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allow “pest control, and handymen reasonable access for the purpose of making repairs and/or
improvements.”
On October 15, defendant filed a written answer generally denying each allegation in the
complaint and asserting various affirmative defenses, including that plaintiff’s demand for
possession violated LARSO. Among the cited violations of LARSO were that the premises
were not registered with the City of Los Angeles as required by LAMC section 151.05, and that
plaintiff “did not post and/or serve on tenant the Certificate of Registration as required by
LAMC [section] 151.05(A).”
Motion for Summary Judgment
Defendant filed a motion for summary judgment, asserting as undisputed material facts
that the subject premises was an illegal residential unit subject to LARSO, and that plaintiff
failed to register the unit. In relevant part, defendant argued plaintiff’s failure to register the
unit rendered the occupancy unlawful and the underlying lease agreement an illegal contract.
He alleged the violation of LARSO, i.e., the lack of registration, served as a complete
affirmative defense to the action.
In support of his motion, defendant filed declarations from himself and his attorney.
Attached as exhibits to the latter were the following.
• A Notice and Order to Comply from Los Angeles Housing and Community Investment
Department (HCIDLA), dated May 23. The document indicated plaintiff’s unit was in
violation of specific sections of the LAMC, ordered plaintiff to eliminate the identified
violations no later than June 29, and advised plaintiff that an inspection of the premises
would be conducted on July 2.
• A July 3 complaint submitted by defendant and a co-tenant to the HCIDLA. It alleged
plaintiff attempted to illegally evict the tenants and did not tender relocation assistance
fees.
• An inspection notice from the HCIDLA, dated July 15, indicating the premises would be
re-inspected on October 2 to verify compliance with applicable codes and regulations,
and noting in particular the violation of LAMC section 161.902 identified during the