It is entirely possible that the landlord's lawyer shrugs off your discovery efforts by giving incomplete and evasive answers and responses to your discovery, and multiple unfounded objections. Under the system, you then have to try to informally resolve the impasse by a "meet and confer" effort.

In a simple case, it can be done by you over the phone, but in a more complex case, where there are several or many items in dispute, the situation generally calls for a written meet and confer letter which can be delivered, emailed, or faxed to them. Generally, you have to give them some time to respond before you then file your motion to compel.

The document requires your lawyer to review the questions, the landlord's responses, and explain for each and every one what is wrong with their responses and what you are seeking. That can be very time-consuming, so that this process might take longer than the estimate hour required for this $500 payment, depending on the number and complexity of the questions and responses. If it will take longer, you will be advised and pay the difference prior to completion of the letter.