I'm Lucy, and I'd be happy to answer your questions today. I'm sorry to hear about your situation.
You have the ability to file a Motion to Compel against them for not complying with your discovery requests. Before you can do that, you have to request a meeting to discuss what they have not sent and why. The request can be sent via email (which helps you prove that you did it), but it can also help to call so you can show the judge you made multiple efforts to reach them. If they refuse to discuss why they didn't give your discovery or don't provide any meaningful answers, then you'd file the motion.
A judge has many remedies for discovery violations available to him. They will first be ordered to produce the documents, but if they continue to stall or not produce the requested documents, it is possible for the judge to enter judgment against them as punishment for ignoring discovery requirements. That usually doesn't happen on the first Motion to Compel, but you can outline everything they've done and
You can also request sanctions against them for filing a frivolous motion. Once the judge has denied a Motion for Summary Judgment, the likelihood of dismissing a case outright is extremely low, and they should know that. The judge has already found that there are factual questions that need to be answered at trial. They're essentially doing this to wear you down, not because there is any valid legal argument, and that's a violation of the Rule of Professional Conduct. That would be done in your response to their motion against you. Even though their motion is ridiculous, it's still important for you to reply.
If you have any questions or concerns about what I've written, please reply so that I may address them. If I did not address the specific thing that you wanted to know, it may not have come across clearly to me, so please restate that question. It's important to me that you are 100% satisfied with the service I provide. Otherwise, please rate my service positively so that I get credit for answering your question. Thank you.