Calling all attornies!!!

Long story short, we filed for modification of custody and are about to file for contempt of court. Our reasoning (as listed on the documents) for the modification is due to her consistent violations.

Mediation is scheduled for 01/09. We received a letter from her new attorney saying we are required to answer to his interrogatories that he listed on the page. And if we chose not to provide him with our proof of her contempt, among his other questions, we are required to give him the reasons why we would not provide such documentation and what those documents are.

Correct me if I'm wrong but we don't have to provide him with that? There is no judge signature and we don't have to legally answer to a lawyer, especially if there isn't a trial in place. Is that basically a tactic to get us to show him our cards in advance? She also tried to get us for attorney fees. But again, there's no trial in place yet.