Johnny Partain v. State of Texas

ACCEPTED 15-25-00005-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 9/16/2025 3:07 PM No. 15-25-00005-CV CHRISTOPHER A. PRINE CLERK FILED IN 15th COURT OF APPEALS In the AUSTIN, TEXAS 9/16/2025 3:07:04 PM Fifteenth Court of Appeals CHRISTOPHER A. PRINE Clerk

JOHNNY PARTAIN, Plaintiff –Appellant, v.

STATE OF TEXAS, Defendant –Appellee.

On Appeal from the 126th Judicial District Court, Travis County, Texas

APPELLEE’S NOTICE OF SUBSTITUTION OF COUNSEL TO THE HONORABLE JUSTICES OF THE FIFTEENTH COURT OF APPEALS: Appellee, State of Texas, files this Notice of Withdrawal and Substitution of Counsel, pursuant to Rule 6.1(c) and 6.5(d) of the Texas Rules of Appellate Procedure, and respectfully shows the Court as follows: Assistant Attorney General Ali Thorburn currently appears as Lead Counsel for Appellee. Ms. Thorburn has moved positions within the Attorney General’s Office and is no longer representing Appellee. Ms. Thorburn should be removed from all correspondence and notifications in this matter.

Appellee hereby gives notice that Assistant Attorney General Kyle Argenbright will appear on behalf of State of Texas and as Lead Attorney in this matter. Mr. Argenbright is a member and in good standing with the State Bar of Texas.

CONCLUSION Appellee requests the Court accept Kyle Argenbright as Lead Counsel for Appellee and send all future notifications to him.

Respectfully submitted.

KEN PAXTON Attorney General BRENT WEBSTER First Assistant Attorney General RALPH MOLINA Deputy First Assistant Attorney General AUSTIN KINGHORN Deputy Attorney General for Civil Litigation KIMBERLY GDULA Chief, General Litigation Division /s/ Kyle Argenbright KYLE ARGENBRIGT Texas Bar No. 24104597 Assistant Attorney General General Litigation Division P.O. Box 12548, Capitol Station Austin, Texas 78711-2548 (512) 979-5389 FAX: (512) 320-0667 [email protected] Counsel for Appellee

CERTIFICATE OF SERVICE The undersigned counsel certifies that the above and foregoing instrument has been served on all counsel of record in accordance with the Texas Rules of Appellate Procedure on this September 16th, 2025, through the electronic filing system, and Certified Mail, return receipt requested.

Johnny Partain 7020 N. 16th Street McAllen, Texas 78504 [email protected] Pro Se Appellant-Plaintiff

/s/ Kyle Argenbright Kyle Argenbright Assistant Attorney General

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.

Kyle Argenbright on behalf of Kyle Argenbright Bar No. 24104597 [email protected] Envelope ID: 105652704 Filing Code Description: Other Document Filing Description: 20250916_Appellee Ntc Sub of Counsel Status as of 9/16/2025 3:39 PM CST Associated Case Party: Johnny Partain Name BarNumber Email TimestampSubmitted Status Johnny Partain [email protected] 9/16/2025 3:07:04 PM SENT

Associated Case Party: State of Texas Name BarNumber Email TimestampSubmitted Status Chelsea Goodman [email protected] 9/16/2025 3:07:04 PM SENT Kyle Argenbright [email protected] 9/16/2025 3:07:04 PM SENT