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ATTORNEY WORK PRODUCT VERSUS GRAND JURY SUBPOENA

Mar 05 2012
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Protecting Attorney Client Relationship, Privileged Information from Government Subpoena
By: Houston Criminal Lawyer John Floyd and Paralegal Billy Sinclair

The attorney work-product and the attorney-client privilege are often confused with each other. Although related, insofar as they both concern the attorney client relationship, they are distinct privileges protecting different types of information for completely different rationales. The attorney client privilege protects all information disclosed to a lawyer for purposes of receiving legal advice, allowing unfettered communication between lawyer and client. The “work product” privilege protects the fruits of a lawyer’s efforts and prevents unnecessary intrusion into the lawyer’s thought processes, allowing the lawyer to freely investigate and assemble information.

“Work Product” was discussed in 1947 by the U.S. Supreme Court inHickman v. Taylorwhen it acknowledged the necessity of protecting a lawyer’s thoughts from unnecessary intrusion by opposing counsel. This privacy was thought necessary to allow a lawyer the ability to properly represent the client and adequately prepare for the case by freely assembling information, sifting through relevant and irrelevant facts, preparing legal theories and planning a strategy without undue and needless interference. Otherwise, the court said, an attorney’s thoughts would no longer be his own and forced disclosure of these thoughts would demoralize the profession and be injurious to the cause of justice.

In 1995 the Texas Supreme Court inOccidental Chemical Corp. v. Banalesdescribed “work product” as protecting two types of information: “First, the privilege protects the attorney’s thought process, which includes strategy decisions and issue formulation, and notes or writings evincing those mental processes. Second, the privilege protects the mechanical compilation of information to the extent such compilation reveals the attorney’s thought processes.”

Rule 192.5(a) of the Texas Rules of Civil Procedure subsequently defined what “work product” comprises:

(1) material prepared or mental impressions developed in anticipation of litigation or for trial by or for a party or a party’s representative, including the party’s attorney, consultants, sureties, indemnitors, insurers, employees, or agents; or

(2) a communication made in anticipation of litigation or for trial between a party and the party’s representatives or among a party’s representatives, including the party’s attorneys, consultants, sureties, indemnitors, insurers, employees, or agents.

Five years afterBanalesthe Texas Supreme Court inIn re Georgeclarified work product as any material “created in anticipation of trial that has not been placed in the public record or shared with the other side.”

A case before the Ninth Circuit Court of Appeals in 2010, inIn re Grand Jury Subpoenas, stirred significant controversy related to work product materials subpoenaed for a grand jury criminal investigation. In that case, the Government was conducting an antitrust investigation into criminal conduct by the clients of a number of law firms. In separate civil proceedings, the law firms had obtained non-privileged material through the discovery process; namely, documents originating outside the United States. The Government then demanded these documents pursuant to their criminal-related subpoena power authorized by Rule 17 of the Federal Rules of Criminal Procedure.

The law firms filed a motion to quash the subpoenas. The district court admitted that it could find no authority supporting the motion. Thus, the court concluded that “because the motions to quash raise novel issues with potentially far-reaching implications about the power of the grand jury and the relationship between grand jury proceedings and civil discovery of unindicted foreign defendants,” it found that it was “more prudent to quash the subpoenas and allow the [Government] to raise these issues on appeal to the Ninth Circuit.”

The Ninth Circuit was not sympathetic to the Law Firms, finding:

On appeal, the Law Firms argue that the district court exercised its discretion under Fed. R. Crim. P. 17 to quash the subpoenas and that the court of appeals should respect its reasonable exercise of discretion. We do not read the district court’s decision as an exercise of discretion but as a passing of the decision to this court. We are not reviewing an exercise of discretion but a request for guidance.

No collusion between the civil suitors and the government has been established or even suggested by the Law Firms. Indeed, the district court determined that the government had not engaged in any bad faith tactics. Moreover, the Law Firms do not claim that the documents are privileged. Accordingly, we apply our per se rule that a grand jury subpoena takes precedence over a civil protective order. By a chance of litigation, the documents have been moved from outside the grasp of the grand jury to within its grasp. No authority forbids the government from closing its grip on what lies within the jurisdiction of the grand jury.

The Law Firms sought certiorari review before the U.S. Supreme Court. They were supported throughamicus curiaebriefs by the following organizations and groups: the American Bar Association (ABA), the National Association of Criminal Defense Lawyers, the Washington Legal Foundation (WLF), and the U.S. Chamber of Commerce and DRI, jointly. Each of these interested parties argued against aper seenforcement of grand jury subpoenas directed to attorneys for client information. The ABA brief put it this way:

The Ninth Circuit has adopted a per se rule that grand jury subpoenas always take precedence over civil protective orders, even where a prosecutor uses a grand jury’s broad investigative subpoena power to compel a lawyer to produce client information. That ruling directly implicates an existing conflict among the circuit courts on an issue of great importance to the legal profession. The question presented moreover has significant potential to affect the trust and confidence that are the essential foundations of the attorney-client relationship.

The ABA has adopted policies against per se enforcement of subpoenas because of their potential to undermine the attorney-client relationship. Beyond information protected by the attorney-client privilege, a lawyer is obligated in the attorney-client relationship to maintain a client’s confidences except as directed by the client in the course of the representation. This per se approach overrides this element of confidence by compelling the lawyer served with a subpoena to act contrary to the interests of the client without an inquiry as to whether the government has other means for obtaining the information. Thus, clients under grand jury investigation may hold back important information from their lawyers out of fear that their counsel will be compelled to produce to the government information that was disclosed to the lawyer through the attorney-client relationship.

Much of the “work product” material by an attorney is derived, directly or indirectly, from the confidences of the client. Theper seenforcement forces an attorney whose client is under continuing investigation to make hard choices about what (non-privileged) material to compile and maintain, knowing it is subject to grand jury subpoena if is actually compiled and maintained. As the COC/DRI brief pointed out: “ … theper serule adopted by the Ninth Circuit’s decision places defendant in an ‘untenable position’ of choosing between the adverse risk of consequences in civil litigation and the risk of self-incrimination in a parallel criminal investigation.”

A primary distinction between the “work product” privilege and the attorney-client privilege lies in the “confidentiality” needed in the attorney-client relationship to the client’s interests in a criminal (or civil) proceeding while the “work product” privilege is designed almost exclusively to protect material from disclosure to opposing parties in litigation. Disclosure of confidences in the attorney-client privilege automatically waives that privilege while disclosure of non-privileged material does not automatically waive the work product privilege. Significantly, however, misconduct, more often referred to the crime-fraud exception, by either the attorney or client may waiveeitherprivilege if there isprima facieevidence of misconduct byeitherof them.

Hickmanconfined itself to the disclosure of non-privileged documents, including the non-privileged portions of an otherwise protected document. TheHickmancourt placed work product materials into two categories: fact work product and opinion work product. Fact work product is material assembled by the attorney that does not include his/her mental processes, conclusions, opinions or legal theories. The Fifth Circuit inIn re Thompsonheld that the fact work product protection is qualified and, therefore, can be overcome by a showing of need and hardship.

It is easy to discern why absolute attorney-client privilege and the qualified work product privilege have produced significant legal head-butting. The Sixth Circuit in 1986 inIn re Antitrust Grand Juryexcellently detailed this history (absent the decision’s internal citations):

The policies underlying the attorney-client privilege and the attorney work product doctrine are well documented in the annals of legal history.The purpose of the attorney-client privilege is to encourage clients to communicate freely and completely with their attorney. The privilege also serves the purpose of promoting “broader public interests in the observance of law and administration of justice.” However, it is not an absolute privilege. It applies only where necessary to achieve its purpose and protects only those communications necessary to obtain legal advice. Under some circumstances the privilege is to be very narrowly construed. All reasons for the attorney-client privilege are completely eviscerated when a client consults an attorney not for advice on past misconduct, but for legal assistance in carrying out a contemplated or ongoing crime or fraud.

There may be some overlap, but the work product doctrine “is distinct from and broader than the attorney-client privilege.” Where only confidential communications are protected by the attorney-client privilege, the work product doctrine protects any document prepared in anticipation of litigation by or for the attorney. Moreover, only the client may assert the attorney-client privilege while both the attorney and the client may invoke the work product doctrine.

The premier case shaping the contours of the work product doctrine is Hickman v. Taylor. The Supreme Court in Hickman observed the dangers inherent in permitting unwarranted disclosure of an attorney’s work product materials and limited the scope of the discovery of those materials.

Historically, a lawyer is an officer of the court and is bound to work for the advancement of justice while faithfully protecting the rightful interests of his clients. In performing his various duties, however, it is essential that a lawyer work with a certain degree of privacy, free from unnecessary intrusion by opposing parties and their counsel. Proper preparation of a client’s case demands that he assemble information, sift what he considers to be the relevant from the irrelevant facts, prepare his legal theories and plan his strategy without undue and needless interference. That is the historical and the necessary way in which lawyers act within the framework ofour system of jurisprudence to promote justice and to protect their clients’ interests. This work is reflected, of course, in interviews, statements, memoranda, correspondence, briefs, mental impressions, personal beliefs, and countless other tangible and intangible ways — aptly though roughly termed by the Circuit Court of Appeals in this case as the “work product of the lawyer.”

Were such materials open to opposing counsel on mere demand, much of what is now put down in writing would remain unwritten. An attorney’s thoughts, heretofore, inviolate, would not be his own. Inefficiency, unfairness and sharp practices would inevitably develop in the giving of legal advice and in the preparation of cases for trial. The effect on the legal profession would be demoralizing. And the interests of the clients and the cause of justice would be poorly served.

We do not mean to say that all written materials obtained or prepared by an adversary’s counsel with an eye toward litigation are necessarily free from discovery in all cases.Where relevant and non-privileged facts remain hidden in an attorney’s file and where production of those facts is essential to the preparation of one’s case, discovery may properly be had.

Some courts interpreting Hickman have defined two types of work product.Ordinary fact or “unprivileged fact” work product, as referred to in Hickman, is written or oral information transmitted to the attorney and recorded as conveyed by the client. The presumption in favor of nondisclosure is shifted with respect to fact work product. When there has been an ongoing client crime or fraud, any privilege to fact work product is waived and the “scale tips in favor of disclosure.”

Opinion work product is any material reflecting the attorney’s mental impressions, opinions, conclusions, judgments or legal theories. The Court in Hickman observed that “not even the most liberal of discovery theories can justify unwarranted inquiries into the files and the mental impressions of an attorney.” One court has interpreted Hickman as giving opinion work product nearly absolute immunity. But even this privilege can be waived by a client when the attorney was consulted in furtherance of a crime or fraud.

However, since this privilege is jointly shared, an unknowing attorney may successfully assert the privilege even in the face of a client’s fraud or crime. Indeed, there may be rare occasions when the attorney knowingly participates in a guilty client’s ongoing fraud or crime. In those rare instances, none of the public policies advanced in support of the privilege would be served if an attorney who committed a crime or fraud could shield himself from prosecution or litigation because he asserted the work product doctrine. Therefore, to speak of the work product doctrine as an absolute privilege enjoyed by either the attorney or the client is wrong.

Essentially,the overriding purpose of both the attorney-client and the work product privileges is to encourage the proper functioning of the adversary system. Often, however, these privileges come into conflict with other societal interests when they are invoked during a grand jury investigation.

Invocation of [either] privilege before the grand jury could jeopardize an effective and comprehensive investigation into alleged violations of the law, and thereby thwart that body’s dual functions of determining “if there is probable cause to believe that a crime has been committed and of protectingcitizens against unfounded criminal prosecutions.”

Recognizing this inherent tension between the two interests, the courts have applied an exception when the otherwise protected communications or materials are made in furtherance of a crime or fraud. As it has been so designated, the crime-fraud exception has been applied in a number of cases where the attorney-client privilege has been invoked during the grand jury investigation. The exception has also been applied in cases involving a privilege asserted under the work product doctrine.

The government sought to compel the production of a number of documents listed in Exhibit C.In analyzing whether the documents requested by the government were within the crime-fraud exception to the attorney-client privilege or attorney work product doctrine, the district court utilized a test formulated and applied by a number of other circuits. First, the government must make a prima facie showing that a sufficiently serious crime or fraud occurred to defeat the privilege; second, the government must establish some relationship between the communication at issue and the prima facie violation.

The court relied on the “evidence presented in Exhibit B as supplemented by the facts of a related case,” in concluding that a prima facie antitrust violation had occurred. It described the burden satisfied by the Government to support the prima facie violation as that which would “permit a court to deny an initial motion for a directed verdict if such proof were submitted at trial.” The court further reasoned that since the government had established a prima facie case that the transaction violated the Sherman Act, all legal assistance provided by the law firms was in furtherance of that violation. It then ordered the appellants to produce every document requested by the Government in Exhibit C that was withheld as privileged attorney-client material. It also ordered the appellants to produce all documents withheld that constituted fact work product. All opinion work product was found to be protected by the doctrine.

The court retained the power to conduct an in camera examination of that document in the event that any of the parties disputed the characterization of any document.

We agree with the ABA and the other groups arguing againstper sedisclosure of material sought by the Government in grand jury investigations. The grand jury is a powerful investigative tool frequently used by the Government to create a crime when none exists. A source of controversy throughout its existence, we do not like the secret inquisition nature of grand juries. The enforcement of aper sedisclosure rule, as advanced by the Ninth Circuit, forces an attorney, especially one representing a client under continuing criminal investigation, to caution the client about disclosing too much confidential information—and this caution has a chilling effect on the very nature of the attorney-client relationship; and, in many ways, can impact the quality of the representation to the client.

By: Houston Criminal Attorney John Floyd and Paralegal Billy Sinclair
John Floyd is Board Certified in Criminal Law by the Texas Board of Legal Specialization

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    Excellent service and a lawyer that doesn't lie. He does what he says. JW recommends him.
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    One of the best services Ive used in awhile. Thank you for all the help and answers. You got my life back. Thank youPositive
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    It was a pleasure speaking with John. He is knowledgeable and has a true desire to help the people of society. I turned to him for some guidance of a long-standing issue. He never … More rushed our conversation and went out of his way to look into the details to provide the right answer as well as assist me anyway he could. Thank you for our conversations and I wish your and your firm the best. If you need a lawyer, John Floyd is your guy!
  • Avatar Andrew Vo ★★★★★ 3 years ago
    John represented me in court for roughly 2 years. I won't (and shouldn't) get into any serious details, but let me tell you that I couldn't have chosen anyone better. … More Seriously.Every appearance in court I felt very comfortable. The judge and DA's had a high regard for his reputation. There is a time I recall where simply his presence greatly impacted the court's interpretation of my case and persons. We were in front of the stand and the judge could not stop talking about John's prestige and past accomplishments and how that took in relation to my case. I kept silent in front of the judge, but I observed then that John's popularity and reputation within the court had already given me a better looking rapport with the judge. Let me tell you, I never had more confidence then, knowing that the judge held him in such high regard.This is not to mention how personable John is. I'll be honest that during the stress of court, sharing a laugh with your lawyer helps a lot. This may sound a lot, but I really appreciated the relationship we had then. This is also not to mention that he was able to deal very well with any DA that rotated over the years. Seriously, John was great, prompt with information and very hands on with my case. I had great peace those 2 years until everything wrapped up.If you're looking for a lawyer, I highly, HIGHLY recommend the John T. Floyd Law Firm. He IS nationally renowned, you know. He'll get the job done to the utmost confidence. He's very experienced and has a great record to boot. I am glad to have had him represent me in court and trust me that I never thought I'd ever say that (and whoever does?). We explored every avenue of victory together and I personally enjoyed the experience, despite the seriousness of the accusation.If you have a case that needs to be represented at the highest levels, choose John T. Floyd. He's a good man and very good at what he does. Him and his team has the experience you need to make the best decisions and options to get the best outcome for your case. We got the best result I could possibly ask for, thank God.Seriously. Hire John. He knows what he's doing.Seriously.
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    One of the few honest lawyers I have ever talked to. His complimentary consultation was knowledgeable and thorough. He knew exactly what the issue was and how to handle it. His candid … More appraisal of the situation and how to proceed saved me thousands of dollars in legal fees. If you have a case requiring expertise in John's area of practice, look no further. Hire this man!
  • Avatar Larry Green ★★★★★ 3 years ago
    I had the opportunity to read an article that Mr. Floyd wrote and it was very interesting. I called him about the article and advice concerning a similar situation. He not only gave … More me excellent advice, he pointed out not just what I wanted to hear but what I needed to hear concerning my situation. The Good, The Bad and The ugly in a manner or speaking. He spoke with an open and honest heart with information to help me and not just to get a client.
  • Avatar Jackie Cohen ★★★★★ 3 years ago
    If you are in trouble and need a lawyer, contact the John T. Floyd law firm. Some of the best lawyers in Texas work there! Understanding and helpful lawyers and staff that will do all … More they can to help you 😊
  • Avatar It’s Me ★★★★★ 3 years ago
    He gave me one of the most honest answers I have received in a very long time about any issue I was having with anything. Legal or not legal. I highly recommend giving him a call and … More will be referring him to friends and family if they have any issues in the future.Positive
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  • Avatar I’m Home ★★★★★ 3 years ago
    He took time out of his day to answer my legal questions and didn’t even charge me. I would definitely recommend him to you.
  • Avatar Tad Nieschwietz ★★★★★ 3 years ago
    Gave free consultation on getting gun rights back. He truly cares about gun rights and getting you the help you deserve. 100% worth a callPositive
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  • Avatar Maher Abbara ★★★★★ 3 years ago
    Very professional, great quality work, and very friendly and helpful. Overall, their service is phenomenal. I recommend Mr. Floyd to anyone.
  • Avatar Thomas McLaughlin ★★★★★ 3 years ago
    Mr. Floyd took the time to explain his experience with the law to me in layman's terms. Definitely give him a call.Positive
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  • Avatar Zarrie Adkins ★★★★★ 3 years ago
    He was honest , knowledgeable , and professional about what we talked about. Most lawyers are just about the money , but not john.Positive
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  • Avatar Keisha Gaches ★★★★★ 3 years ago
    He was very truthful and honest with us very great man I would recommend him and we would use him again
  • Avatar Samyra Carrasquillo ★★★★★ 3 years ago
    Very professional honest and works hard currently working my husband’s appeal I pray he does his best workPositive
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  • Avatar Raul Perez ★★★★★ 3 years ago
    I contacted John T. Floyd Law firm and I was very satisfied with service extremely helpful and friendly thank you Mr. FloydPositive
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  • Avatar Johnny Johnson Jr ★★★★★ 3 years ago
    This law frim was informative,great response time ,and the attorney called back not some secretary or legal assistant thank u guys for all your help wish it was more like youPositive … More
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  • Avatar Dana Adkison ★★★★★ 3 years ago
    I would highly recommend Mr Floyd. He was very helpful and knowledge with a legal question I had.Positive
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  • Avatar Crecencio Fabian ★★★★★ 3 years ago
    He explained my case better then any other lawyerPositive
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  • Avatar Barry Lewis ★★★★ 3 years ago
    Very informative
  • Avatar Ismael Flores ★★★★★ 3 years ago
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  • Avatar Neil Productions ★★★★★ 4 years ago
    Had the pleasure speaking with John Floyd on a personal matter, he was very responsive, nothing but exceptional, and he really cares about you with sincerity and most importantly knows … More what is he talking about! No games or bs, his approach to my situation even though I knew it was probably way smaller then what he normally takes on, he was extremely helpful and didn't care about the size of the matter like other attorneys do. He really looked out for my best interests. You can tell he has decades of experience doing what he does just by chatting with him. I would highly recommend him.
  • Avatar S A ★★★★★ 4 years ago
    Words can’t describe how grateful I am for working with John, he went above and beyond my expectation. I was wrongly accused and hired many lawyers before hiring John Floyd but they … More all disappointed me, I had lost hope until a friend of mine referred me to John. From the start he had my best interest in mind and gave helpful advice, he explained the process and guided me. He put more work and time than all my previous lawyers that cost me thousands of dollars. He was constantly communicating with court and defended me more than all lawyer i had hired before him. Don’t waste your time and money like I did, believe me when I say I hired countless lawyers before him and no one came close to John. I’m forever thankful for him for fighting for my innocence and getting my case dismissed. Thank you so much🙏🏼🙏🏼
  • Avatar Gary Watch ★★★★★ 4 years ago
    I called Mr Floyd and left a message, with in the hour I received a call back with much more information then I could have ever expected. Mr Floyd was very informative on every question … More I had for him. He seemed like he cared, instead of like most attorneys that you talk to that are just out for a quick buck. If you want someone that is going to shoot strait with you, and has your best interest in hand, this is you guy. This was the best experience that I have ever had with an lawyer.
  • Avatar Saman Daftarian ★★★★★ 4 years ago
    I can state with confidence that Mr. Floyd and his team are the most competent and professional lawyers one can hope for. My case was quite complex and I admit that as a law student … More I was not the most patient client. Mr. Floyd did a phenomenal job of managing the bench, prosecution and myself! The result was above expectation, and I will never hesitate to recommend this firm regardless of the caliber of the case at issue.
  • Avatar calvin robinson ★★★★★ 4 years ago
    It was a pleasure working with Mr. Floyd. I contacted him regarding a legal matter and he was extremely knowledgeable about the law, and responded in a timely manner. I appreciated … More the fact I did not feel rushed, and he made sure he thoroughly answered all questions I had. I would highly recommend him!Positive
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  • Avatar Alan Howk ★★★★★ 4 years ago
    Spoke with John Floyd about a 45 year old criminal case I was involved in. I had very little information about the case and John helped me search what records were available and gave … More me guidance to find more information. He was very professional and took his time helping me. I may need to hire a lawyer on this case and Mr. Floyd will be the man.Thanks John.
  • Avatar CMCustom Cycles ★★★★★ 4 years ago
    Very professional and straight forward. He's not going to waste your time or money. Very knowledgeable in a large range of possible matters one could face living in these days … More and times. If ever you need legal assistance, this is who I would suggest. Awesome!Positive
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  • Avatar Greg Page ★★★★★ 4 years ago
    I called about some legal questions I needed to get clarified and John was able to give me clarification and sound advice. I will definitely contact John for all future legal questions … More and issues.Thank you John!Positive
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  • Avatar Kristen Rankin ★★★★★ 4 years ago
    Knows his stuff and well respected with DA and judges. I have referred him a couple times and every client has been satisfied
  • Avatar Kedar Puranik ★★★★★ 4 years ago
    John is beyond knowledgeable! If I decide to pursue my case any further I would only have him represent me.
  • Avatar Joseph Sivadon ★★★★★ 4 years ago
    What a great attorney, this guy really took time out of his day to answer my questions and explain my case to me. Very grateful, thank you so muchPositive
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  • Avatar Lex Strider ★★★★★ 4 years ago
    Absolutely a very professional lawyer. Very well read in the current law and more than willing to help if needed.
  • Avatar karim khalifa ★★★★★ 4 years ago
    Mr. John he’s a professional he knows what he’s doing and he’s patient they recommend Him stronglyPositive
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  • Avatar James Haggard ★★★★★ 4 years ago
    Great service, very knowledgable and happy to help with any questions I had
  • Avatar David Sustaita ★★★★★ 4 years ago
    Quick to action and helpful and knowledgeable with entertainment industry based issues!
  • Avatar Chad Groves ★★★★★ 4 years ago
    Responded on a holiday week. Very knowledgeable and reassuring.
  • Avatar Mark Fein ★★★★★ 4 years ago
    Very professional
  • Avatar Bthomason903 Bthomason903 ★★★★★ 4 years ago
  • Avatar Anton Jasser ★★★★★ 4 years ago
  • Avatar Alma Garza ★★★★★ 4 years ago
  • Avatar Victory 2020 ★★★★★ 6 years ago
    I want to thank John T. Floyd and all of his team. He is the best lawyer who cares aboutHis clients and fights really hard to get the best outcome. He is a fighter and he is awesome!!!I … More recommend if any one needs criminal defense , he is the BEST. We had a really serious caseAnd we are very thankful for the outcome. Thank you John!!!!! God bless you!!!!!!
  • Avatar Alma Garcia Cunningham ★★★★★ 6 years ago
    The attorneys at John T. Floyd Law Firm work diligently to achieve the best possible results for their clients. They are caring and knowledgeable professionals. Their expertise in the … More law and their experience as trial attorneys makes them the right choice as a defense attorney. I recommend this law firm highly.
  • Avatar Rajiv Patel ★★★★★ 6 years ago
    From beginning to end this firm handled my case like the top tier professionals they are. I would not trust ANYONE else with my legal needs after having less than stellar experiences … More with other teams. Thank you Floyd!!!
  • Avatar Jose Tapia ★★★★★ 6 years ago
    I really felt like the team cared about my case and am super satisfied with the outcome. Would not recommend anyone else!
  • Avatar Sagar Patel ★★★★★ 6 years ago
    These guys do amazing work and have phenomenal service! Hands down best in the Houston area!!
  • Avatar RAYNINN ★★★★★ 6 years ago
    John and Chris are true professionals! Love those guys like family!
  • Avatar Virginia Martin ★★★★★ 6 years ago
    Mr. Floyd and his team are very knowledgeable, informative, and helpful.
  • Avatar Darla Latham ★★★★★ 6 years ago
    A team you can depend on to stand up and fight for you to prove the truth the whole truth!
  • Avatar Veronica Elorza ★★★★★ 6 years ago
  • Avatar Karetta Lux ★★★★★ 7 years ago
    Mr. John T. Floyd represented me.I couldn't be happier with the outcome he managed to achieve on an VERY Important case that was dismissed the day of Trial. He is patient & … More very knowledgeable of the legal system. I HIGHLY recommend him to anyone in need of a lawyer!John, I am forever grateful & satisfied with the effort you put forth & all you did for me. Thank you isn't enough!God bless you & your family!
  • Avatar GM ★★★★★ 8 years ago
    The John T. Floyd Law Firm assisted me, and I can tell you that the attorney took the time to answer my questions, and I didn't feel rushed or dismissed as I have experienced in … More the past with attorneys. The attorney was very nice and extremely knowledgeable. Initial impressions and continued excellent customer service are big factors for me and as such I would highly recommend this firm.
  • Avatar Sandra Bivens ★★★★★ 8 years ago
    I thank you for your efforts to help Felons regain their Civil rights, and for the information on possession , I am A convicted Felon, no violent history. I am an expert shot, I am … More 76 yoa, and very concerned about the present lake of Security in our State and Country. God Bless and Prosper you in your efforts, Your friend, Sonny Bivens
  • Avatar Mike Kittelson ★★★★★ 8 years ago
    I really appreciated both Chris and John helping with my legal questions and concerns. Both are good guys and I would not hesitate to recommend them.
  • Avatar Robert Hair ★★★★★ 8 years ago
    Extremely helpful!!! Helping me understand the law.

John T. Floyd is Board Certified in Criminal Law By the Texas Board of Legal Specialization

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