Comes now, Lawrence K. Whicree Jr., movant pro se, in the above-sy let numbered cause, ^[3] respectfully files ^[4] whimits this his motion to compel production's of attorney I client file for attorney Layuanda Lacy to produce I deliver the attorney I client file to Lawrence Kelvin Walker Jr. Pro Se Defendant, Lawrence K. Whicree Jr. shows the following in support of an Order to compel production of Attorney I client file.

I Attorney Lo Juanda Lacy was retoined lappointed to represent Lawrence K. Whilker Jr. during the criminal proceedings in this case, which began on January 27, 2014 5 concluded on January 30, 2014, thus ending attorney La Juanda Lacy's representation. Lawrence K. Whalker Jr. has formally reguetted his entire 5 complete attorney I client file on October 23, 2014. See attached Exhibit A. Attorney La Juanda Lacy has failed to respond to request, nor notified Lawrence K. Whalker Jr. for reasons for his inability to fulfill request for entire 1 complete attorney I client file. Pro Se defendant Lawrence K. Whalker Jr. saw attorney Layuanda Lacy December 24, 2014 3 tried to contact attorney Layuanda Lacy for attorney I client file, but the attempt failed. As provided in request, attorney La Juanda Lacy was given sufficient time to respond; notice was given should attorney La Juanda Lacy failed to respond or act.

*2 Relationship of attorney's client is one of principal's agent. Doval County Ratch Co., L. Alamo Lumber Co., 643 S.W. do 627 (Tex. App. Anorillu (1983). Under Tewer Law, large or is agent of his Iber client. Auguston v. Lisea - Recca Nacional - chile Ja, 76 F. so 638 (510 Gr. 1984). It is well established that Lawrence K. Walker S. i. attorney La Grande Lacy had an attorncy's client relationship when attorney was detained (appointed or otherwise See Sampson v. State, 854 swio 659 (Tex. App - Dallas 1982). The papers i. documents which were generated by the attorney in representing the client 50 -longs to the client Kennedy v. Gulf Coast Lancer i. Diagnostic Center at Southwast, loc 328 Sw. 30552 (Tex. App - Houston [1st] 2010); in Re George, 28 sw. 30511 (Tex. 2000). with an client request these papers i. documents from attorney, said attorney has a duty to promptly deliver to client. See: Melon v. Foreman, 665 F. 2d 728 (514 Gr. 1982); Hobson v. State, 615 sw. 2d 864 (Tex. (iv. App - Houston [1st] 1981). As in Defendant Lawrence K. Walker S. has requested the entire 1 complete attorney's client file from attorney La Grande Lacy, who has failed to fulfill the request to promptly deliver. (See ExA). Texas Disciplinary Rules of Professional London provides," a lawyer shall promptly deliver to the client... any funds or other property that the client... is entitled to receive... "Rule 1.14 (b)" Upon termination of representation, a lawyer shall take steps to the extent reasonably possible to protect a client's interest, such as "lazy" succeeding papers i. property to which the client is entitled"... Rule 1.15 (d), see also Burnett v. Steep, 2010 w. 4132211 (Tex. App. - Houston [11th Dist] 2010). While attorney may wish to change client for copy of file before he delivers to client, thus changing client for his/her own property. Under Tewer Law, entire contents of an attorney's client file belonged to client, however, attorney could copy, at his own expense, portions of file the he/she wanted to retain. Resolution Tewer Law v. H... R. 128 F.R. 647 (N.D. Tex. 1984). Thus, a court should not deprive a client of his or her property without compelling reason. Attorney La Grande Lacy has not put forth any reason compelling otherwise, for his fortune to deliver the entire attorney's client file.

*3

Therefore, Iawrence K. W. W. U. U. canard's he has shown that attorney La Janda Lavy has failed in his/her duty under Texas Law to promptly deliver entire attorney lclent file as requested.

Prayer

Whorefore, Premises considered, the moment Lawrence K. W. W. W. U. U. prays this Hauscotte Court finds attorney La Janda Lavy has failed in his ther duties, Dedys attorney La Janda Lavy to promptly deliver the entire 2 complete con- tarnes of attorney lclent file to Lawrence K. W. W. W. W. W. U. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W. W