Sometimes, the landlord's lawyer does not respond to your discovery at all. This motion is to get an order that the landlord answer your questions, produce the required documents and/or that the court deem admitted those requests for admission when that happens. In addition, we seek an order that the landlord reimburse you for the discovery expenses in getting this motion and the related work completed, as a punishment for giving you a hard time.
If you don't file this motion, you are stuck with what little information you have provided by the landlord's lawyer. Maybe it's enough as is and not worth filing this motion to get what was excluded. If you do file it, there is still the chance that the judge denies the motion, and you've wasted your money. However, in most cases, the judge does back you up, and requires at least some of the hidden information to be supplied to you, often with the trial delayed until some time after you receive the responses.
This portion of the case can be additionally problematic because the trial may be approaching and a separate ex parte application to continue the trial may also be required for this motion to be heard. This $200 estimate itself 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.