This motion is for each discovery item, so if you got the trio and the responses are all bad, you get one for admissions, one for form interrogatories, one for production. That's $1800 total. It includes for each motion, the basic motion, the long and tedious Separate Statement, and any Request for Judicial Notice that might be needed. The Separate Statement has to list what we asked, how they answered , and why that's not good enough.

Usually, the landlord responds to your discovery with nothing but objections and evasive answers, in order to conceal that they don't have a case. First, we have to "meet and confer" [Item #376] and then file this motion, which has to be heard no later than 5 days prior to trial. The landlord's strategy is to speed up the trial while stalling us on your discovery to use that 5-day cutoff to avoid telling you anything. That is why we try to start discovery as soon as possible and use the Demurrer to buy us more time to get the discovery motions done.

If the judge grants your motion, the landlord will have some time to provide the answers, the trial can be postponed, and the judge should award you attorney fees incurred in bring these motions, to reimburse you for these expenses. If their new response is still evasive, you can file another one of these motions.

Discovery is the most expensive part of the lawsuit before trial, but it is the only way to find out what your landlord will claim and present at trial. Without discovery, the landlord could tell a whopper at trial that, if you had only known he would claim that, you could have had the proof ready to show it's a lie. Unless you follow through with the motions to compel further responses, you are stuck with what little they said in their responses. You can still ask the same questions at trial that the landlord didn't answer in discovery, but you do take the risk of the whopper you can't disprove.

This charge may vary greatly with the number and complexity of the issues, but it does NOT include any related motions or ex partes, responses to their opposition, reading or advising on their opposition, phone calls, faxes, scans, emails, or mail.