Antlers, I work in IT and we have to do a lot of email and document searches for litigations. One of the tactics these lawyers play is ask for the world...knowing fully well they don't need it but it gives them an out if we can't produce the docs by saying we're hiding something. However, the judges know this and if they take it to court they will have to show cause for these searches. Again, not an attorney just an IT geek.
I just heard back from my attorney on this:
"Produce what you have and only what you can reasonably get. I will let [paralegal] know that if opposing counsel wants more, they can go to their expense of subpoena-ing them."
Me: 35|WAW: 38|D: 6yo | http://tinyurl.com/2dxx7m6 Feb 2006, left, came back in two weeks Aug 2006, left again Apr 2007, filed for divorce Dec 2007, reunited Mar 2010, moved out, filed again