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 9/10/2025 10:07 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 9/10/2025 10:07:26 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 MOTION FOR FIVE DAYS’ EXTENSION OF TIME TO COMPLETE AND FILE REPLY BRIEF AND FOR LEAVE TO FILE CORRECTED BRIEF TO THE HONORABLE JUSTICES: Appellant, Ugalahi Offoboche, files this Motion to request five days extension of time to file her reply brief and for leave to file attached corrected brief with 123 excess words. Appellant shows the court as follows: 1. Appellant’s reply is due on September 10, 2025.

2. This is the appellant’s first request for extension of time to file the reply brief and first post-filing request to correct appellant’s Amended Opening Brief.

Motion-5-Days’ Extension-file-Reply and for Leave-File-Corrected Opening brief Page 1 of 6 3. Appellant requests that the court grant her a 5-day extension of time to file her reply up to, and including September 15, 2025, and grant leave to file a corrected Appellant’s brief.

4. Good cause for granting this motion is that: a. Appellant is currently working on three urgent immigration filings which are all due tomorrow and one of those cases involves a child.

b. Appellant was in the process of completing time sensitive guardianship and heirship filings for three children as an attorney ad litem appointed by a statutory probate court in Dallas, when the response brief was filed, and was unable to start working on the reply until September 4, 2025, resulting in the inability to complete the reply in a timely manner. Even now, the parties are in discussions regarding whether a contested modification of the court order is required.

c. The Court is aware1 that appellant has a chronic condition that was acute from May 8, 2025, to June 25, 20252 causing appellant to have several periods of lost vision which resulted in numerous errors and omissions when Appellant was drafting and when Appellant filed her Amended Brief.

See notice given to this court in Motion for Leave to file untimely brief by 9 minutes and to file Amended Appellant’s Brief with Excess words filed on June 25th, 2025.

Appellant’s condition remained until at least the beginning of the second week in July 2025 but the court is only aware of the condition up to June 25th, 2025.

Motion-5-Days’ Extension-file-Reply and for Leave-File-Corrected Opening brief Page 2 of 6 d. Appellant was able to cure errors 3 but not the omissions at that time.

Appellees caught the omissions and there is a necessity to correct the Amended Brief by filing a Corrected Amended Brief without changing any arguments or facts.

5. Appellees are aware of the omissions and understand that without the corrections, the relevant portions of the brief that are missing the page number for the case and the inclusion of the cases short title, will render those arguments meaningless and defeat a merit-based review of the case.

6. Filing a reply brief will not cure the defects because the substantive arguments in the opening brief will make no sense without the words omitted being included.

7. On September 5, 2025, appellant reached out to appellees to conference about whether appellees would be opposing appellant filing a corrected brief and identified specific corrections needed but because appellees would rather have appellant’s claims rejected on technicalities rather than have the case reviewed on the merits, appellees are opposed.

8. Appellant also conferenced about her need to request five days’ extension of time to file the reply and but appellees counsel is also opposed.

9. While appellant will be greatly prejudiced if this motion is denied, appellees will not suffer any prejudice from the deadline being extended by a mere 5 days up to

See Motion for Leave paragraphs 3 and 4.

Motion-5-Days’ Extension-file-Reply and for Leave-File-Corrected Opening brief Page 3 of 6 and including September 15, 2025, nor will they be prejudiced by appellant adding the correct page number (285) to Medlin v. King, 4 an important case in appellant’s argument, cited on page 39 and referenced on pages 41 and 46 of the Amended Brief but the citation was accidentally omitted, nor will appellees be prejudiced by appellant adding the words “and Medlin” or “and see Medlin” where it was obviously 5 omitted with the short citation which increased the words. Other minor changes include adding a bracket, changing the word “adversarial” to “adversary,” “Carried” to “Carry,” “reside” to “resides,” “and” to “are,” correcting the court name from Houston Appeals Court to El Paso Appeals Court on page 46, deleting “be” at the bottom of pate 47 etc. The proposed corrected brief is simultaneously filed per clerk instruction.

10. From the above, there are clearly no substantive changes made yet the proposed corrections are extremely important to the readability and comprehension of the brief but do not change any fact or argument in the brief.

11.Appellees response brief is not affected by it and only permits greater clarity of any confusing omissions.

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

705 S.W.3d 267, 285 (Tex. App.—El Paso 2024) The full quote from that case on which Appellant relies having been provided on page 39 running into page 40 of the Amended Appellant’s Brief.

Motion-5-Days’ Extension-file-Reply and for Leave-File-Corrected Opening brief Page 4 of 6 13. 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 Reply Brief by Five days, from September 10, 2025, to September 15, 2025, and granting leave for Appellant to file the attached Appellant’s Corrected Amended Brief in the interest of resolving the issues on the merits and so that justice may be done.

Dated this 9th day of September 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 Fax: 214-853-5708 [email protected] PRO SE APPELLANT UGALAHI OFFOBOCHE

Motion-5-Days’ Extension-file-Reply and for Leave-File-Corrected Opening brief Page 5 of 6 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 opposed.

/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

Motion-5-Days’ Extension-file-Reply and for Leave-File-Corrected Opening brief Page 6 of 6 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: 105475226 Filing Code Description: Motion Filing Description: Motion for Five Days Extension to complete and file Reply Brief and for Leave to file corrected brief Status as of 9/11/2025 7:05 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Ugalahi UgyOffoboche [email protected] 9/10/2025 10:07:26 PM SENT Robert J.Davis [email protected] 9/10/2025 10:07:26 PM SENT Robert J.Davis [email protected] 9/10/2025 10:07:26 PM SENT Robert J.Davis [email protected] 9/10/2025 10:07:26 PM SENT Kyle T.Barry [email protected] 9/10/2025 10:07:26 PM SENT Kyle T.Barry [email protected] 9/10/2025 10:07:26 PM SENT