Ugalahi Offoboche v. Collin County, Texas, Collin County Sheriff's Deputies Mounger, Watson, and McMillan and Former Collin County Chief Deputy Constable Rumfield

ACCEPTED 15-25-00044-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 5/22/2025 11:00 PM No. 15-25-00044-CV CHRISTOPHER A. PRINE CLERK In The Fifteenth Court of Appeals FILED IN 15th COURT OF APPEALS at Austin, Texas AUSTIN, TEXAS 5/22/2025 11:00:06 PM CHRISTOPHER A. PRINE Clerk UGALAHI OFFOBOCHE, Appellant, V. COLLIN COUNTY, TEXAS, COLLIN COUNTY SHERIFF’S DEPUTIES MOUNGER, WATSON, AND MCMILLAN AND FORMER COLLIN COUNTY DEPUTY CONSTABLE RUMFIELD, Appellees.

On appeal from the 429th Judicial District Court, Collin County, Texas Cause No. 429-08578-2024 The Honorable Jill Willis, Presiding APPELLANT’S UNOPPOSED SECOND MOTION FOR EXTENSION OF TIME TO FILE BRIEF TO THE HONORABLE JUSTICES: Appellant, Ugalahi Offoboche, files this Unopposed Second Motion to request a 30-day extension of time to file her brief on the merits. Appellant shows the court as follows: 1. Appellant’s brief is due on May 23, 2025.

2. This is the Appellant’s second request for extension of time to file a brief in this case.

Page 1 of 4 3. Appellant requests that the court grant her a 30-day extension of time to file her brief up to and including June 23, 2025.

4. Good cause for granting this motion is that on May 8, 2025, counsel, who has a serious chronic condition, had a severe episode that lasted for over ten days.

5. Counsel has Idiopathic Intracranial Hypertension which causes temporary blindness, severe headaches, sensitivity to light and sound and suffers from episodes occasionally.

6. The current episode was so severe that counsel lost ten days of work further delaying counsel’s already backlogged workload and pre-existing time sensitive commitments.

7. Because of the severity of the episode, on May 11, 2025, counsel’s daughter took it upon herself to notify all opposing counsel 1 of the condition because there was no way of knowing when the symptoms would let up.

8. As such, counsel was prevented from making progress on the brief so as to complete the brief by the deadline along with the pending responses to motions to dismiss at the Eastern District of Texas, and other filings due at other courts.

Those who had deadline marked open files on present counsel’s desk. Present counsel found out what her daughter had done only after she began recovering.

Page 2 of 4 9. Once counsel began recovering on May 19, 2025, Counsel tried but is unable to meet her other legal obligations and make sufficient progress to complete the brief by May 23, 2025, as scheduled and must seek this extension.

10.Appellees, who are aware of the situation, are not opposed and will not suffer any prejudice from the deadline being extended by 30 days up to and including June 23, 2025.

11. This motion is filed, not for delay, but in the interest of justice so that the Court may hear this case on the merits.

12.All supporting facts are made from the personal knowledge of appellant, who is an attorney, and are true and correct.

For the above reasons, appellant humbly requests that this Motion be granted extending the time for appellant to file appellant’s brief by 30 days, from May 23, 2025, up to and including June 23, 2025.

Dated this 22nd day of May 2025.

Respectfully Submitted: U. A. C. OFFOBOCHE LAW FIRM /s/ Ugalahi Agbo Claire Offoboche Ugalahi Agbo Claire Offoboche State Bar No. 24068619 Town Square Blvd., Bldg. 1A, Ste. 200, Garland, TX 75040 Ph: 469-315-0358 Page 3 of 4 Fax: 214-853-5708 [email protected] APPELLANT: UGALAHI OFFOBOCHE CERTIFICATE OF CONFERENCE Pursuant to Tex. R. App. Proc. 10.1(a)(5), I, the undersigned attorney, hereby certifies, that I conferred with both opposing counsel, Robert Davis and Kyle Barry regarding the need to file this motion and counsel for appellees, Robert Davis has indicated that the Motion is unopposed.

/s/ Ugalahi Agbo Claire Offoboche Ugalahi Agbo Claire Offoboche

CERTIFICATE OF SERVICE I, the undersigned counsel certifies that the above and foregoing has been simultaneously served upon e-filing via efile.texascourts.gov, on appellees through their Attorneys of record: Robert Davis, Kyle Barry, Matthews, Shields, Knott, Eden, Davis & Beanland, L.L.P., 8131 LBJ Freeway, Ste. 700, Dallas, Texas 75251 [email protected] [email protected] ATTORNEYS FOR APPELLEES /s/ Ugalahi Agbo Claire Offoboche Ugalahi Agbo Claire Offoboche

Page 4 of 4 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.

Ugalahi Offoboche Bar No. 24068619 [email protected] Envelope ID: 101189138 Filing Code Description: Motion Filing Description: Appellant's Unopposed Second Motion for Extension of Time to File Brief Status as of 5/23/2025 7:07 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Ugalahi UgyOffoboche [email protected] 5/22/2025 11:00:06 PM SENT Robert J.Davis [email protected] 5/22/2025 11:00:06 PM SENT Kyle T.Barry [email protected] 5/22/2025 11:00:06 PM SENT Kyle T.Barry [email protected] 5/22/2025 11:00:06 PM SENT