Lawyers’ Manual on Professional Conduct §31:1211 at 13 (2006) ("Courts and ethics committees have struggled with crafting a bright-line rule as to when withholding client property will imper-missibly prejudice the client's case.”); Arthur Garwin, Trading Files for Fees, 90 ABA J. 24, 24 (Jan.2004) (noting conflicts and observing that "the decisions offer little certainty as to the circumstances under which the client’s right to the papers exceeds the lawyer’s right to use the papers as a vehicle to get paid"); Note, Attorney’s Retaining Lien Over Former Client’s Papers, 65 Colum. L.Rev. 296, 296 (1965) (criticizing lien jurisprudence as exhibiting "the inconsistency of ad hoc judicial decision”). 3 . See, e.g., Resolution Trust Corp. v. H -, P.C., 128 F.R.D. 647, 648-50 (N.D.Tex.1989) (<HOLDING>); Acad. of Cal. Optometrists, Inc. v. Super.
holding trial court erred when it sanctioned client where the evidence showed that the attorney filed frivolous pleadings on behalf of the client but the client did nothing more than rely on her attorneys advice holding that an attorneys filing a notice of appearance on behalf of his or her client constitute a waiver of service of process by the client holding that under texas law the attorneys file belongs to client and must be transferred holding that under texas law the mere representation of a party in a lawsuit does not establish privity between an attorney and his or her client holding that where the entity was incorporated in texas and the shareholders reside in texas and the bankruptcy case is pending in texas texas law  not arizona law  should be applied