You don't have to turn over everything they ask for. And you only have to honor a judge's subpoena for the information. Work with your attorney on it.

Then can ask for everything but only give what's forced by subpoena.  It's a game. Your lawyer needs to look out for you and not give away your children's privacy. 

I can't imagine you'll have to produce that stuff.  They're probably doing it to drown you in paper and hope you produce something of value to them.  Your attorney will likely object to most of it.

Edited to add:  What is the custody battle for?  Is someone trying to get more time, or are you trying to change the schedule?  If BM's parents are wealthy and willing to provide endless funds for her lawyer, this could break you.

Is none of the HCBM business, if and that's a big if, you are subpoenaed to hand over any information about your kids, I would redacted so much that it would be just a black page. Anything medical, legal or financial should be off limits, besides how would she know about any emails between you and your DH? Please tell me when they split that he changed all his passwords and HCBM doesn't have access to viewing his emails?

They are playing you. They can ask in one hand and shit in the other and they will find out in a hurry which hand fills up first.

Anyone can ask for anything in discovery.  You are not required to provide anything much less everything.  Your personal communication between you and your husband is none of BM's or her idiot attorney's business and your attorney should have the balls to tell them both to fuck off.  

If your attorney is worth a crap he will shut the bullshit down and nail their asses to the wall with a comprehensive justifiable list of discovery items that a Judge will force them to provide.  

Use your head, apply the test of reasonableness to their discovery requests, shut them down on the ridiculous crap and go for their throats with logical and justifiable discovery requests of your own.

Do not give this toxic harpy space in your head and learn to be energized by battling her crap and barring her ass.  This is the long game.  The side with the firmest commitment to winning.... wins.

Idiots like the BM in your situation will always hang themselves by trying to take too much rope.

Enjoy the process.

Remind yourself that this is *only* a custody battle and you are not being tried for murder. They can ask for anything they want, doesn't mean they have to get it. I think it's highly unlikely that a judge will supboena your private messages - like I said, you're not on trial, this is not a criminal case.

I hope you get a judge who not only sees the games she's been playing but also that she's behaving like  jack russell terrier who has gotten his teeth into a toy and won't let go. 

Just make sure that all of her income is requested with all the details including all her bank statements so that any *gifts* from her parents or anyone else come to light.

Just say you don't have anything to turn over. Once texts are deleted you can't recover them. They can't prove otherwise.

Most people don't save texts because it takes up memory space on the phone.

OMG, I just had a memory. When DH was in court last because BM wanted an increase in CS and college tuition ordered, DH had to submit our joint tax returns - so I redacted my SSN, as a normal person would.  Of course tuition was ordered, and when BM sent the first bill for tuition along, SS's Student ID was redacted.  We puzzled over that for a while - did she think DH would hack into SS's student account?  Then it occurred to me - she was upset that he redacted my SSN, and this was payback.  Sure enough, that got it out of her system and when the next bill came along, we could see his Student ID.

These women are nuts. I can't imagine being in their heads.  Such bitterness all the time.

OP, I say that you tell them that you delete all texts and emails except for sexy ones, which you hang to for material for your sex life.  Then send those along to her attorney ...        

I am not a lawyer, but shouldn't communications between husband and wife be covered under spousal privilege? They are asking your husband to waive privilege. He shouldn't voluntarily waive privilege. BM can ask for anything. That does not mean DH has to give unreasonable/ not legally required items.

Dh gets VERY nervous anytime court dates are brought up. Toxic Troll, when he didnt want to work on her car, threatened to up the spousal support and child support, throwing all kinds of numbers around, adding a few references to "her lawyer". 

I told him

1. she cant go up for a review any old time she wants, its every 3 years, unless something major happens.

2. Shes full of chit, because the judge already went through the formula and came up with a number. His pay hasnt changed and so she can take a flying leap.

3. She was on her last month of spousal support. Once spousal support is awarded it takes an act of God to change it. So there she can go pound sand on that one too...