order, in response to a request for the production of documents a party must, within 30 days of service thereof and as to each item or category, either: (1) state that the inspection will be permitted/production will be made; or (2) state with specificity the grounds for objecting to the request, including the reasons, and state whether any responsive materials are being withheld on the basis of that objection. Fed. R. Civ. P. 34(b)(2)(A)-(C). If the responding party states that it will produce documents, such production must be completed no later than the time specified in the request or another reasonable time specified in the response. Fed. R. Civ. P. 34(b)(2)(B).

If a party fails timely to object to discovery requests, such a failure generally constitutes a waiver of any objections which a party might have to the requests.[10] See Fed. R. Civ. P. 33(b)(4) (any ground not stated in timely objection to interrogatory waived unless court, for good cause, excuses failure); Richmark Corp. v. Timber Falling Consultants, 959 F.2d 1468, 1473 (9th Cir. 1991) (“It is well established that a failure to object to discovery requests within the time required constitutes a waiver of any objection.”) (citation omitted), cert. dismissed, 506 U.S. 948 (1992).[11]

B. Privileges/Privacy

Questions of privilege that arise in the course of the adjudication of federal rights are governed by the principles of federal common law. United States v. Zolin, 491 U.S. 554, 562 (1989) (citing Federal Rules of Evidence 501). Where, as in this case, federal question and pendent state law claims are present, federal law on privilege, not state law, applies. Agster v. Maricopa County, 422 F.3d 836, 839 (9th Cir.), cert. denied, 546 U.S. 958 (2005). Accordingly, this Court will consider only federal privileges in assessing the discovery disputes in issue. To the extent Defendants assert any state-law based privileges, such privileges are not applicable and will not be further addressed. See Miller v. Pancucci, 141 F.R.D. 292, 297-99 (C.D. Cal. 1992) (applying federal privilege law to discovery disputes in federal civil rights action; rejecting contention that California state law should also apply as California rules for discovery and privileges are fundamentally inconsistent with federal rules/law).

*9 When a party withholds information otherwise discoverable by claiming that the information is privileged, the party must (1) expressly make the claim; and (2) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable other parties to assess the claim. Fed. R. Civ. P. 26(b)(5); see also In re Grand Jury Investigation, 974 F.2d 1068, 1071 (9th Cir. 1992) (party asserting privilege must make prima facie showing that privilege protects the information part intends to withhold; privilege log is one means by which party can do so) (citing Dole v. Milonas, 889 F.2d 885 n.3, 890 (9th Cir. 1989)); In re Imperial Corp. of Am., 174 F.R.D. 475, 479 (S.D. Cal. 1997) (although Rule 26(b)(5) does not require document-by-document privilege log, such a privilege log has been, undoubtedly will, and should remain, the traditional format, but provision of same may be unduly burdensome or inappropriate in some circumstances).

Federal courts ordinarily recognize a constitutionally-based right of privacy that can be raised in response to discovery requests. Farber, 234 F.R.D. at 191. Courts balance the need for the information sought against the privacy right asserted. Id.

IV. DISCUSSION AND ORDERS

A. Issues/Objections Relating to Multiple Discovery Requests in Issue

As there are several issues/objections that relate to multiple Discovery Requests in Issue, the Court initially addresses such issues/objections.

First, the Court agrees with defendants that the Joint Stipulation initially prepared by plaintiffs' counsel does not comport with the letter of the Local Rule 37-2.1 in that the parties' contentions as to particular discovery requests in issue are not directly followed by separately stated contentions regarding such requests. (JS at 72). Plaintiffs instead list all of the Discovery Requests in Issue and objections thereto in a serial fashion and then have general sections containing legal arguments which to some degree reference specific Discovery Requests in Issue and to some degree do not. While plaintiffs appear to have structured the Joint Stipulation in this manner in an attempt to be efficient, this has instead rendered the Joint Stipulation unwieldy and sometimes difficult to track, causing the Court (and probably defense counsel) to have to flip back and forth to try and mix and match plaintiffs' various arguments with specific requests in issue. While the Court declines to deny the entire Motion to Compel on this basis and has done its best to follow the parties' arguments and match them with particular requests, plaintiffs are admonished to refrain from utilizing such a structure in the future and instead to simply follow the Local Rules.

Second, the Court finds that the defendants have waived their objections to the Discovery Requests in Issue by their failure timely to respond to the Discovery Requests in Issue and have failed to demonstrate good cause to excuse such waivers (though the Court will excuse the waivers as to attorney-client privilege/work product objections and sua sponte will limit discovery on other grounds to the extent it deems it appropriate). While defendants attribute their untimely responses to a calendaring error/change in the counsel responsible for day-to-day handling of the case, the record reflects that at least two other attorneys remained responsible for the case and were/should reasonably have been aware of the outstanding discovery requests and communicated with new co-counsel relating to the same upon his assignment to the case. Reasonable diligence further suggests that a newly assigned attorney with responsibility for day-to-day handling would promptly review the file to determine what deadlines may be outstanding/speaking to co-counsel regarding the same. Further, one would reasonably expect that becoming aware of outstanding document requests numbered 65-66 (see Maland Decl. ¶ 3), would trigger an inquiry into the status of document requests numbered 1-64/other potentially outstanding discovery and that subsequently becoming aware of missed deadlines/non-calendaring of deadlines for the HRC Kadisha Interrogatories, the HRC K3 Interrogatories and the Document Requests from opposing counsel (see Maland Decl. ¶ 4), would trigger an inquiry into whether any other discovery (such as the Ortega Interrogatories) were outstanding. Notwithstanding the foregoing, the Court sua sponte limits discovery to the extent it deems it appropriate and alternatively addresses certain of defendants' objections on the merits.

*10 Third, to the extent defendants have interposed general objections which they purport to have incorporated into each discovery response in issue, the Court alternatively overrules such objections because such general and boilerplate objections are improper. See Farber, 234 F.R.D. at 188. Such general objections do not explain or analyze on an individualized basis, why any particular discovery request is objectionable, and thus are inadequate.

Fourth, to the extent defendants have objected to/refrained from producing discovery because of the pendency of their motion to dismiss, the Court alternatively overrules such objections/rejects such arguments. The pendency of a motion is not a legitimate basis to refrain from producing discovery which parties are otherwise obligated to produce – particularly in light of the fast approaching case deadlines and, of course, the fact that such motion has since been denied.

Fifth, the Court addresses whether the Discovery Requests in Issue are overbroad and/or call for discovery not relevant/proportional to the needs of the case. The Court sua sponte limits/denies the Motion to Compel as to certain Discovery Requests in Issue without prejudice based on overbreadth/ relevance/proportionality as detailed below. In particular, the Court has denied the Motion to Compel without prejudice as to multiple Discovery Requests in Issue which it views to be vastly overbroad/not proportional to the needs of the case with the expectation that the parties will meet and confer and agree to narrow them. The Court has also narrowed multiple requests which call for information/documents regarding properties beyond the five properties in which the individual tenants resided based upon overbreadth/relevance/proportionality. For example, depending upon the information sought, the Court has limited multiple Discovery Requests in Issue that call for extensive information regarding the 30 properties listed in the Complaint (which include the 28 properties listed in RFP Exhibit 1) to 15 properties of plaintiffs' choice (including the five properties in which the individual tenants resided) as it views 15 properties to provide plaintiffs with an ample/sufficient opportunity to establish the matters it assertedly seeks such information to establish (e.g., to establish a pattern and practice). To the extent the Court below orders defendants to produce discovery over an overbreadth/relevance/proportionality objection, it has alternatively overruled such objections on the merits.

Sixth, except to the extent considered in the Court's sua sponte proportionality analysis, defendants' objections that certain Discovery Requests in Issue are unduly burdensome are alternatively overruled as conclusory, unsupported by evidence and/or otherwise lacking in merit. See Farber, 234 F.R.D. at 188 (collecting cases).

Seventh, the Court addresses whether the Discovery Requests in Issue should be limited based upon privacy/third party privacy issues. The Court sua sponte limits/denies the Motion to Compel as to certain Discovery Requests in Issue based on privacy/third party privacy as detailed below. Further, to the extent the Court below orders defendants to produce discovery over privacy/third party privacy objections it has alternatively overruled such objections on the merits. Where the Court has granted the Motion to Compel as to arguably private information/documents, it has determined that the privacy rights of those involved is outweighed by plaintiffs' need for the information and that such information can be adequately protected by the Protective Order that has been entered in this action. Farber, 234 F.R.D. at 191 (privacy concerns can be addressed by carefully drafted protective order). To the extent the Court has denied the Motion to Compel as to arguably private information/documents, the Court has determined that plaintiffs' need for the information is not outweighed by the privacy rights of those involved.

*11 Finally, to the extent defendants have interposed other objections not otherwise expressly addressed, the Court has alternatively overruled the objections on the merits.

B. Ortega Interrogatory Nos. 1, 3, 5, 7-8, and 10-11

Ortega Interrogatory No. 1 calls for the defendants in issue to identify by full name, date of registration, and office or agency where name is registered, each corporate or fictitious business name, trade name, or assumed name under which any defendant, its principals, employees or agents owned, operated or managed each of the rental properties listed in the Complaint on pages 9-10. (JS at 12).

The Motion to Compel is granted as to Ortega Interrogatory No. 1. Defendants Michael Kadisha, Nathan Kadisha, K3 Manager and K3 Holdings are ordered to provide a substantive response to this interrogatory.

Ortega Interrogatory No. 3 calls for the defendants in issue to identify by full name, brokerage, address, email, telephone and building address, each real estate broker or agent who represented either the seller and/or buyer in connection with the purchase or sale by any defendant, its principals, or agents of each of the rental properties listed in the Complaint on pages 9-10. (JS at 12).

The Motion to Compel is granted as to Ortega Interrogatory No. 3. Defendants Michael Kadisha, Nathan Kadisha, K3 Manager and K3 Holdings are ordered to provide a complete response to this interrogatory.

Ortega Interrogatory No. 5 calls for the defendants in issue to identify by full name, address, email, telephone, and building address, each investor or lender who provided capital or financing to any defendant, its principals, or agents for the purchase of each of the rental properties listed in the Complaint on pages 9-10. (JS at 12-13).

The Motion to Compel is granted as to Ortega Interrogatory No. 5. Defendants Michael Kadisha, Nathan Kadisha, K3 Manager and K3 Holdings in issue are ordered to provide a complete response to this interrogatory.

Ortega Interrogatory No. 7 calls for the defendants in issue, to the extent not fully provided in response to HRC's Interrogatory No. 9, to identify by full name, company name, dates of service or engagement, the total compensation paid to date, and last known mailing and street addresses, telephone, and email, each person or entity engaged by any defendant, its principals, employees or agents in connection with services for the relocation of tenants. (JS at 13).

The Motion to Compel is granted in part and denied in part as to Ortega Interrogatory No. 7. The Court narrows this interrogatory to call for the requested information relative to rental properties listed in the Complaint on pages 9-10 for the time period of January 1, 2019 and directs defendants Michael Kadisha, Nathan Kadisha, K3 Manager and K3 Holdings – to the extent they have not already done so – to provide a complete response to such interrogatory as narrowed.

Ortega Interrogatory No. 8 calls for the defendants in issue, to the extent not fully provided in answer to Interrogatory No. 7, to identify by full name, company name, dates of service or engagement, the total compensation paid to date, and last known mailing and street addresses, telephone, and email, each person or entity engaged by any defendant, its principals, employees, or agents in connection with services for relocation of tenants from each of the rental properties listed in the Complaint on pages 9-10. (JS at 13).

*12 The Motion to Compel is granted as to Ortega Interrogatory No. 8. Defendants Michael Kadisha, Nathan Kadisha, K3 Manager and K3 Holdings are ordered to provide a complete response to this interrogatory.

Ortega Interrogatory No. 10 calls for the defendants in issue, to the extent not fully provided in answer to Interrogatory Nos. 8-9, to identify by the full name, company name, dates of service or engagement, the total compensation paid to date, and last known mailing and street addresses, telephone, and email of each of the following persons or entities: (a) “Sandy Newman” aka email username, tenantrelo7@gmail.com; (b) “Darby” aka email username, tenantrelo3@gmail.com; (c) “Natalia” aka email username, tenantrelo1@gmail.com; and (d) Jacob Avila aka email username jacob.avila.consulting@gmail.com. (JS at 13-14).

The Motion to Compel is granted in part and denied in part as to Ortega Interrogatory No. 10. The Court narrows the inquiry to the time frame of January 1, 2019 to the present (i.e., requiring defendants to supply dates of service and compensation for the specified individuals only during such time period). Defendants Michael Kadisha, Nathan Kadisha, K3 Manager and K3 Holdings are ordered to provide a complete response to this interrogatory as modified.

Ortega Interrogatory No. 11 calls for the defendants in issue to fully describe each method of advertisement used by any defendant, its principals, employees, or agents since January 1, 2019, to advertise dwellings for rent, including each advertiser's name, last known address, telephone and email, any account number associated with each advertiser, dates of use of each advertiser, and the name of the publication or website in which each advertisement was printed or posted. (JS at 14).

The Motion to Compel is granted in part and denied in part as to Ortega Interrogatory No. 11. The Court narrows this interrogatory to call for the requested information relative to rental properties listed in the Complaint on pages 9-10 for the time period of January 1, 2019 and directs defendants Michael Kadisha, Nathan Kadisha, K3 Manager and K3 Holdings – to the extent they have not already done so – to provide a complete response to such interrogatory as narrowed.

C. HRC Kadisha Interrogatory Nos. 5-9

HRC Kadisha Interrogatory No. 5 calls for the defendants in issue – to the extent not fully answered in response to Interrogatories 1-3 – to list each affirmative defense by name and number that the defendants in issue intend to rely upon in this action and fully explain the good faith legal and factual basis for that affirmative defense's application to each claim for relief. (JS at 17). It further calls for the defendants in issue to explicitly list by name and number each affirmative defense that it does not intend to pursue in this action. (JS at 17).

The Motion to Compel is denied without prejudice as to HRC Kadisha Interrogatory No. 5, but counsel are directed to meet and confer regarding affirmative defenses.

HRC Kadisha Interrogatory No. 6 calls for the defendants in issue to identify the substance and source of any evidence the defendants in issue may offer to impeach the testimony of any plaintiff, including but not limited to each plaintiff's prior inconsistent statements, bias, or character for truthfulness. (JS at 18).

*13 The Motion to Compel is denied as to HRC Kadisha Interrogatory No. 6 without prejudice because the Joint Stipulation does not contain any argument specific thereto.

HRC Kadisha Interrogatory No. 7 calls for the defendants in issue to identify each LLC (a) involved in the ownership, operation or management of rental dwellings located in Los Angeles County (b) of which either defendant in issue was a member or manager (c) since January 1, 2018, listing the full name of the LLC, the rental dwelling owned, operated or managed by that LLC, his status (member or manager), and time period such defendant was a member of manager of that LLC. (JS at 18-19).

The Motion to Compel is granted as to HRC Kadisha Interrogatory No. 7. Defendants Michael Kadisha and Nathan Kadisha shall provide a complete response thereto.

HRC Kadisha Interrogatory No. 8 calls for the defendants in issue to identify each (a) rental dwelling located in Los Angeles County (b) owned, operated or managed by any LLC of which either defendant in issue was a member or manager (c) since January 1, 2018, listing each dwelling's address, number of units, ownership, and time period that the dwelling was owned, operated or managed by the LLC. (JS at 19).

The Motion to Compel is granted as to HRC Kadisha Interrogatory No. 8. Defendants Michael Kadisha and Nathan Kadisha shall provide a complete response thereto.

HRC Kadisha Interrogatory No. 9 calls for the defendants in issue to identify (a) each employee, partner, investor, vendor or contractor – by full name, last known address, telephone, and email status (employee, vendor, etc.) and time period of service provided – who (b) since January 1, 2018 (c) provided services in connection with (d) the acquisition, development, rehabilitation, operation, management or sale of (e) any rental dwelling in Los Angeles County (f) owned or operated by any LLC in which either defendant in issue was either a member or manager. (JS at 19).

The Motion to Compel is denied as to HRC Kadisha Interrogatory No. 9 without prejudice as the Court views it to be overbroad/not proportional to the needs of the case.

D. HRC K3 Interrogatory Nos. 5, 7-9, 11-12

HRC K3 Interrogatory No. 5 calls for the defendants in issue to identify the substance and source of any evidence that the defendants in issue may offer to impeach the testimony of any plaintiff, including but not limited to each plaintiff's prior inconsistent statements, bias, or character for truthfulness. (JS at 23).

The Motion to Compel is denied as to HRC K3 Interrogatory No. 5 without prejudice because the Joint Stipulation does not contain any argument specific thereto.

HRC K3 Interrogatory No. 7 calls for the defendants in issue to identify each corporate entity (a) involved in the ownership, operation, or management of rental dwelling (b) in which the defendants in issue held any ownership interest or (c) any management or operational control (d) since January 1, 2017, listing the full name of each corporate entity, such defendant's role (e.g., manager, member, shareholder, etc.), and the time period of its ownership or management. (JS at 24).

The Motion to Compel is granted in part and denied in part as to HRC K3 Interrogatory No. 7. The Court narrows this interrogatory to call for information from January 1, 2018 to the present and directs defendant K3 Manager and K3 Holdings to provide a complete response this interrogatory as narrowed.

*14 HRC K3 Interrogatory No. 8 calls for the defendants in issue to identify each rental dwelling (a) located in Los Angeles County (b) owned, operated or managed by such defendants or any entity owned or managed by them (“Related Entity”) (c) since January 1, 2018, listing each dwelling's address, number of units, ownership, and time period that defendant or any Related Entity owned or operated that rental dwelling. (JS at 24-25).

The Motion to Compel is granted as to HRC K3 Interrogatory No. 8. The Court directs defendant K3 Manager and K3 Holdings to provide a complete response this interrogatory as narrowed.

HRC K3 Interrogatory No. 9 calls for the defendants in issue to identify (a) each individual who provided services to the defendants in issue (b) since January 1, 2018, (c) in connection with its – or any Related Entity's – ownership, operation, or management of (d) any rental dwelling in Los Angeles County, listing each individual by full name, last known address, telephone and email, his or her job title, the nature of his or her services, and the time period during which those services were provided or performed. (JS at 25).

The Motion to Compel is denied as to HRC K3 Interrogatory No. 9 without prejudice as the Court views it to vastly overbroad and not proportional to the needs of the case.

HRK K3 Interrogatory No. 11 calls for K3 Manager to identify by subchapter and section each provision of the General Corporation Law of the State of Delaware, Title 8, Ch. 1 of the Delaware Code that governs the operation of each LLC named as a defendant in this action. (JS at 27).

The Motion to Compel is denied as to this interrogatory as the Court does not view it to be proportional to the needs of the case.

HRK K3 Interrogatory No. 12 calls for K3 Manager to identify by article and section each provision of the California Revised Uniform Limited Liability Company Act, Title 2.6 of the Cal. Corporations Code that governs the operation of each LLC named as a defendant in this action. (JS at 27).

The Motion to Compel is denied as to this interrogatory as the Court does not view it to be proportional to the needs of the case.

E. Document Request Nos. 1-3, 5-58, 59 (numbering erroneously omitted), and 60-64 (misnumbered 59-63)

RFP No. 1 calls for K3 Manager to produce a complete copy of any document – regardless of form, type, purpose or origin – that regards, concerns or discusses any plaintiff in this action. (JS at 28).

As defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 1, the Court grants the Motion to Compel as to RFP No. 1 and directs K3 Manager to produce, to the extent it has not already done so, all non-privileged responsive documents in its possession, custody or control and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 2 calls for K3 Manager to produce – if not produced in response to RFP No. 1 – any document that may be used by any defendant to impeach the testimony of any plaintiff. (JS at 28).

The Motion to Compel is denied as to RFP No. 2 without prejudice because the Joint Stipulation does not contain any argument specific thereto.

RFP No. 3 calls for K3 Manager to produce – if not produced in response to RFP No. 1 – any document that regards, discusses, or concerns any individual plaintiff's household, including any member or guest of that household. (JS at 28).

*15 As defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 3, the Court grants the Motion to Compel as to RFP No. 3 and directs K3 Manager to produce, to the extent it has not already done so, all non-privileged responsive documents in its possession, custody or control and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 5 calls for K3 Manager to produce a complete copy of the articles of incorporation for each LLC named as a defendant in this action, including any amendments thereto. (JS at 30).

As defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by the document request seeking articles of incorporation (erroneously referred to as RFP No. 6), the Court grants the Motion to Compel as to RFP No. 5 – which so requests – and directs K3 Manager to produce, to the extent it has not already done so, to produce all responsive documents in its possession, custody or control and to provide a supplemental response indicating that it has done so.

RFP No. 6 calls for K3 Manager to produce a complete copy of the operating agreement, including all exhibits and attachments, for each LLC named as a defendant in this action, including any amendments thereto. (JS at 31).

The Motion to Compel is granted as to RFP No. 6. Defendant K3 Manager is directed to produce the requested documents and to provide a supplemental response indicating that it has done so.

RFP No. 7 calls for K3 Manager to produce, for each LLC named as a defendant in this action, documents sufficient to determine each capital contribution by (a) name of contributor; (b) date of contribution; (c) amount of contribution; and (d) purpose of contribution (if stated). (JS at 31).

The Motion to Compel is granted as to RFP No. 7. Defendant K3 Manager is directed to produce the requested documents and to provide a supplemental response indicating that it has done so.

RFP No. 8 calls for K3 Manager to produce, for each LLC named as a defendant in this action, documents sufficient to determine each distribution by (a) name of recipient; (b) date of distribution; (c) amount of distribution; and (d) purpose of distribution (if stated). (JS at 31).

The Motion to Compel is granted in part and denied in part as to this request. The Court narrows this request to eliminate the call for information regarding the purpose of any distribution and narrows it to call for the other requested information relative to distributions to LLC members only for the period of January 1, 2019 to the present.

RFP No. 9 calls for K3 Manager to produce, for each LLC named as a defendant in this action, each IRS Form 8832 or 2553 filed with the IRS regarding Entity Classification Election since January 1, 2018. (JS at 31).

The Motion to Compel is denied without prejudice as to this request as the Court does not view the requested tax information to be proportional to the needs of the case, at least at this juncture.

RFP No. 10 calls for K3 Manager to produce, for each LLC named as a defendant in this action, each IRS Form 1065, including schedules, filed with the IRS since January 1, 2018. (JS at 31-32).

The Motion to Compel is denied without prejudice as to this request as the Court does not view the requested tax information to be proportional to the needs of the case, at least at this juncture.

*16 RFP No. 11 calls for K3 Manager to produce, for each LLC named as a defendant in this action, each IRS Form 1120, including schedules, filed with the IRS since January 1, 2018. (JS at 32).

The Motion to Compel is denied without prejudice as to this request as the Court does not view the requested tax information to be proportional to the needs of the case, at least at this juncture.

RFP No. 12 calls for K3 Manager to produce, for each LLC named as a defendant in this action, each IRS Form 1120S, including schedules, filed with the IRS since January 1, 2018. (JS at 32).

The Motion to Compel is denied as to this request without prejudice as the Court does not view the requested tax information to be proportional to the needs of the case, at least at this juncture.

RFP No. 13 calls for K3 Manager to produce, for each defendant not filing an IRS Form 1065, 1120, or 1120S, then the schedules appended to that defendant's IRS tax returns reflecting income derived and expenses incurred from the ownership or operation of any defendant LLC since January 1, 2018. (JS at 32).

The Motion to Compel is denied without prejudice as to this request as the Court does not view the requested tax information to be proportional to the needs of the case, at least at this juncture.

RFP No. 14 calls for K3 Manager to produce, for each defendant, documents sufficient to determine the name, job title, employment dates, work address, business email and business telephone of each person employed (e.g., typically issued an IRS W2) by any defendant, its principals or its managerial employees. (JS at 37).

The Motion to Compel is granted in part and denied in part as to the request. The Court narrows RFP No. 14 to call for the requested information for the period of January 1, 2018 to the present and directs K3 Manager to produce documents responsive to this request as narrowed and to provide a supplemental response indicating that it has done so.

RFP No. 15 calls for K3 Manager to produce, for each defendant, documents sufficient to determine the name, description of services, dates of services provided, business address, business email and business telephone of each person hired as an agent or contractor (e.g., typically issued an IRS 1099) by any defendant, its principals, or its managerial employees. (JS at 38).

The Motion to Compel is granted in part and denied in part as to the request. The Court narrows RFP No. 15 to call for the requested information for the period of January 1, 2018 to the present and directs K3 Manager to produce documents responsive to this request as narrowed and to provide a supplemental response indicating that it has done so.

RFP No. 16 calls for K3 Manager to produce any document – dated, created, or received since January 1, 2018 – reflecting, communicating, or applying any process, procedure or practice followed by any defendant, its principals, employees or agents in the selection of rental dwellings for acquisition. (JS at 32).

As defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 16, the Court grants the Motion to Compel as to RFP No. 16 and directs K3 Manager to produce, to the extent it has not already done so, all non-privileged responsive documents in its possession, custody or control and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

*17 RFP No. 17 calls for K3 Manager to produce any document – dated, created, or received since January 1, 2018 – reflecting, communicating, or applying any substantive criterion considered by any defendant or its principals, employees, or agents in the selection of rental dwellings for acquisition. (JS at 32).

As defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 17, the Court grants the Motion to Compel as to RFP No. 17 and directs K3 Manager to produce, to the extent it has not already done so, all non-privileged responsive documents in its possession, custody or control and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 18 calls for K3 Manager to produce – if not produced in response to RFP Nos. 16-17 – a complete copy of any document – dated, created, or received since January 1, 2018 – regarding the purchase, acquisition, or financing of each building identified in RFP Exhibit 1. (JS at 33).

As defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 18, the Court grants the Motion to Compel as to RFP No. 18 and directs K3 Manager to produce, to the extent it has not already done so, all non-privileged responsive documents in its possession, custody or control and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 19 calls for K3 Manager to produce – if not produced in response to RFP Nos. 16-18 – a complete copy of any advertisement, solicitation, or prospectus regarding the sale or purchase of any building listed on RFP Exhibit 1. (JS at 33).

As defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 19, the Court grants the Motion to Compel as to RFP No. 19 and directs K3 Manager to produce, to the extent it has not already done so, all non-privileged responsive documents in its possession, custody or control and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 20 calls for K3 Manager to produce – if not produced in response to RFP Nos. 16-19 – a complete copy of any communication, including documents exchanged or transmitted between any defendant, its principals, employees, or agents and any real estate agent or broker regarding the sale or purchase of any building listed on RFP Exhibit 1. (JS at 33).

The Motion to Compel is granted in part and denied in part as to this document request without prejudice. The Court narrows this request to call for the requested communications regarding the sale or purchase of 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice). The Court directs K3 Manager to produce, to the extent it has not already done so, a complete copy of the non-privileged documents in its possession, custody or control that are responsive to this request, as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

*18 RFP No. 21 calls for K3 Manager to produce – if not produced in response to RFP Nos. 16-20 – a complete copy of any communication, including documents exchanged or transmitted, between any defendant, its principals, employees, or agents and any seller regarding the sale or purchase of a building listed on RFP Exhibit 1. (JS at 33).

The Motion to Compel is granted in part and denied in part as to this document request without prejudice. The Court narrows this request to call for the requested communications regarding the sale or purchase of 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice). The Court directs K3 Manager to produce, to the extent it has not already done so, a complete copy of the non-privileged documents in its possession, custody or control that are responsive to this request, as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 22 calls for K3 Manager to produce – if not produced in response to RFP Nos. 16-21 – a complete copy of any communication, including documents exchanged or transmitted amongst defendants, their principals, employees, or agents regarding the sale or purchase of any building listed on RFP Exhibit 1. (JS at 33).

The Motion to Compel is granted in part and denied in part as to this document request without prejudice. The Court narrows this request to call for the requested communications regarding the sale or purchase of 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice). The Court directs K3 Manager to produce, to the extent it has not already done so, a complete copy of the non-privileged documents in its possession, custody or control that are responsive to this request, as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 23 calls for K3 Manager to produce any document – dated, created, or received since January 1, 2018 – reflecting, communicating, or applying any process, procedure, or practice followed by any defendant, its principals, employees, or agents regarding the condition, renovation or repair of dwellings owned or operated by any defendant. (JS at 33-34).

The Motion to Compel is granted in part and denied in part as to this document request without prejudice. The Court narrows this request to call for the requested documents regarding/encompassing the condition, renovation or repair of 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice). The Court directs K3 Manager to produce, to the extent it has not already done so, a complete copy of the non-privileged documents in its possession, custody or control that are responsive to this request, as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

*19 RFP No. 24 calls for K3 Manager to produce any document – dated, created, or received since January 1, 2018 – reflecting, communicating, or applying any substantive criteria considered by any defendant, its principals, employees, or agents regarding the condition, renovation or repair of dwellings owned or operated by any defendant. (JS at 34).

The Motion to Compel is granted in part and denied in part as to this document request without prejudice. The Court narrows this request to call for the requested documents regarding/encompassing the condition, renovation or repair of 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice). The Court directs K3 Manager to produce, to the extent it has not already done so, a complete copy of the non-privileged documents in its possession, custody or control that are responsive to this request, as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 25 calls for K3 Manager to produce – if not produced in response to RFP Nos. 23-24 – a complete copy of any document regarding the condition, renovation or repair of dwellings listed on RFP Exhibit 1, including plans, contracts, governmental notices, applications for permits and permits. (JS at 34).

The Motion to Compel is granted in part and denied in part as to this document request without prejudice. The Court narrows this request to call for the requested documents regarding/encompassing the condition, renovation or repair of 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice). The Court directs K3 Manager to produce, to the extent it has not already done so, a complete copy of the non-privileged documents in its possession, custody or control that are responsive to this request, as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 26 calls for K3 Manager to produce – if not produced in response to RFP Nos. 23-25 – a complete copy of any communication, including documents exchanged or transmitted, between any defendant, its principals, employees, or agents and any contractor, vendor, or agent hired to evaluate the condition, renovate, or repair any dwelling in any building listed on RFP Exhibit 1. (JS at 34).

The Motion to Compel is granted in part and denied in part as to this document request without prejudice. The Court narrows this request to call for the requested communications encompassing those between any defendant, its principals, employees, or agents and any contractor, vendor, or agent hired to evaluate the condition, renovate, or repair of 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice). The Court directs K3 Manager to produce, to the extent it has not already done so, a complete copy of the non-privileged documents in its possession, custody or control that are responsive to this request, as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

*20 RFP No. 27 calls for K3 Manager to produce – if not produced in response to RFP Nos. 23-26 – a complete copy of any document reflecting any submission, notice, or communication between any defendant, its principals, employees, or agents and any city, county, or state agency, including the City of Los Angeles Department of Building and Safety, the City of Los Angeles Housing Department (aka the Los Angeles Housing + Community Investment Department (“LAHCID”)), and the Los Angeles Department of Public Health regarding the condition, renovation or repair of any dwelling in any building listed on RFP Exhibit 1. (JS at 34).

The Motion to Compel is granted in part and denied in part as to this document request without prejudice. The Court narrows this request to call for the requested documents regarding/encompassing the condition, renovation, or repair of 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice). The Court directs K3 Manager to produce, to the extent it has not already done so, a complete copy of the non-privileged documents in its possession, custody or control that are responsive to this request, as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 28 calls for K3 Manager to produce – if not produced in response to RFP Nos. 23-27 – a complete copy of any communication, including documents exchanged or transmitted, between any defendant, its principals, employees, or agents, and any tenant regarding the condition, renovation, or repair of any dwellings in any building listed on RFP Exhibit 1. (JS at 34-35).

The Motion to Compel is granted in part and denied in part as to this document request without prejudice. The Court narrows this request to call for the requested communications regarding/ encompassing the condition, renovation, or repair of 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice). The Court directs K3 Manager to produce, to the extent it has not already done so, a complete copy of the non-privileged documents in its possession, custody or control that are responsive to this request, as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 29 calls for K3 Manager to produce – if not produced in response to RFP Nos. 23-28 – a complete copy of any communication, including documents exchanged or transmitted, amongst defendants, their principals, employees, or agents regarding the condition, renovation, or repair of dwellings listed on RFP Exhibit 1. (JS at 35).

The Motion to Compel is granted in part and denied in part as to this document request without prejudice. The Court narrows this request to call for the requested communications regarding/ encompassing the condition, renovation, or repair of 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice). The Court directs K3 Manager to produce, to the extent it has not already done so, a complete copy of the non-privileged documents in its possession, custody or control that are responsive to this request, as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

*21 RFP No. 30 calls for K3 Manager to produce any document – dated, created, or received since January 1, 2018 – reflecting, communicating, or applying any process, procedure, or practice followed by any defendant, its principals, employees, or agents regarding the turnover, removal, eviction, buyout, replacement, relocation or transfer of any tenant in any dwelling owned or operated by any defendant. (JS at 35).

The Motion to Compel is granted in part and denied in part as to this document request without prejudice. The Court narrows this request to call for the requested documents reflecting, communicating, or applying any process, procedure, or practice followed by any defendant, its principals, employees, or agents regarding the turnover, removal, eviction, buyout, replacement, relocation or transfer of any tenant in/encompassing any tenant in 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice). The Court directs K3 Manager to produce, to the extent it has not already done so, a complete copy of the non-privileged documents in its possession, custody or control that are responsive to this request, as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 31 calls for K3 Manager to produce any document – dated, created, or received since January 1, 2018 – reflecting, communicating, or applying any substantive criterion typically considered by any defendant, its principals, employees, or agents regarding the turnover, removal, eviction, buyout, replacement, relocation or transfer of any tenant in any dwelling owned or operated by any defendant. (JS at 35).

The Motion to Compel is granted in part and denied in part as to this document request without prejudice. The Court narrows this request to call for the requested documents reflecting, communicating, or applying any substantive criterion typically considered by any defendant, its principals, employees, or agents regarding the turnover, removal, eviction, buyout, replacement, relocation or transfer of any tenant in/encompassing any tenant in 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice). The Court directs K3 Manager to produce, to the extent it has not already done so, a complete copy of the non-privileged documents in its possession, custody or control that are responsive to this request, as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 32 calls for K3 Manager to produce – if not produced in response to RFP Nos. 30-31 – a complete copy of any document regarding, concerning, or discussing the profitability of any building listed on RFP Exhibit 1, including the factors, conditions, or events affecting its profitability. (JS at 35).

Defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 32 – but as best as the Court can determine – such agreement is limited to only the five buildings in which the individual tenant defendants resided. The Court narrows this request to call for the requested information relative to/encompassing the profitability of 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice) and accordingly grants the Motion to Compel in part and denies the Motion to Compel in part as to RFP No. 32. The Court directs K3 Manager to produce, to the extent it has not already done so, a complete copy of the non-privileged documents in its possession, custody or control that are responsive to this request, as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

*22 RFP No. 33 calls for K3 Manager to produce – if not produced in response to RFP Nos. 30-32 – a complete copy of any document regarding, concerning or discussing the application or effect of the Los Angeles Rent Stabilization Ordinance (LARSO) on the profitability of any building listed on RFP Exhibit 1. (JS at 35-36).

Defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 33 – but as best as the Court can determine – such agreement is limited to only the five buildings in which the individual tenant defendants resided. The Court narrows this request to call for the requested information relative to/encompassing the profitability of 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice) and accordingly grants the Motion to Compel in part and denies the Motion to Compel in part as to RFP No. 33. The Court directs K3 Manager to produce, to the extent it has not already done so, a complete copy of the non-privileged documents in its possession, custody or control that are responsive to this request, as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 34 calls for K3 Manager to produce – if not produced in response to RFP Nos. 30-33 – a complete copy of any document regarding, concerning or discussing the effect of tenant turnover, unit turnover, or unit vacancy on the profitability of any building listed on RFP Exhibit 1. (JS at 39).

Defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 34 – but as best as the Court can determine – such agreement is limited to only the five buildings in which the individual tenant defendants resided. The Court narrows this request to call for the requested information for/encompassing 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice) and accordingly grants the Motion to Compel in part and denies the Motion to Compel in part as to RFP No. 34. The Court directs K3 Manager to produce, to the extent it has not already done so, a complete copy of the non-privileged documents in its possession, custody or control that are responsive to this request, as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 35 calls for K3 Manager to produce – if not produced in response to RFP Nos. 30-34 – a complete copy of any document reflecting or regarding any communication, including the exchange or transmission of documents between any defendant, its principals, employees, or agents, and the LAHCID (aka the LA Housing Department) in connection with defendants' ownership or operation of any building listed on RFP Exhibit 1. (JS at 36).

*23 Defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 35 – but as best as the Court can determine – such agreement is limited to only the five buildings in which the individual tenant defendants resided. The Court narrows this request to call for the requested information for/encompassing 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice) and accordingly grants the Motion to Compel in part and denies the Motion to Compel in part as to RFP No. 35. The Court directs K3 Manager to produce, to the extent it has not already done so, a complete copy of the non-privileged documents in its possession, custody or control that are responsive to this request, as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 36 calls for K3 to produce – if not produced in response to RFP Nos. 30-35 – a complete copy of any communications, including documents exchanged or transmitted, between any defendant, its principals, employees, or agents and any tenant regarding the turnover, removal, eviction, buyout, replacement, relocation or transfer of any tenant in any dwelling in a building listed in RFP Exhibit 1. (JS at 39).

Defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 36 – but as best as the Court can determine – such agreement is limited to only the five buildings in which the individual tenant defendants resided. The Court narrows this request to call for the requested information for/encompassing 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice) and accordingly grants the Motion to Compel in part and denies the Motion to Compel in part as to RFP No. 36. The Court directs K3 Manager to produce, to the extent it has not already done so, a complete copy of the non-privileged documents in its possession, custody or control that are responsive to this request, as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 37 calls for K3 to produce any document – dated, created, or received since January 1, 2018 – reflecting, communicating, or applying any process, procedure, or practice followed by any defendant, its principals, employees or agents regarding the advertisement of dwellings for rent at any building owned or operated by any defendant. (JS at 39).

Defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 37 – but as best as the Court can determine – such agreement is limited to only the five buildings in which the individual tenant defendants resided. The Court narrows this request to call for the requested information for/encompassing 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice) and accordingly grants the Motion to Compel in part and denies the Motion to Compel in part as to RFP No. 37. The Court directs K3 Manager to produce, to the extent it has not already done so and to the extent within its possession, custody or control, all non-privileged documents in its possession, custody or control responsive to this request, as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

*24 RFP No. 38 calls for K3 to produce any document – dated, created, or received since January 1, 2018 – reflecting, communicating, or applying any substantive criterion considered by any defendant, its principals, employees or agents regarding the advertisement of dwellings for rent at any building owned or operated by any defendant. (JS at 39).

Defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 38 – but as best as the Court can determine – such agreement is limited to only the five buildings in which the individual tenant defendants resided. The Court narrows this request to call for the requested information for/encompassing 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice) and accordingly grants the Motion to Compel in part and denies the Motion to Compel in part as to RFP No. 38. The Court directs K3 Manager to produce, to the extent it has not already done so and to the extent within its possession, custody or control, all non-privileged documents in its possession, custody or control responsive to this request, as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 39 calls for K3 to produce – if not produced in response to RFP Nos. 37-38 – a complete copy of each unique advertisement, including any drafts thereof, placed, printed, or published in any media for the rental of dwelling at any building listed on RFP Exhibit 1. (JS at 39-40).

Defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 39 – but as best as the Court can determine – such agreement is limited to only the five buildings in which the individual tenant defendants resided. The Court narrows this request to call for the requested information for/encompassing 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice) and accordingly grants the Motion to Compel in part and denies the Motion to Compel in part as to RFP No. 39. The Court directs K3 Manager to produce, to the extent it has not already done so and to the extent within its possession, custody or control, all non-privileged documents in its possession, custody or control responsive to this request, as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 40 calls for K3 to produce – if not produced in response to RFP Nos. 37-39 – a complete copy of any communication, including documents exchanged or transmitted, between any defendant, its principals, employees, or agents, and any consultant, specialist, or advertiser regarding the nature, type, text, form, audience, prospective tenant profile, or placement of advertisements for the rental of dwellings in any building listed on RFP Exhibit 1. (JS at 40).

*25 Defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 40 – but as best as the Court can determine – such agreement is limited to only the five buildings in which the individual tenant defendants resided. The Court narrows this request to call for the requested information for/encompassing 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice) and accordingly grants the Motion to Compel in part and denies the Motion to Compel in part as to RFP No. 40. The Court directs K3 Manager to produce, to the extent it has not already done so and to the extent within its possession, custody or control, all non-privileged documents in its possession, custody or control responsive to this request, as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 41 calls for K3 to produce – if not produced in response to RFP Nos. 37-40 – a complete copy of any communication, including documents exchanged or transmitted, amongst defendants, their principals, employees, or agents regarding the nature, type, text, form, audience, prospective tenant profile, or placement of advertisements for the rental of dwellings in any building listed in RFP Exhibit 1. (JS at 40).

Defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 41 – but as best as the Court can determine – such agreement is limited to only the five buildings in which the individual tenant defendants resided. The Court narrows this request to call for the requested information for/encompassing 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice) and accordingly grants the Motion to Compel in part and denies the Motion to Compel in part as to RFP No. 41. The Court directs K3 Manager to produce, to the extent it has not already done so and to the extent within its possession, custody or control, all non-privileged documents in its possession, custody or control responsive to this request, as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 42 calls for K3 to produce – if not produced in response to RFP Nos. 37-41, then documents sufficient to determine the publisher and publication frequency of each unique advertisement regarding the rental of any dwelling in any build listed in RFP Exhibit 1

Defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 42 – but as best as the Court can determine – such agreement is limited to only the five buildings in which the individual tenant defendants resided. The Court narrows this request to call for the requested information for/encompassing 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice) and accordingly grants the Motion to Compel in part and denies the Motion to Compel in part as to RFP No. 42. The Court directs K3 Manager to produce, to the extent it has not already done so and to the extent within its possession, custody or control, documents sufficient to determine the matters referenced in this request as narrowed and to provide a supplemental response indicating that it has done so.

RFP No. 43 calls for K3 to produce any document – dated, created, or received since January 1, 2018 – reflecting, communicating, or applying any process, procedure, or practice followed by any defendant, its principals, employees or agents regarding the solicitation of prospective investors or LLC members in connection with defendants' ownership or operation of any rental dwelling. (JS at 40).

*26 The Motion to Compel is denied as to RFP No. 43 without prejudice because the Joint Stipulation does not contain any argument specific thereto.

RFP No. 44 calls for K3 to produce any document – dated, created, or received since January 1, 2018 – reflecting, communicating, or applying any substantive criterion considered by any defendant, its principals, employees or agents regarding the solicitation of prospective investors or LLC members in connection with defendants' ownership or operation of any rental dwelling. (JS at 40-41).

The Motion to Compel is granted in part and denied in part as to RFP No. 44. The Court views this request to be overbroad/not proportional to the needs of the case and narrows it to call for the requested information for prospective investors/LLC members in connection with defendants' ownership or operation of/encompassing 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice). The Court directs K3 Manager to produce, to the extent it has not already done so, all non-privileged documents in its possession, custody or control that are responsive to this request as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 45 calls for K3 to produce – if not produced in response to RFP Nos. 42-43 – a complete copy of any communication, including documents exchanged or transmitted, between any defendant, its principals, employees, or agents and any existing or prospective investor or LLC member regarding building listed in RFP Exhibit 1. (JS at 41).

The Motion to Compel is granted in part and denied in part as to RFP No. 45. The Court views this request to be overbroad/not proportional to the needs of the case and narrows it to call for the requested communications regarding/encompassing 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice). The Court directs K3 Manager to produce, to the extent it has not already done so, all non-privileged documents in its possession, custody or control that are responsive to this request as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 46 calls for K3 to produce any document – dated, created, or received since January 1, 2018 – reflecting, communicating, or applying any process, procedure, or practice followed by any defendant, its principals, employees, or agents in connection with the sale of any rental dwelling owned or operated by any defendant. (JS at 41).

The Motion to Compel is granted in part and denied in part as to RFP No. 46. The Court views this request to be overbroad/not proportional to the needs of the case and narrows it to call for the requested communications regarding/encompassing 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice). The Court directs K3 Manager to produce, to the extent it has not already done so, all non-privileged documents in its possession, custody or control that are responsive to this request as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

*27 RFP No. 47 calls for K3 to produce any document – dated, created, or received since January 1, 2018 – reflecting, communicating, or applying any substantive criterion considered by any defendant or its principals, employees, or agents in connection with the sale of any rental dwelling owned or operated by any defendant. (JS at 41).

The Motion to Compel is granted in part and denied in part as to RFP No. 47. The Court views this request to be overbroad/not proportional to the needs of the case and narrows it to call for the requested information for/encompassing 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice). The Court directs K3 Manager to produce, to the extent it has not already done so, all non-privileged documents in its possession, custody or control that are responsive to this request as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 48 calls for K3 to produce – if not produced in response to RFP Nos. 46-47 – a complete copy of any communication, including documents transmitted or exchanged, between any defendant, its principals, employees, or agents and any real estate agent or broker regarding the sale of any building listed on RFP Exhibit 1. (JS at 41).

The Motion to Compel is granted in part and denied in part as to RFP No. 48. The Court views this request to be overbroad/not proportional to the needs of the case and narrows it to call for the requested information regarding/encompassing the sale of 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice). The Court directs K3 Manager to produce, to the extent it has not already done so, all non-privileged documents in its possession, custody or control that are responsive to this request as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 49 calls for K3 to produce – if not produced in response to RFP Nos. 46-48 – a complete copy of any communication, including documents transmitted or exchanged, between any defendant, its principals, employees or agents and any prospective purchaser of any building listed in RFP Exhibit 1. (JS at 41).

The Motion to Compel is granted in part and denied in part as to RFP No. 49. The Court views this request to be overbroad/not proportional to the needs of the case and narrows it to call for the requested communications with any prospective purchaser of/encompassing any one of 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice). The Court directs K3 Manager to produce, to the extent it has not already done so, all non-privileged documents in its possession, custody or control that are responsive to this request as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

*28 RFP No. 50 calls for K3 to produce documents – such as tenant rosters, property management program data, or seller's disclosures – sufficient to determine (a) on a monthly basis (b) since the date of any defendant's acquisition (closing date) or its first date of operational control of (c) each building listed on RFP Exhibit 1 (d) the occupancy of each dwelling unit therein, including the unit number, configuration and size (i.e., BR/BA/SqFt), full name of household head (i.e., lead tenant), first date of occupancy, last date of occupancy, monthly rent, monthly charges for utilities, services, or amenities, the number and age of each household members, and the unit's RSO registration number. (JS at 42).

Defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 50 – but as best as the Court can determine – such agreement is limited to only the five buildings in which the individual tenant defendants resided. The Court narrows this request to call for the requested information for 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice) and accordingly grants the Motion to Compel in part and denies the Motion to Compel in part as to RFP No. 50. The Court directs K3 Manager to produce, to the extent it has not already done so and to the extent within its possession, custody or control, documents sufficient to determine the matters referenced in this request as narrowed and to provide a supplemental response indicating that it has done so.

RFP No. 51 calls for K3 to produce documents – such as tenant rosters, property management program data, or seller's disclosures – sufficient to determine the whereabouts of each household head (lead tenant) who rented a dwelling unit in any building listed in RFP Exhibit 1, identified by unit number, full name, race or ethnicity, last known address, telephone, email, and dates of occupancy for the period since any defendant acquired (closing date) or assumed operational control of the tenant's building. (JS at 42).

The Motion to Compel is granted in part and denied in part as to RFP No. 51. As the Court views this request to be overbroad/not proportional to the needs of the case, the Court narrows it to call for the requested information (to the extent within K3 Manager's possession, custody or control) for 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice). The Court directs K3 Manager to produce all documents in its possession, custody or control that are responsive to this request as narrowed and to provide a supplemental response indicating that it has done so.

RFP No. 52 calls for K3 to produce a complete collection of all buyout agreement and related notices, and any revisions or amendment thereto offered to any tenant occupying a dwelling in any building listed in RFP Exhibit 1. (JS at 42).

Defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 52 – but as best as the Court can determine – such agreement is limited to only the five buildings in which the individual tenant defendants resided. The Court narrows this request to call for the requested information for 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice) and accordingly grants the Motion to Compel in part and denies the Motion to Compel in part as to RFP No. 52. The Court directs K3 Manager to produce, to the extent it has not already done so, all documents in its possession, custody or control that are responsive to this request as narrowed and to provide a supplemental response indicating that it has done so.

*29 RFP No. 53 calls for K3 to produce a compete collection of each buyout agreement fully executed by any defendant, its principals, employees, or agents and any tenant who occupied a dwelling in any building listed in RFP Exhibit 1. (JS at 43).

The Motion to Compel is granted in part and denied in part as to this request. As the Court views RFP No. 53 to be vastly overbroad and not proportional to the needs of the case as framed and to call for private information, it narrows it to call for – for the period of January 1, 2018 to the present – a complete collection of the requested buyout agreements as to any tenant in the five buildings in which the individual tenant defendants resided and ten other buildings listed on RFP Exhibit 1 of plaintiffs' choice. The Court directs K3 Manager to produce, to the extent it has not already done so (and subject to the Protective Order), all documents in its possession, custody or control that are responsive to this request as narrowed and to provide a supplemental response indicating that it has done so.

RFP No. 54 calls for K3 to produce a complete collection of any notice of any type related to the termination for any reason of the tenancy of any tenant in any building listed in RFP Exhibit 1. (JS at 43).

Defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 54 – but as best as the Court can determine – such agreement is limited to only the five buildings in which the individual tenant defendants resided. The Court narrows this request to call for the requested information for 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice) and accordingly grants the Motion to Compel in part and denies the Motion to Compel in part as to RFP No. 54. The Court directs K3 Manager to produce, to the extent it has not already done so, all documents in its possession, custody or control that are responsive to this request as narrowed and to provide a supplemental response indicating that it has done so.

RFP No. 55 calls for K3 to produce a complete collection of all documents reflecting or regarding the temporary or permanent relocation or transfer of any tenant in any building listed in RFP Exhibit 1. (JS at 43).

The Motion to Compel is granted in part and denied in part as to this request. As the Court views RFP No. 55 to be vastly overbroad and not proportional to the needs of the case as framed, it narrows it to call for documents sufficient to reflect for the period of January 1, 2018 to the present, the temporary or permanent relocation or transfer of any tenant in the five buildings in which the individual tenant defendants resided and ten other buildings listed on RFP Exhibit 1 of plaintiffs' choice and the reason(s) therefor.

RFP No. 56 calls for K3 to produce any document reflecting or regarding any qualification criteria or applications, or rental standards or procedures such as income standards, application requirements, application fees, credit analysis, or rental approval procedures, or other requirements used by any defendant, its principals, employees, or agents, to determine whether to accept an application for rental of a dwelling at any building listed in Exhibit 1. (JS at 43).

*30 Defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 56 – but as best as the Court can determine – such agreement is limited to only the five buildings in which the individual tenant defendants resided. The Court narrows this request to call for the requested information for/encompassing 15 of the locations identified on RFP Exhibit 1 (the five buildings in which the individual tenant defendants resided, plus 10 others of plaintiffs' choice) and accordingly grants the Motion to Compel in part and denies the Motion to Compel in part as to RFP No. 56. The Court directs K3 Manager to produce, to the extent it has not already done so, all non-privileged documents in its possession, custody or control that are responsive to this request as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 57 calls for K3 Manager to produce a complete copy of the data/ESI kept or stored in any rental property management program, such as Yardi, Buildium, AppFolio, etc., regarding any defendant's ownership or operation of any building listed on RFP Exhibit 1. (JS at 28-29).

The Motion to Compel is denied as to RFP No. 57 because such request is vastly overbroad, lacks specificity and is not proportional to the needs of the case. (Having said that, and to avoid any confusion, the Court clarifies that to the extent the Court has ordered defendant K3 Manager to produce documents responsive to one or more other document requests that may be kept or stored in a rental property management program, defendant K3 Management is obligated to produce such specified ESI).

RFP No. 58 calls for K3 to produce any document that indicates a preference or limitation on the basis of race, color, ethnicity, national origin, or familial status (families with children) in connection with the rental, sale, purchase, occupancy, management, or ownership of any rental dwelling. (JS at 43).

As defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 58, the Court grants the Motion to Compel as to RFP No. 58 and directs K3 Manager to produce, to the extent it has not already done so, all non-privileged responsive documents in its possession, custody or control and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 59 (number erroneously omitted) calls for K3 to produce a complete copy of any insurance agreement under which an insurance business may be liable to satisfy all or part of a possible judgment in this action, or to indemnify or reimburse for payments made to satisfy the judgment, or to pay all or part of the cost of defense against any claim asserted in this action. (JS at 45).

The Motion to Compel is granted as to RFP No. 59 (which essentially seeks items required to be disclosed as part of defendants' initial disclosures – see Fed. R. Civ. P. 26(a)(1)(A)(iv)) and directs K3 Manager to produce responsive documents in its possession, custody or control and to provide a supplemental response indicating that it has done so.

RFP No. 60 (misnumbered as 59) calls for K3 to produce any document regarding, discussing, or concerning the Los Angeles Tenants Union (LATU), including any tenants union, tenant organization, or tenant organizer affiliated with LATU. (JS at 43).

As defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 60 (misnumbered as 59), the Court grants the Motion to Compel as to RFP No. 60 (misnumbered as 59) and directs K3 Manager to produce, to the extent it has not already done so, all non-privileged responsive documents in its possession, custody or control and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

*31 RFP No. 61 (misnumbered as 60) calls for K3 to produce any complaint filed with any governmental agency or court related to any rental dwelling owned or operated by any defendant. (JS at 44).

As defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 61 (misnumbered as 60), the Court grants the Motion to Compel as to RFP No. 61 (misnumbered as 60) and directs K3 Manager to produce, to the extent it has not already done so, all non-privileged responsive documents in its possession, custody or control and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 62 (misnumbered as 61) calls for K3 to produce any complaint filed with any governmental agency or court in which any defendant, its principals or employees are named as a party. (JS at 44).

As defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 62 (misnumbered as 61), the Court grants the Motion to Compel as to RFP No. 62 (misnumbered as 61) and directs K3 Manager to produce, to the extent it has not already done so, all non-privileged responsive documents in its possession, custody or control and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 63 (misnumbered as 62) calls for K3 to produce any certificate or training materials reflecting any training in fair housing or nondiscrimination laws received or attended by any principal, employee, or agent of any defendant. (JS at 44).

As defendants' counsel previously represented that defendants were agreeable to amending their responses to/producing documents called for by RFP No. 63 (misnumbered as 62), the Court grants the Motion to Compel as to RFP No. 63 (misnumbered as 62) and directs K3 Manager to produce, to the extent it has not already done so, all non-privileged responsive documents in its possession, custody or control and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

RFP No. 64 (misnumbered as 63) calls for K3 to produce any certificate or training materials reflecting any training in the Los Angeles Rent Stabilization Ordinance received or attended by any principal, employee, or agent of any defendant. (JS at 44).

The Motion to Compel is granted in part and denied in part as to RFP No. 64 (misnumbered as 63). The Court narrows it to call for the requested materials for the period of January 2012 to the present and orders Defendant K3 Manager to produce all non-privileged documents in its possession, custody or control that are responsive to this request as narrowed, and a privilege log – consistent with the parties' agreement in the Joint Rule 26(f) Report – corresponding to any responsive documents withheld based upon an assertion of privilege and to provide a supplemental response indicating that it has done so.

*32 IT IS SO ORDERED.