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Motion to Compel discovery

A pro-se defendant needs to file a motion to compel discovery. The discovery was propounded but the Plaintiff's attorney keeps coming up with reason not to answer it, without providing legal basis. Demands were made, and timeline extended, and now it's time to compel. Please provide an estimated budget or number of hours you expect to expand. The Plaintiff failed to respond at all, they are not disputing the number of the RFAs, or particular ones, they are disputing that they need to answer discover at all.

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