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The following fact pattern contains all the relevant information. How do I prepare a straightforward discovery motion for a client of the firm utilizing this

The following fact pattern contains all the relevant information. How do I prepare a straightforward discovery motion for a client of the firm utilizing this fact pattern? What specific documents should I ask for?
The client of the business has filed a lawsuit to recover their whole apartment rental deposit. Because the unit has been damaged, the landlord is refusing to reimburse the deposit. The leaky pipes that caused these damages were immediately reported to the landlord. According to the client, the lease agreement clearly mentions this kind of damage and specifies that the landlord is accountable for it. The client is looking for a copy of the signed lease from the landlord because hers was unfortunately water damaged.

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