Here's a hint - they will submit it. There are certain discovery costs that are allowed to be charged to the defense by law. Normally, the citing agency will ignore it for small requests (e.g. 10 pages or less), but in this case a fee of $15 is justified. There are two ways you can learn this - the easy way or the hard way. I'd suggest the easy way on this one.
As for the delay with getting discovery, i don't think you'd get very far with it. You still have to establish that failure to comply with discovery harmed your ability to plan a defense. Considering that your arraignment is at least a month away, you'd have a tough time establishing that your case got prejudiced by a slight delay. As far as I can tell, the prosecution has complied with discovery and you're not going to make much of a headway trying to get a dismissal on this grounds.
Since you got popped for making a right without stopping, have you checked if you can use the free right turn defense? Basically, if there is a dedicated right turn lane with a raised island that creates a dedicated channel for vehicles making a right turn, you are only required to yield to other traffic rather than make full stop unless there is a traffic light to the RIGHT of the turn channel. Post a googlemaps link to the intersection along with the direction you were traveling.

