In the event that the landlord's lawyer files a motion to compel your responses, you will need to file an Opposition showing why you should not have to respond, or to pay the landlord's costs for filing that motion. While the costs on this can vary greatly with the number and complexity of the issues, this $400 estimate is PER MOTION, and does not include any related consultation, email, faxes, phone calls, mail or related ex parte motions. Any additional money required will be paid before the drafting of your Opposition is completed, and any overage will be credited to your account for future use or refund.