Oh and P.S. I agree that he is avoiding "Discovery" for a reason. That is your first hint that you already have leverage you can use to your advantage.
Depositions are a AMAZINGLY effective way to haul out as much dirty laundry as you can dream up. You can ask anyone, about anything for as long as needed. And they are sworn under oath to tell the truth. My wife caved in before having to face a Deposition. Yes it was leverage I knew I had from day one of the process.