in Re Hugh Larkin ( 2015 )

ACCEPTED
01-15-00392-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
5/6/2015 6:28:00 AM
CHRISTOPHER PRINE
NO. 01-15-00392-CV
CLERK
In the Court of Appeals for FILED IN
1st COURT OF APPEALS
the First District of Texas HOUSTON, TEXAS
Houston, Texas 5/6/2015 6:28:00 AM
CHRISTOPHER A. PRINE
Clerk
HUGH LARKIN
Relator
RELATOR’S MOTION TO DELIVER PRIVILEGED DOCUMENTS FOR
IN CAMERA REVIEW
On Petition for Writ of Mandamus
from the Civil County Court at Law #4 of Harris County, Texas
Trial Court Cause No. 1047713
Respectfully Submitted
Famose T. Garner
SBN 24074252
6201 Bonhomme Road, Suite 354N
Houston, Texas 77036
famosegarner@gmail.com
Phone: (832) 722-0881
Fax: (713) 481-0205
ATTORNEY FOR RELATOR
ORAL ARGUMENT REQUESTED
Dated: May 6, 2015
TO THE HONORABLE COURT OF APPEALS:
Relator, Hugh Larkin files this Motion to Deliver Privileged Documents for
in camera Review.
1. On April 27, 2015, Relator filed a petition for writ of mandamus. By
the mandamus petition, Relator challenges the trial court’s order overruling
assertions of privilege to defendant’s discovery requests and its order denying
reconsideration.
2. The Relator provided documents to the trial court for in camera review.
By this motion, the Relator seeks to provide this Court those same documents to
help this Court evaluate the merits of the Relator’s privilege claim.
3. Relator seeks an order from this Court directing him to provide the
privileged documents for review under any mechanism the Court sees fit to
entertain.
PRAYER
THEREFORE, Relator, Hugh Larkin, respectfully requests that this Court
grant this motion and issue an order directing him to provide the privileged
documents to the Court for review. Relator further requests all other relief to
which he may be entitled.
/s/ Famose T. Garner
Famose T. Garner
2
CERTIFICATE OF SERVICE
This will certify that a true and correct copy of this Motion to Deliver
Privileged Documents for in camera Review. has been served on the Respondent and
Real Parties in Interest this May 6, 2015 addressed as follows:
Via E-filing and H and Delivery
The Honorable Roberta Lloyd
County Court at Law #4
Harris County Civil
Courthouse 201 Caroline, 5th
Floor
Houston, Texas 77002
Via E-filing and Email
Richard Weaver
THE WEAVER LAW FIRM
1800 Bering Drive, Suite 305
Houston, Texas 77057
rweaver@weaverlawyers.com
Attorneys for Holly Rodriguez
Shawn Robert McKee
LAMBRIGHT & ASSOCIATES
2603 Augusta, Suite 1100
Houston, Texas 77057
srm@lambrightlaw.com
Attorneys for Riverwalk Council of Co-owners, Inc.
/s/Famose T. Garner
Famose T. Garner
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