Rich Robins v. State Bar of Texas, Commission for Lawyer Discipline, and Chief Disciplinary Counsel

ACCEPTED 15-25-00144-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 10/20/2025 11:57 PM CHRISTOPHER A. PRINE CLERK No. 15-25-00144-CV FILED IN 15th COURT OF APPEALS IN THE AUSTIN, TEXAS 10/20/2025 11:57:18 PM 15th COURT OF APPEALS CHRISTOPHER A. PRINE Clerk

at Austin, Texas

–––––––––––––––––––––––––––––––––––– Rich Robins, Appellant, v. State Bar of Texas, et al Appellees. ––––––––––––––––––––––––––––––––––––

Appealed from the 189th District Court of Harris County, Texas as directed by Judge Tamika Craft ___________________________________________________________

APPELLANT’S 1st MOTION FOR AN EXTENSION ___________________________________________________________

Rich Robins 2450 Louisiana St. #400-155 Houston, TX 77006-2380 Rich@RichRobins.com Tel. 713-574-6279

PRO SE APPELLANT

___________________________________________________________

APPELLANT’S 1st MOTION FOR AN EXTENSION ___________________________________________________________

October 20th, 2025

Appellant Richard Robins hereby files this 1st motion for a deadline extension to file the opening brief.

A. Introduction

1. The Appellee (Plaintiff at the trial court level) is the State Bar of Texas & Commission for Lawyer Discipline (hereinafter the “State Bar”). Attorney Michael Graham is their appellate counsel.

2. The pro se Appellant (Defendant at the trial court level) is Rich Robins (hereinafter “Appellant Robins”).

3. Pro se appellant Robins hereby files this first motion for an extension.

B. Facts

4. Appellant Robins has worked earnestly to try to understand the 15th Court of Appeals’ reported position that it lacks jurisdiction for matters against the State Bar of Texas even in the wake of relatively recent jurisprudence.

5. Appellant Robins would prefer to know which appellate court will be the audience for his upcoming brief before he finishes drafting it

accordingly and submits it. The identity of the destined appellate court is not yet clear, though. Appellant Robins hopes that either the 15 th Court of Appeals will decide to keep this appeal or to involve the Supreme Court of Texas so that that Court can rightly affirm this appeal’s destination in the 15th Court of Appeals.

6. The appellant’s brief was originally due on September 29th, 2025 with the 15 day post-deadline extension date being October 14th, 2025. By that date, however, the 15th Court of Appeals issued a deadline of until October 20th, 2025 to, among other options, file a motion for an extension. Appellant Robins seeks a sua sponte stay from the Court while it decides what it will do regarding its (surprising) decision not to grant this case jurisdiction. That is what the Court did in Baumgardner v. Brazos River Auth., No. 15-24-00070-CV, 2025 WL 4771427 (Tex. App.—Austin June 27, 2025, no pet. h.). In the alternative, Appellant Robins seeks an extension of until November 20th, 2025.

C. Argument & Authorities

7. The Court of Appeals has the authority to postpone the relevant filing deadline pursuant to TRAP 10.5 (b) & 38.6(d).

8. This first request for an extension to file the appellate brief is sought not to cause undue delay but rather to be able to improve the brief, for the benefit of all who decide to read it.

9. Appellant Robins also mentions that considerable caselaw exists to entitle appellants to extensions under at least some circumstances. Such caselaw includes Jones v. City of Houston, authored by (then) Justice Nathan Hecht. Jones v. City of Houston, 976 S.W.2d 676, 677 (1998).

Permissible if not obligatory circumstances for an extension can include (but are not limited to) brief-filing, especially when the opposing side is not unfairly prejudiced by the extension request’s granting. Head v. Twelfth Ct. of Appeals, 811 S.W. 2d 570, 571 (Tex. 1991). Meanwhile Appellant Robins has always swiftly approved of any extension request made by the Appellee (as former counsel Matt Greer can confirm). All of this makes the motion’s respectfully requested granting seem within the realm of lawful permissibility, please.

D. Conclusion

10. Pro se appellant Rich Robins hereby files this first motion for an extension. He invites the Court to issue a stay, sua sponte, like it did in Baumgardner v. Brazos River Auth., No. 15-24-00070-CV, 2025 WL 4771427 (Tex. App.—Austin June 27, 2025, no pet. h.) while striving for a final decision as to jurisdiction. In the alternative, an extension of until November 20th, 2025 is requested, please.

Sincerely submitted:

Rich Robins Pro se appellant 2450 Louisiana St. #400-155 Houston, TX 77006-2380 Rich@RichRobins.com Tel. 713-574-6279

No. 15-25-00144-CV

CERTIFICATE OF SERVICE

I do hereby certify that a true and correct copy of the above and foregoing Appellant’s 1st motion for an extension will be served upon the Appellee by court-authorized electronic means pursuant to Texas Rule of Appellate Procedure 9.5 and also Rules 21 & 21a) of the Texas Rules of Civil Procedure on October 20th, 2025.

Michael G. Graham Appellate Counsel for the Appellee, the Commission for Lawyer Discipline State Bar of Texas, Box 12487 Austin, Texas 78711. Tel. 512-427-1356 Michael.Graham@texasbar.com

BY: Rich Robins

No. 15-25-00144-CV

CERTIFICATE OF CONFERENCE

Appellant Robins e-mailed Appellee’s counsel Michael Graham about a 1 st deadline extension request on October 14th, 2025. Appellant Robins received no opposition from opposing counsel, who did not respond. Perhaps that is because Appellant Robins mentioned in that e-mailed conferencing that there seems to be a customary automatic granting of the first extension request in appellate courts here in Texas. At any rate, the motion is unopposed.

Sincerely submitted:

Rich Robins 2450 Louisiana St. #400-155 Houston, TX 77006-2380 Rich@RichRobins.com 713-574-6279 ____________________

Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Rich Robins on behalf of Rich Robins Bar No. 00789589 rich@RichRobins.com Envelope ID: 107074950 Filing Code Description: Motion Filing Description: Appellant's 1st motion for an extension or a stay, sua sponte Status as of 10/21/2025 7:11 AM CST

Case Contacts Name BarNumber Email TimestampSubmitted Status Michael Graham 24113581 Michael.Graham@TEXASBAR.COM 10/20/2025 11:57:18 PM SENT