B.

    This Court Should Grant Defendant Dan Donner’s Motion to Compel Discovery Because

Plaintiff Patt’s Personal History is Relevant to the Defense.

This Court should grant Mr. Donner’s Motion to Compel Discovery because Ms. Patt’s personal history is

relevant to the defense that Mr. Walters declined to rent to her because she is unreliable and irresponsible.

(Apply Fed. R. Civ. P. 26(b)(1) to the Defendant’s Motion to Compel.)

If Ms. Patt  is unwilling to provide the Mr. Walters enough information about her

personal history to establish her character and reputation, then she has not demonstrated a

willingness to comply with the rental application process. Ms. Patt’s refusal to share basic

information about her background suggests the plaintiff could be hiding relevant information

from the landlord. For instance, the occupancy of the unit that P is interested in is limited to two

people. As a result, it is relevant for building management to inquire if S.P’s father will be

staying there. The identity of S.P’s father is relevant because the building manager should be

aware of who is entering or staying in the building in the interest of other tenant’s safety. Some

of Ms. Patt’s background information is necessary to ensure that she is fit to rent the property,

the rules of the building will be followed, and the safety of other tenants will be ensured.