The minimum charge is for the standard motion. Due to the complexities of what might be involved in the motion we are trying to undo, and there are many different and compounding types, more time may be required than the expected hour to provide the effective motion for you. The charge is PER MOTION, so if there are three motions to file, 3 units of this are $2400.

It is most common for the landlord to avoid giving honest answers to your discovery, but to arrogantly provide only objections and evasive responses to our discovery. If the landlord had confidence in their case, you would have gotten straight answers. Their objections and evasive responses to discovery show they they lack confidence, and don't want you to get the evidence to win. You have turned the tables.

The purpose of discovery is to learn in advance what the landlord claims, so that at trial, you will be ready to disprove what they claim. They don't want that. The only way to get that information is by a court order to compel them to respond. This motion to get that order. If they still hide the truth, the judge can order that you have proving the point you intended to make by getting that evidence.

Unfortunately, this motion is expensive. The time to prepare it requires more than the basic templates use in other areas. Each question, response and reason to require it has to be provided in a "Separate Statement", which is a time consuming process. The result is that each motion is $800; to compel admissions and production both would be $1600. Of course, by this time, you have saved so much in rent, you are really spending the landlord's money on this. If you win the motion, the judge can order the landlord to reimburse you for this expense as punishment.