RESPONSE

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                          Filed

10 January 19 P12:12
Amalia Rodriguez-Mendoza
District Clerk
Travis District
CAUSE NO. D-1-GN-08-004283
BARBARA ALLEN, § IN THE DISTRICT COURT OF

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Plaintiff, §
§ TRAVIS COUNTY, TEXAS
v. §
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MOSTER & WYNNE, P.C. d/b/a §
MOSTERWYNNE 8 98" JUDICIAL DISTRICT
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Defendant. §

PLAINTIFF’S RESPONSE IN OPPOSITION TO
DEFENDANT’S MOTION TO COMPEL PRODUCTION OF DOCUMENTS

TO THE HONORABLE JUDGE OF SAID COURT:

Plaintiff Barbara Allen (“Allen”) contends that Defendant’s attempt to compel
production of privileged documents from her former attorneys should be denied and in
support would respectfully show as follows:

ARGUMENT

“The attorney-client privilege belongs to the client. Unless the client waives it,
the attorney cannot be compelled to disclose matters that come within that privilege.”
West v. Solito, 563 S.W.2d 240 (Tex. 1978). In the final month of discovery, Defendant
has attempted to subpoena the files from five of Plaintiffs former attorneys in the
underlying divorce. Four at…