Legal writing has to separate arguments into sections.
NO
Denied: entry without permission, breaking in, harassing & humiliating plaintiff in front of people, threatening her to call police
YES
Denied: entry without permission,
The lease of xx/xx/xx provides that "landlord can enter with tenant's consent". The consent does not have to be in writing.
then state your fact.
Therefore The allegation of "enter without permission" is not supported by the facts.
Denied breaking in,
The legal definition of breaking in is "google your state law", or quote her complaint.
state your fact
Therefore The allegation of "breaking into her apartment " is not supported by the facts.
Denied harassing & humiliating plaintiff in front of people, threatening her to call police
find legal definition or quote her complaint
state your fact
...
