Repairs

Advised CL re LL (OP's) duty of habitability and reasonable repair
Advised CL that this duty can only be modified and cannot be cancelled, waived, or eliminated.

Advised CL to prove the repair issues, bring as much documentation of repair issues as she can. Advised CL to request repairs in writing/document any time CL has asked OP to perform repairs. Advised CL to take pictures of any repair issues as well.

Advised CL if CL is going to withhold b/c of the repairs, want to make sure it is kept in escrow. Advised CL, if CL does put the rent in escrow, will be difficult to convince judge withheld rent for repair issues (as opposed to just not having the money.)

Advised CL 100 percent abatement of rent is extremely rare and CL should be prepared to pay at the very least a portion of rent (ideally CL will put total rent amount in escrow).