I am an attorney based in Fort Lauderdale, Florida.
Rule 1.350 of the FL Rules of Civil Procedure are liberally construed. That said, the documents requested must be somewhat relative to your case. They cannot be "so excessive as to be unduly burdensome to the party ordered to produce."
Generally, information sought must relate to issues involved in litigation. It is probably smart to retain an attorney to help with crafting objections to specific requests and then defend you in a hearing in case opposition files a motion to compel responses.
Yes, he has an attorney and you do not so you are going to be pushed around. You are meeting with an attorney so heed that advice and we will wish you well.
This is intended to be general guidance and not necessarily state specific advice. There are some concepts that are the same or similar in most jurisdictions but not all. Use the AVVO.com web site to find an attorney in your area for state specific advice. In addition to that, contact your local bar association for referral to an attorney who specializes in this or talk to friends and neighbors to ask about an attorney they have used and liked. Often, but not always, the attorney will do an initial consultation free of charge. You will then be in a better position to determine what to do next. Best of luck to you!
If you liked this answer, click on the thumbs up or vote it best answer! Thanks. Eliz. C. A. Johnson Post Office Box 8 Danville, California 94526-0008 Legal disclaimer: I do not practice law in any state but California. As such, any responses to posted inquiries, such as the one above, are limited to a general understanding of law in California and not to any other jurisdiction. In addition, no response to any posted inquiry should be deemed to constitute legal advice, nor to constitute the existence of an attorney/client or other contractual or fiduciary relationship, inasmuch as legal advice can only be provided in circumstances in which the attorney is able to ask questions of the person seeking legal advice and to thus gather appropriate information.