Here is the bare-bones discovery in eviction cases. You CAN prepare these yourself, but need to be sure that you check the right boxes. This form covers basc information in the typical eviction case, such as money paid, repairs needed, actions by the landlord, service of the notices, and so forth.

Discovery should be done at the earliest opportunity after the motion to quash is finally decided, because things can go quickly after that, such as the shortened hearing on the demurrer. There is a deadline by which all discovery has to be completed, and if the landlord's lawyer tries to stall you with evasive tactics, and you need to file a motion to compel, even that has a deadline to file which you may not meet if you delay in beginning discovery.