The meet and confer process has failed. Now you have to decide whether (1) you need to bring a Motion to Compel Further Documents because the documents are an integral part of the defense and/or prosecution of your case, or (2) wait for trial and make a motion in limine to exclude the documents categorically at trial. Two of the factors you are going to have to consider are how much time it’s going to take to prepare the motion as well as the cost to your client.
Most attorneys underestimate the time and cost in filing a Motion to Compel Further Responses.