in Re Hugh Larkin

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 3