The unopposed motion to compel responses to UHS’s requests to produce documents is granted. The defendant’s request for sanctions is denied. The proposed order will be signed as modified.

Analysis: Although the defendant sought sanctions in the sum of $950, no declaration explains how that sum is calculated, how many hours were incurred to bring the motion, or what hourly rate is reasonable. The Court also notes that defendant’s counsel wrote a letter to plaintiff’s counsel concerning the lack of any responses, but offers no evidence that any phone call was ever placed to plaintiff’s counsel before drafting and filing the motion. Without a reasonably diligent meet-and- confer effort, the Court will not impose sanctions. For both reasons, the request for sanctions is denied.