Referring to the case below, and if the Landlord was your client, what questions would you ask him/her on examination for discovery?

John (Landlord) applied for an Order to terminate the tenancy and evict Michelle Barrenwark (Tenant) from Unit 4B, because the tenant did not pay the rent that they owe.

Three months ago, from today's date, the Landlord woke up to the sound of someone knocking loudly on his front door. He opened the door to find his tenant of Unit 4B, standing before him very angry. The tenant had arrived home from her night-shift to find her driveway blocked by the Landlord's car, and a padlock on the door of her rental unit.

For the past 2 months, the tenant has been behind on her rental payments. The Landlord had tried to contact the tenant regrading the overdue rent on several occasions. When the landlord could not get her attention, he decided to block her driveway and lock her out of the unit. A shouting match ensued, which was only brought to an end when the tenant called the police. The police ordered the Landlord to remove both the car and the lock on the door.

Things got worse a week later when Tenant experienced water, internet, and power outages at her unit 4B. She called the Landlord to complain about this.

The Landlord was frustrated with the fact that the Tenant was still behind with her rent and the fact that her neighbors were constantly calling him to file noise complaints against her. She shared the unit with her three adult sons. The landlord decided to take steps to evict the tenant and her family from the unit.