In Re Amrock, LLC F/K/A Title Source, Inc. v. the State of Texas

Fourth Court of Appeals
San Antonio, Texas

MEMORANDUM OPINION

No. 04-25-00754-CV

IN RE AMROCK, LLC f/k/a Title Source, Inc.

Original Proceeding 1

PER CURIAM

Sitting: Lori I. Valenzuela, Justice
Adrian A. Spears II, Justice
H. Todd McCray, Justice

Delivered and Filed: March 11, 2026

DENIED

On November 21, 2025, Relator Amrock, LLC, f/k/a Title Source, Inc., filed a petition for

writ of mandamus asking our court to compel the trial court to vacate its order granting certain

discovery in the underlying case. On November 24, 2025, this court granted temporary relief and

stayed the trial court’s November 19, 2025 order pending resolution of this petition. After

consideration, we deny Relator’s petition.

“The party who seeks to limit discovery by asserting a privilege has the burden of proof.”

In re E.I. DuPont de Nemours & Co., 136 S.W.3d 218, 223 (Tex. 2004) (orig. proceeding).

1
This proceeding arises out of Cause No. 2016-CI-06300, styled HOUSECANARY INC. F/K/A CANARY ANALYTICS
VS AMROCK LLC F/K/A TITLE SOURCE INC., pending in the 438th Judicial District Court, Bexar County, Texas,
the Honorable Rosie Alvarado presiding.
04-25-00754-CV

Generally, a trial court conducts an in camera inspection to determine if a document
is in fact privileged. If it is not privileged, then it may become evidence that the
factfinder may consider. If the document is privileged, it is not subject to discovery
and may not be considered by the factfinder, even when the factfinder is the trial
court.

Goode v. Shoukfeh, 943 S.W.2d 441, 448 (Tex.1997). Based on the record provided in these

proceedings, we are unable to determine whether the trial court abused its discretion by ordering

the complained of discovery. Accordingly, this petition for writ of mandamus is denied and our

stay of the trial court’s November 19, 2025 order is lifted.

PER CURIAM

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