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Housing Court Statement of Material Facts

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THE COMMONWEALTH OF MASSACHUSETTS

Housing Court Department

Division

Address

,SS:

No. / / C / / V / / / / /

STATEMENT OF MATERIAL FACTS

(Please Print)

Plaintiff(s)

Address:

Tel:

Defendant(s)

Address:

Tel:

BRIEFLY STATE THE FACTS:

Signed under the pains and penalties of perjury on:

Date:

Signature:

Enter text

What the Housing Court Statement of Material Facts Is

The Housing Court Statement of Material Facts is a sworn, concise factual summary used in landlord-tenant litigation to present undisputed facts for the judge’s consideration. It lists chronological events, lease terms, payment history, notices served, inspection dates, and other concrete facts that parties agree are uncontested or that the submitting party intends to prove. Courts use the statement to narrow issues, expedite hearings, and support motions for summary judgment or default judgments. Accuracy and completeness are essential because statements often substitute for live testimony on routine, uncontested matters.

Why a Clear Statement Matters in Housing Court

A Housing Court Statement of Material Facts clarifies disputed issues, streamlines hearings, and enables judges to rule on narrow legal questions efficiently. Clear, well-supported statements reduce evidentiary disputes and can shorten case timelines while preserving parties’ procedural rights.

Why a Clear Statement Matters in Housing Court

Who Prepares and Uses These Statements

Common users include litigants, attorneys, and pro se tenants preparing material fact statements for housing court proceedings.

  • Landlords and property managers preparing clear timelines and payment records to support eviction actions.
  • Tenants responding to claims who document repairs, payments, notices, and lease compliance defenses.
  • Attorneys using statements to narrow issues, support summary judgment, and streamline discovery.

Courts rely on precise, verified facts; parties should corroborate entries with exhibits, affidavits, and service proof before filing.

Typical Signers and Preparers

Tenant (Pro Se)

A self-represented tenant compiles a concise list of dates and events—rent payments, repair requests, and notices—to present uncontested facts. Including copies of receipts and dated photographs reduces the need for live testimony and helps the judge verify the timeline quickly.

Landlord/Attorney

Landlords and their attorneys assemble lease excerpts, payment ledgers, served notices, and inspection reports to establish undisputed facts. Organized exhibits with clear labels and a chronology make the statement admissible and easier for the court to consider during trial or motion practice.

Core Elements of a Professional Statement

A professional Statement of Material Facts contains numbered facts, precise dates, cross-referenced exhibits, clear signatory blocks, a chronology, and a succinct cover page for court intake.

Numbered Facts

Present each fact as a numbered line item. Include the date, location, brief description, and source citation such as a lease paragraph or dated notice so the judge can verify quickly.

Chronology

Provide a short chronology summarizing events in order. Chronologies reduce ambiguity and help the court understand causal connections between rent payments, repairs, notices, and breaches.

Exhibit Index

Create an exhibit index listing each attachment with its exhibit label, document type, date, and a brief explanation of how it supports a specific numbered fact in the statement.

Signatures

Include signature lines for the preparer and each signing party with printed name, title (if applicable), and date. If an attorney signs, include bar number and firm contact information.

Statement Cover

Add a brief cover page with case caption, court, docket number, party contact details, and a short summary of the issues the statement addresses for quick judicial reference.

Format Standards

Use consistent fonts, page numbers, and margins per local rules. Prefer PDF/A or court-accepted PDF to preserve formatting and ensure embedded exhibit references remain stable during filing.

Step-by-Step: Preparing and Filing the Statement

Follow these ordered steps to prepare and file a concise Statement of Material Facts that aligns with court rules and exhibits.

  • 01
    Collect Evidence: Gather leases, receipts, notices, and photos.
  • 02
    Draft Chronology: Number facts chronologically and include precise dates.
  • 03
    Attach Exhibits: Label and reference each exhibit next to the fact.
  • 04
    Review & Sign: Confirm accuracy, sign, and notarize if required.

How Electronic Preparation and Submission Works

Electronic preparation and submission streamline exchanges with opposing counsel and the court while preserving an audit trail and attached evidence for each material fact.

  • Upload Document: Start from a PDF or DOCX file.
  • Place Fields: Insert signature, date, and exhibit tags.
  • Share for Review: Send to opposing counsel and parties.
  • File with Court: Follow local e-filing or paper rules.

Technical Considerations for eSubmission

Electronic creation and submission require compatible file formats, secure delivery, and authentication measures that satisfy court and local rules.

  • File Formats: Accept PDF, PDF/A, DOCX.
  • Integrations: Connects with Google Workspace and NetSuite.
  • Authentication: Email, SMS codes, or stronger methods.

Common Filing and Service Deadlines

Time limits for filing and serving statements vary by jurisdiction; follow local rules and the scheduling order for deadlines and response times.

File with Complaint:

Attach or file as required by local court.

Service on Opposing Party:

Serve per court rules; include certificate of service.

Response Deadline:

Opposing party responds per scheduling order.

Hearing or Motion Dates:

The court schedules hearing dates after filings.

Appeal and Preservation:

Preserve the record and timely appeal per local rules.

Frequent Preparation Mistakes to Avoid

  • Omitting exhibit labels or failing to attach supporting documents creates evidentiary gaps and can force courts to exclude unverified facts at hearing.
  • Using argumentative or conclusory language instead of neutral factual statements risks straying into legal argument and may be disregarded by the judge.
  • Incorrectly formatted dates, missing docket numbers, or mismatched party names can result in misfiling or rejection under local court intake rules.
  • Failing to serve the opposing party or to file a certificate of service as required may void the filing or reopen contested issues.

Consequences of Incorrect or Incomplete Statements

Statement Rejected: Noncompliant pleadings may be rejected.
Delay in Hearing: Scheduling may be postponed.
Evidence Excluded: Uncorroborated facts may be excluded.
Sanctions Risk: Bad-faith filings can incur sanctions.
Fee Exposure: Court costs or attorney fees possible.
Perjury Exposure: False sworn facts may lead to perjury.

Practical Tips for Accurate, Efficient Statements

Follow local rules, corroborate facts with admissible exhibits, avoid argumentative phrasing, and confirm service and filing procedures before submission to court.

Double-check dates, receipts, and notices
Cross-check entries against original documents and digital metadata. Confirm timestamps on emails and service receipts. Discrepancies should be resolved or noted with an explanation to prevent evidentiary challenges at hearing.
Keep language factual, not argumentative
State observable events, dates, and outcomes without legal conclusions. Avoid phrases that argue liability; reserve legal argument for briefs and oral argument rather than the fact statement. Cite statutes only when necessary and label them as legal references, not facts.
Use clear exhibit labeling and cross-references
Ensure every exhibit is uniquely labeled and referenced in the corresponding fact entry. Include a brief exhibit description and the page or Bates range so the court can locate supporting proof rapidly.
Confirm local service and filing rules
Check court rules for e-filing, paper submission, certificate of service, and required copies. Some housing courts require additional attestation or local form attachments; noncompliance can delay hearings or result in rejection.

Real-World Examples Showing Practical Use

Two representative scenarios illustrate how Statements of Material Facts clarify disputed timelines and support motions or trial preparation in housing court matters.

Case Study: Late Rent

A landlord filed a Statement listing missed payments, notices served, and attempted contacts with dates and exhibit labels to document nonpayment.

  • Judge used undisputed timeline to grant summary judgment.
  • Because each fact referenced a specific receipt or email and exhibits were cross-referenced, the court required no live testimony for routine payment facts, shortening the hearing and reducing counsel time.

Case Study: Repair Dispute

A tenant submitted dated repair requests, photographs, and inspection reports itemized in a material facts statement to rebut landlord claims of notice absence.

  • Cross-referenced exhibits supported tenant's timeline.
  • The court considered the documented repair history alongside service records; because the tenant’s facts were corroborated, the judge narrowed live testimony to contested legal issues rather than factual chronology, reducing hearing duration.

Essential Document Header Fields

Document Title: Housing Court Statement of Material Facts
Court Name: Housing Court or specific county court
Docket Number: Case or docket identification number
Parties: Plaintiff (landlord) | Defendant (tenant) names
Date Filed: Use MM/DD/YYYY format for all dates
Exhibit List: Attach labeled exhibits and evidence

Frequently Asked Questions About Statements of Material Facts

Common questions about preparing and filing a Housing Court Statement of Material Facts, with concise answers to reduce procedural errors and evidentiary disputes.


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