Let's say I hire you to prepare my tax return. You do so and tell me, "That will be $200." I say, "Nonsense, I'm not paying. Now give me my entire file." Do you truly believe you have to hand over the return you prepared, at no cost? Of course not. That would be work product, and as you admit there is no obligation to turn over that type of work product (or certain other records) when your client doesn't pay you.

