These are the basic documents you would probably use to get the information from the landlord.

The UD form interrogatories are the easiest to fill out, but you still need to know which ones apply to your case. Checking all of them is not a good idea for several reasons.

The requests for admission ask the landlord to admit that certain specific things are true, so that you have already proven them for trial if he does. For anything he denies, we use the General form interrogatories to get the facts, witnesses and documents that support his denial.

The requests for production require the landlord to give you the papers that relate to the case, like the lease with modifications, payment records, letters and emails, repair records, photographs, corporation organization documents, fictitious business name statements, management contracts, and so forth. He didn't want to give them to you before, but now he has to, since he's filed this case.