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I am filing out a PLD-C-010 and am confused. i read advise

Customer Question
to write next to each...
i am filing out a PLD-C-010 and am confused. i read advise to write next to each allegation "deny" or "admit" but also instructed to write out addressing each assertion. additionally, what if part of the assertion is true but part not? deny all? bot***** *****ne i had a tenant do over 10K in damage to my home, kept his deposit, mailed all receipts, invoices EVERYTHING within 15 days, 3 months later his lawyer asked for it again. told all is good then 8 months later being sued for breach of contract. cant find a lawyer and must respond in 3 days.
JA: Because laws vary from place to place, can you tell me what state this is in?
Customer: orange county california
JA: Has anything been officially filed? If so, what?
Customer: only on his behalf. i received his complaint and that is what i am responding to. again the crazy part is he has everything he is asking for, even his lawyer admits he still has the 50+ page binder with all receipts ect and over 200 pictures
JA: Anything else you want the lawyer to know before I connect you?
Customer: no, are you a lawyer? its contract law that i need help with
Submitted: 3 months ago.Category: Business Law
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Answered in 32 minutes by:
7/31/2017
Business Lawyer: Richard - Bizlaw, Attorney replied 3 months ago
Richard - Bizlaw
Category: Business Law
Satisfied Customers: 10,684
Experience: 30 years of corporate, litigation and international law
Verified

Hello, my name is Richard-Bizlaw and I will try to help you. Please remember I just report or interpret the If law, so the outcome may not be what you hoped for.

If anything in an allegation is not true, no matter how minor, then you deny the allegation. If all the statements are false, then you check box 3.a. If only some of the statements are false, then you have to check box 3.b. and state which ones are not true and in what respect.

If I have answered all your questions, please positively rate my answer as that is how I receive credit. If you have more questions, please let me know. If the answer was especially helpful you can provide a bonus.

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Customer reply replied 3 months ago
he answered my question. To be honest I'm still a little confused about some things but I think it is more comprehensive than what this form can help me with thank you for your help
Business Lawyer: Richard - Bizlaw, Attorney replied 3 months ago

If you have a follow up question let me know and I will try to help you. If your question has been answered please rate my answer with at least 3 stars as that is how I get credit for working on your question.

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Customer reply replied 3 months ago
i believe, for the most part, I have completed the PLD-C-010. right now I am just reviewing for grammatical errors, ect. I would feel a whole lot better if I could find a lawyer to look it over prior to turning it in. I was out of town when the papers were served and simply did not have time to secure a lawyer.
The entire situation is beyond bazaar making my response difficult (aside from the fact I am an accountant turned stay at home mom not a lawyer). My husband and I are being accused of breach of contract from a tenant that moved out nearly 2 years to the day. The tenant did SUBSTANTIAL damage to the home, some of which he acknowledged in writing as well as not paying just under 500 in utility bills that as landlords we got stuck paying.
Less than 21 days from the tenant moving out we mailed an extremely detailed spreadsheet of all the repairs included all receipts, invoices, etc (bot***** *****ne 100% compliant with both California laws and the lease). three months later the previous tenant has a lawyer contact us. we provide everything again only more detailed, more invoices now that more work was completed and over 150 pictures, and offered hundreds more or to answer any questions. we have a fedex receipt as proof we sent the backup. his lawyer acknowledged he received the binder and stated we will not be hearing from him again and made a comment that he did not understand what his client was thinking (not professional but if you knew his details, you might not be as surprised, they are both extremely odd people). ANYWAY, the lawyer admitted to still having all of the necessary backup after filing the complaint yet the complaint claims we never mailed anything.
The plaintiff was/is in breach of contract many, many times over. i am trying to figure out if along with my denials to each of the allegations do I do into detail of why the allegations are not true and furthermore do I mention how the plaintiff was in breach of contract in regards ***** ***** item that he is wrongfully accusing us of breach.
There are many, many things wrong with this lawyers complaint and I cant figure out what best way to attack it. for now I just went line item by line item but i am worried I did it incorrectly.
here is an example:
We, Bridgette Peck and Kevin Peck, deny allegation number five. The term of the lease did not expire on July, 31, 2015. In accordance with Item 2. Section B (iii) Landlord accepted August rent from Tenant in which case a month-to-month tenancy was created which either party could terminate as specified in paragraph 2A of the signed Residential Lease or Month-to-Month Rental Agreement.
On August 20, 2017, the Plaintiffs (Landlords), received a certified letter from the Defendant (previous Tenant). In accordance with the now month-to-month tenancy, Section 2 item A of the lease, “the Tenant may terminate the tenancy by giving written notice at least 30 days prior to the intended termination date.” Per Section 2, Item A of the Month-To-Month Rental Agreement, the Plaintiff’s letter established a lease end date of September 19, 2015.
Customer reply replied 3 months ago
if I click "call me" and pay the $79, when will you call me? am I given an estimated time frame. I am guessing you aren't going to call me now at midnight, or do you?
Business Lawyer: Richard - Bizlaw, Attorney replied 3 months ago

I sent you an offer for a live phone conversation. I could not put in that message that I would also review your draft answer and give you comments. So you would get not just a phone call but a review of your answer. If you accept you will also get a private email address to send your draft answer that I will review. That is why the cost is a little more than the $79 you mentioned in your post.

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Customer reply replied 3 months ago
That sounds wonderful but before we go any further I need you to know this has to be filed by tomorrow. It is best everything is up front so you understand my timeline and don't overextend yourself.
If this is okay I will call you as soon as I get home from taking my daughter to an appt. - approx 1130am.
I have a rough draft of a previous version, not TOO different, on my phone, I can send immediately.
If you are comfortable with the timeline I can send a payment and then the rough draft, previous copy immediately, then call you around at 1130.
please let me know if you want to move foreward.
Customer reply replied 3 months ago
i need to turn it in tomorrow. can you help me in that time frame. if so please let me know, i will pay the $$ and we can get going as soon as you are availabe.
Business Lawyer: Richard - Bizlaw, Attorney replied 3 months ago

Yes you can call but make it 12 noon as I will be back by that time. You have to accept the offer first and we can proceed. If when you accept you also give me your email address I will contact you by email and you can send your draft before we talk if you want.

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Richard - Bizlaw
Richard - Bizlaw
Richard - Bizlaw, Attorney
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