in Re Hugh Larkin

Opinion

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