Answer to Unlawful Detainer
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Eviction Defense packet
Everything a tenant needs to defend an unlawful detainer in California: file the answer, prove service on the landlord, attach extra defenses, and waive the filing fee if money is tight.
What Ezel does with UD-105
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What is UD-105?
Tenant's response to an unlawful detainer (eviction) lawsuit in California Superior Court.
What happens if you miss the deadline: If you miss it, the court can enter a default judgment against you.
How to file
- Filing fee
- First-appearance fee in a limited civil unlawful detainer case is set by Cal. Gov. Code § 70613 and the Judicial Council uniform fee schedule. The dollar amount depends on the amount demanded by the complaint: lower for claims of $10,000 or less, higher above. Recent schedules put the answer fee in the $225-$370 range; the operative number is published on courts.ca.gov and changes periodically, so verify before filing. Pro se tenants who qualify file FW-001 (fee waiver) at the same time as the UD-105.
- Filing method
- in-person, mail, efile (county-specific; many California courts accept e-filing for unlawful detainer answers, particularly in larger counties such as Los Angeles, San Diego, San Francisco, Alameda)
- Filing deadline
- Cal. Code Civ. Proc. § 1167 (as amended by AB 2347, Stats. 2024, ch. 512, effective 01/01/2025) sets the answer deadline. After personal service of the summons and complaint, the tenant has 10 court days (excluding weekends and judicial holidays per CCP § 12 and § 12a) to file (§ 1167(a)). If service was completed by mail or in person through the Secretary of State's Safe at Home address confidentiality program, the tenant gets an additional 5 court days, for 15 court days total (§ 1167(b)). Missing the deadline lets the landlord request a default judgment under CCP § 1169, which produces a writ of possession and effectively ends the case. The court can extend the deadline only by noticed motion or by stipulation; missing the deadline without a court order is a hard loss in nearly every case.
- How to serve
- POS-030 (Proof of Service by First-Class Mail) is filed alongside the answer to show service on the plaintiff or the plaintiff's attorney of record. Per Cal. Code Civ. Proc. § 1015, when the plaintiff has counsel of record, service is on the attorney, NOT on the landlord directly. Service of the answer is by mail under § 1013(a); personal service is also acceptable but rare in pro se practice. The 5-day add-on for in-state mailing under § 1013(a) does not extend the answer deadline (the deadline runs from service OF the complaint on the tenant, not from service OF the answer on the landlord).
- Wet signature
- Yes, sign in pen after printing.
- Notarization
- No
- Original and copies
- One signed original to the clerk, one conformed copy returned to the tenant for their records, and one copy mailed (with POS-030) to the plaintiff or plaintiff's attorney. Practical instruction: print 3 copies, sign all 3 on the verification, file 1, mail 1, keep 1.
Common pitfalls
Two highest-leverage checks for the AI review on UD-105. (1) Deadline. Post-AB 2347 (eff. 01/01/2025) the window is 10 court days from personal service (15 court days if service was by mail or through Safe at Home); review should flag any indication that the verification date is past the applicable window, since that suggests a default risk. (2) Service of the answer on opposing counsel. Mailing the answer to the landlord directly when the landlord has counsel of record is improper service under § 1015 and can be challenged. The review must check whether POS-030 is addressed to the attorney listed on the complaint when one is listed.
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Rule 2.111(1) requires the case caption to identify 'the attorney for the party in whose behalf the paper is presented, or of the party if he or she is appearing in person.' Without the filer's name the court cannot route service or identify the answering party.
- Listing only a first name or a nickname when the lease and complaint use a full legal name; clerks match captions on cross-pleadings and a 'Joe' / 'Joseph' mismatch can route the answer into the wrong file.
- Listing the spouse's or roommate's name because the lease lists multiple tenants; the answer must be filed by each named defendant, and each defendant who files an answer signs their own copy.
Caption must include 'office address or, if none, residence address or mailing address (if different).' Pro se filers without an office address must list residence or mailing address.
- Tenants who are still living at the premises listed in the complaint sometimes hesitate to print that address here; the rule requires an address where the court can mail notices, and the rental unit is acceptable until the tenant has somewhere else.
- Tenants moving out mid-case sometimes list the old address; the court will mail hearing notices to whatever address is on the answer, so use the address where mail will actually reach the tenant during the case.
Part of the address required by rule 2.111(1).
- Putting a neighborhood name (e.g., 'Hollywood') instead of the postal city (Los Angeles); use the city as it appears on the user's mail.
Part of the address required by rule 2.111(1). Defaults to CA on this form because this is a California court filing.
- Out-of-state mailing address: a tenant who has already moved to a different state can still answer a California UD case, but the state code here should match the postal address used in the previous fields.
Part of the address required by rule 2.111(1).
- Tenants from a recently changed neighborhood sometimes use the old ZIP. The ZIP must match the city on the prior field, or the court's mailings (and any service of the answer back at the tenant) may bounce.
Rule 2.111(1) lists 'telephone number' among the items the caption 'must' include. Disability Rights California's pro se guide also instructs tenants to print their phone number.
- Omitting the area code when the tenant has always lived in the same area; the form caption is read by clerks and opposing counsel statewide, so 10 digits is the safer answer.
- Listing a friend's or family member's phone without telling them. The court calls this number for hearing reminders and continuance notices.
Rule 2.111(1) literally lists 'e-mail address' among the items the caption 'must' include, with NO explicit exception for self-represented parties. However, the Disability Rights California pro se guide instructs tenants to print 'name, address, telephone number, and email address' without indicating email is mandatory. In practice, California court clerks accept UD-105 filings from self-represented tenants with a blank email field; no reported clerk rejections on this basis. The rule appears to be drafted with attorneys in mind (also requires fax + State Bar number). For the runtime AI review: do not block or even warn on a blank email for self-represented filers.
- Filers worry the strict text of rule 2.111(1) means a blank email will get the answer rejected. It will not, for self-represented tenants paper-filing a UD answer.
- Filers paste an email they rarely check. If the case later moves to e-service, this becomes the address opposing counsel and the court use; pick one the filer actually monitors.
- Filers list a shared household email that the landlord or a co-tenant can read. The caption is public; treat the email like a public-facing contact, not a private one.
Rule 2.111(2) requires identifying 'the party on whose behalf the paper is filed.' For self-represented tenants this is conventionally written as 'Defendant in Pro Per' or 'Defendant, in Propria Persona.'
- Leaving this blank because the filer is not an attorney; the caption still needs to identify whose paper it is. 'Defendant in Pro Per' is the standard pro se answer.
- Writing 'Self' or 'Pro Se' rather than 'Pro Per' or 'In Propria Persona'; California courts use the Latin 'Pro Per' label, not the federal 'Pro Se' label, by long-standing convention.
The case caption must identify 'SUPERIOR COURT OF CALIFORNIA, COUNTY OF [name]'. Unlawful detainer cases are filed in the county where the property is located (CCP § 1166).
- Filing in the county where the tenant moved to, rather than the county where the rental unit is located. Venue under CCP section 1166 is the county where the property sits; filing elsewhere is grounds for a motion to transfer.
- Copying the wrong county off a complaint that names a different property than the one the tenant occupies (rare, but happens with multi-property landlords).
Caption must include the court's street address.
- Copying the mailing address from the complaint when the courthouse has separate mailing and physical addresses; the caption traditionally lists the physical street address, with the mailing address (if different) shown on a separate line.
- Using a downtown civic center address when the local rules send unlawful detainer matters to a specific limited-jurisdiction branch.
Caption must include the court's city and ZIP.
- Listing the county seat city when the courthouse is in a different city. Confirm against the courthouse address on courts.ca.gov.
Counties with multiple courthouses (LA, San Diego, Sacramento, Orange, Alameda, others) require the specific branch name so the clerk can route the file. Failing to specify can result in the answer being routed to the wrong branch and missing the assigned judge.
- Naming the city instead of the branch (e.g., 'Compton' vs 'Stanley Mosk Civil Courthouse, Compton'); branches have official names assigned by the court and the case clerk routes by that name.
- Filing at a courthouse other than the one designated for unlawful detainer in the local rules. Some counties (e.g., LA) channel UD cases to specific branches; check the complaint's case number prefix or call the self-help center if uncertain.
Rule 2.111(4) requires the case number on every page of every filed document. Without a case number the clerk cannot match the answer to the existing case.
- Mistyping a digit; the case number is the only key the clerk uses to match the answer to the file. A single transposed digit can land the answer in another tenant's case.
- Confusing the case number with the summons number or a docket number; the case number is on the top right of the complaint's first page and on every page of the summons (form SUM-130 in unlawful detainer).
- Some county clerks pre-print a case number stamp at filing; tenants who get a stamped complaint should copy the stamped number, not invent one.
Caption must include the plaintiff's name. Disability Rights California's pro se guide instructs: 'Print the Plaintiff's (Landlord's) name, exactly as it appears on the Complaint.'
- Writing the property manager's name (e.g., 'Sunrise Property Mgmt') when the actual plaintiff is the owning LLC ('1234 Main St LLC'); the property manager is usually not the named plaintiff. Read the complaint, not the rent receipt.
- Writing only the entity short name when the complaint uses the full legal name with 'LLC' or 'Inc.'. Drop nothing; copy character-for-character.
- Dropping a 'dba' (doing business as) clause when the complaint includes one; if the complaint reads 'XYZ LLC dba Sunset Apts', the answer caption should match.
Caption must include the defendant's name. In our UI this auto-cross-fills from your_name; the underlying form field is required either way.
- Listing only the named filer when the complaint names additional defendants (roommates, all occupants); each named defendant who answers must be in the caption, OR each must file their own answer.
- Correcting the lawsuit's spelling of the defendant's name on the answer (e.g., complaint says 'Robert Jones', tenant prefers 'Bob Jones'); match the lawsuit's spelling. Name corrections happen by motion, not silently in the caption.
- Including 'Doe' defendants from the complaint; Does are placeholders for unidentified persons and the actual tenant defendants do not need to copy them into the answer's caption.
Form text reads 'Check ONLY ONE of the next two boxes.' Box 2a (general denial) is permitted only if complaint demands $1,000 or less. Box 2b (specific denials) requires listing paragraph numbers admitted/denied. One must be selected to constitute a valid answer; an answer with neither denial mode selected leaves the complaint effectively unanswered.
- Checking 2a (general denial) when the complaint demands more than $1,000. CCP section 431.30(d) blocks general denial for verified complaints over $1,000; an improper general denial can be stricken on motion, leaving the complaint effectively unanswered.
- Checking BOTH 2a and 2b. The form text says 'Check ONLY ONE.' Two checks invite the landlord to move to strike for ambiguity.
- Checking 2b but leaving the paragraph-list field blank. If 2b is checked, the answer must specify which paragraphs are admitted and which are denied; an empty 2b is treated as no answer at all.
Form text states 'Must be completed in all cases.' If a non-attorney UDA was paid for help, their identity, address, registration county, registration number, and expiration date must all be disclosed (BPC §§ 6411, 6412). Software like fill is not a UDA , it's a tool, not a person , so the truthful answer for self-represented users using only software is 'did not.'
- Treating advice from a free legal aid clinic, a court self-help center staffer, or a friend who is an attorney as 'UDA assistance' and checking 'did'; UDAs are paid non-attorney form-preparation businesses (BPC section 6400), not legal aid volunteers or pro bono counsel. The truthful answer in those cases is 'did not.'
- Treating fillable PDF software (Ezel, Adobe, etc.) as UDA assistance; software is a tool, not a UDA. 'Did not' is the truthful answer.
- Checking 'did' but omitting the UDA's BPC section 6402 registration number, county, and expiration date. If 'did' applies, all sub-fields must be completed.
The Verification block at the end of the form must be dated and signed under penalty of perjury. Without a date the verification is invalid and the answer can be stricken on motion.
- Dating the verification more than 10 court days after the personal-service date on the summons (or more than 15 court days after service by mail or through the Safe at Home program). CCP section 1167(a) sets a 10-court-day window for personal service; subdivision (b) adds 5 court days for mail / Safe at Home (amended by AB 2347, eff. 01/01/2025). A verification dated outside the window suggests default-judgment exposure under CCP section 1169.
- Backdating the verification to a date before the user actually signed; verification under penalty of perjury must reflect the date of signing.
- Leaving the date and signing line blank, intending to fill it at the courthouse; the answer is unverified until the date is on it, and an unverified answer to a verified complaint can be stricken (CCP section 446).
Sources
- Form UD-105 (PDF, Rev. January 1, 2026)
- California Code of Civil Procedure § 1167 (answer deadline in unlawful detainer)
- California Code of Civil Procedure § 1169 (default judgment in unlawful detainer)
- California Code of Civil Procedure § 446 (verification of pleadings)
- California Government Code § 70613 (uniform civil case filing fees)
- Disability Rights California, Instructions for UD-105
- California Courts Self-Help: Eviction (tenant)
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