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

Opinion

ACCEPTED 15-25-00144-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 9/19/2025 11:57 PM CHRISTOPHER A. PRINE CLERK No. 15-25-00144-CV FILED IN 15th COURT OF APPEALS IN THE AUSTIN, TEXAS 9/19/2025 11:57:05 PM CHRISTOPHER A. PRINE 15th COURT OF APPEALS 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

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APPELLANT’S RESPONSE RESPECTFULLY OPPOSING THE COURT’S EJECTION NOTICE REGARDING THIS CASE

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

PRO SE APPELLANT

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___________________________________________________________

APPELLANT’S RESPONSE RESPECTFULLY OPPOSING THE COURT’S EJECTION NOTICE REGARDING THIS CASE

___________________________________________________________

Sept. 19th, 2025

Pro se appellant Rich Robins hereby files this opposition response to the court’s pending ejection notice regarding his case.

A. Introduction

1. The Appellees (Plaintiffs at the trial court level) are 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 respectfully files this opposition to the Court’s pending ejection of this case. As further background, Appellant Robins mentions the following...

B. Facts

4. Appellant Robins includes Exhibit 1, below, as his trial court petition filed pursuant to the Texas Deceptive Trade Practices Act against the State Bar of Texas, et al.

C. Argument & Authorities

Procedural background

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5. Appellant Rich Robins desires to appeal to the 15th Court of Appeals from a judgment signed by Judge Tamika Craft-Demming on June 16th, 2025 in the 189th District Court of Harris County. The case number is #2025-10213. The judgment very hastily dismissed Robins’ Deceptive Trade Practices Act (DTPA) claims against the Appellees, based on mere TRCP 91a grounds. Appellant Robins subsequently timely filed a request, and later a revived request for Findings of Fact & Conclusions of Law on July 4th 2025 and August 1st, 2025, respectively. Tamika Craft filed no response whatsoever while the 1st Court of Appeals still refrains from ruling on a longstanding case there which challenges the legitimacy of her purported and very narrow electoral victory of 2022. See Erin Lunceford v. Tamika Craft, No. 01-23-00921-CV (Tex. App.—Houston [1st Dist.] Dec. 12th, 2023). More than one justice in that court is not only a member of the State Bar of Texas but also an officer in it. Appellant Robins has previously politely filed a motion to recuse Andrew Johnson in that court regarding Robins’ underlying dispute with the Texas Bar, and it was expeditiously denied. The 1st Court of Appeals similarly demanded that his administrative case transfer attempt to the 15th Court of Appeals (initially approved by the 15th Court of Appeals, too) be denied, too.

Facts underlying the Appellees’

ethics violation accusations against Appellant Robins

6. In part, this case is about the ethics rules-related consequences inflicted by the Appellees upon Appellant Robins. They primarily relate to his having not rushed to formally declare to a never-visited (by him), faraway court up in Tyler, Texas the (undocumented) reported death of a female client & eventual litigant (Cindy Crisp). She was approximately 59

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years old when Appellant Robins worked with her telephonically, without ever meeting her or receiving any compensation for himself, ever. She needed to try to recover compensation for herself from an estate vendor in Tyler, Texas who had issued her two bounced checks that he had written as the total liquidation amount for her estate. The estate vendor did so around the time when he also bounced dozens more checks to others. The two checks to the client were for approximately $7,000. Appellant Robins inserted in the lawsuit that the Appellant would settle for twice that amount (approximately $14,000) if no further legal wrangling would transpire. The client did, after all, repeatedly say that her estate was worth several multiples of the final checks’ amount. Appellant Robins filed the lawsuit in Tyler, which he has since only visited for a single day, ever, nearly a year after filing the abovementioned lawsuit and months after Robins had already taken the initiative to report the possibility of the (then still undocumented) death to the court.

7. No rule, not even TRCP 151, authorized Appellant Robins’

disclosing that she was reportedly dead and thereby subjecting her and her family to identity theft risks, and even worse if she was actually still alive (such as a forced hospitalized death for organ donation purposes). No obituary was ever published for her, either. Meanwhile, Appellant Robins was officially and repeatedly denied a death certificate when he repeatedly attempted to quietly obtain one. Her status as living or dead did not matter for her relevant legal rights to recover on a small ($7,000) claim that Appellant Robins pursued for her. Appellant Robins knows of no outstanding creditors for her to this day, as the amount of the checks was smaller than Medicaid’s minimum required for it to file collections actions.

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Furthermore, there is still no way to exclude the possibility that the client is confidentially cryopreserved, either. Cryonics service providers have learned repeatedly that heirs who learn of monetary deposits financing a relative’s cryopreservation would prefer to “pull the plug” on the deep freeze container and take the money for themselves.

8. Appellant Robins’ religion aligns with that of the Church of Perpetual Life, a science-based alliance in which death is considered optional thanks to cryonics. Everyone reading this is welcome to visit www.Perpetual.life. Cryonics or other life extension approaches plus time travel could someday enable us all to visit with our deceased loved ones. The Bar appellees in this appeal mocked and scorned Appellant Robins’ cryonics-related precautions, in writing, as he can easily prove.

9. Because of Appellant Robins’ taking months to investigate before voluntarily mentioning the client’s supposed passing to the court months before his lone visit there days after a devastating Houston hurricane (Harvey), the Commission for Lawyer Discipline accused him of misrepresenting, just like it did to its fairly recent grievance prosecution appellees Brent Webster, Ken Paxton & Sidney Powell (etc.). The Texas Bar appellees inflicted on Appellant Robins the only ethics or criminal prosecution that he has ever endured for anything at all during his nearly 30 year legal career. So here we are. The corresponding DTPA lawsuit (Exhibit 1) provides additional details. Meanwhile:

The Fifteenth Court of Appeals’ involvement is needed to help make the State Bar of Texas’ ethics rule interpretations uniform statewide.

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10. By litigating this dispute in the 15th Court of Appeals, we can jointly make it clear at the statewide level what the Bar appellees’ ethics rules actually permissibly mean. Regarding the Bar appellees’ boundless rule prohibiting attorney misrepresentations, for example, we can get statewide clarity regarding at what point one may even disclose a client’s rumored but nevertheless undocumented death despite intimidatingly strict ethics rules protecting client confidentiality. Afterwards, perhaps Texas could subsequently begin to catch up with other U.S. states where cryonics centers exist and (in some locales) thrive while Texas has endured the (literally) chilling weight of this ethics dispute as it continues to lack such an active center. The list of U.S. states where active cryonics facilities serving humans actually exist presently includes Michigan, Arizona, California, Oregon and Florida, but not Texas. Nevertheless, the prospect of making death optional has its appeal (now literally). The Fifteenth Court of Appeals, with its statewide electorate and focus on state agencies, governmental actions & inactions can help Texas catch-up especially here in Space City (i.e. Houston). Cryonics breakthroughs are needed to help make long distance space travel more viable, after all. Ask Elon…

11. Appellant Robins appeals the judgment in this DTPA case to the new Fifteenth Court of Appeals in Austin, Texas. That court has exclusive intermediate appellate jurisdiction over matters arising out of or related to civil appeals brought by or against the state.

12. The 15th Court has exclusive intermediate appellate jurisdiction over certain enumerated matters. Tex. Gov’t Code §22.220(d); §25A.007.

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13. The Texas Legislature restricted the 15th Court’s jurisdiction by divesting it of jurisdiction over criminal matters. In re Dallas Cnty., 2024 WL 3908122, at *15. Nowhere do the relevant provisions of the Texas Government Code prohibit jurisdiction regarding the State Bar of Texas or its statewide Commission for Lawyer Discipline, however. See generally, Tex. Gov’t Code §22.220.

14. Puzzlingly enough, earlier this year the 15th Court of Appeals denied jurisdiction to unrelated litigation against the Commission for Lawyer Discipline. See Turnbull v. Commission, 15-24-00095-CV (15th COA, 2024). The legal climate has since evolved, though, in part due to new jurisprudence from the Supreme Court of Texas. It is time to let this jurisdictional debate regarding the State Bar of Texas go directly to the Supreme Court of Texas, for the good of nearly all Texans who want governmental rules (such as attorney ethics ones) to be interpreted similarly throughout the entire state.

15. Texas’ Governor Abbott, Senator Huffman and other proponents of the 15th Court of Appeals’ creation envisioned a Texas where government regulations mean the same in all 14 different state appellate districts. This goal is particularly important in the legal profession, where presently some ethics rules are interpreted substantially differently, depending upon the appellate district. Sometimes a lawyer’s services cover more than one lone appellate jurisdiction, as is the case with Robins’ underlying dispute with the State Bar of Texas. One cannot obey conflicting interpretations of the same rule without running into even more ethics problems with the profiteering Bar appellees. The resulting

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unpredictability makes it more costly to retain legal representation in Texas. That helps almost nobody.

Relevant statutory authority requires that disputes against the State Bar of Texas (and its progeny) go to the 15th Court of Appeals

16. Texas’ Legislature limited the 15th Court of Appeals’

jurisdiction to specific civil matters, including:

[M] atters brought by or against the state or a board, commission, department, office, or other agency in the executive branch of the state government…or by or against an officer or employee of the state or a board, commission, department, office, or other agency in the executive branch of the state government arising out of that officer’s or employee’s official conduct….

TEX. GOV’T CODE § 22.220(d)(1). Such appellate matters may

be heard only by the 15th Court of Appeals, instead of any other

intermediate appellate court. Id.

17. The Legislature’s use of a disjunctive “or” in the

abovementioned text is significant. In viewing that text with some

emphases inserted, it appears as:

[M] atters brought by or against the state or a board, commission, department, office, or other agency in the executive branch of the state government…or by or against an officer or

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employee of the state or a board, commission, department, office, or other agency in the executive branch of the state government arising out of that officer’s or employee’s official conduct….

TEX. GOV’T CODE § 22.220(d)(1) (emphasis added). The “or”

disjunctions are important.

18. “Or” as underlined in the abovementioned text

disjunctively indicates an alternative. The two “or” conjunctions,

therefore, indicate that the Texas Legislature intended to divide

qualifying civil matters into four categories: (i) by or against the

state; (ii) by or against a board, commission, department, office, or

other agency in the executive branch of this state; (iii) by or against

an officer or employee of the state; and (iv) by or against an officer

or employee of a board, commission, department, office, or other

agency in the executive branch of this state. See TEX. GOV’T

CODE § 22.220(d)(1). Stated differently, as long as the underlying

civil case falls into one of the abovementioned four categories, the

case is within the 15th Court of Appeals’ jurisdiction.

19. An appeal against the State Bar of Texas falls into, at the very

least, category (i) mentioned above (“by or against the state”). The

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State Bar and its progeny purport to be, or purport to be part of a

legislatively created public corporation and administrative agency

of the State. See, TEX. GOV’T CODE § 81.011(a). Claims against

the State Bar appellees fall into the 15th Court of Appeals’

jurisdiction under category (i) described above: claims brought by

or against the State. TEX. GOV’T CODE § 22.220(d)(1).

The doctrine of last antecedent, as depicted in Texas Supreme Court jurisprudence:

20. The Fifteenth Court of Appeals has seemingly preliminarily interpreted jurisprudence from the Supreme Court of Texas to mean that the words “executive branch” in the 15th Court of Appeals’ statutory enabling authorization require that a “commission” must be part of the executive branch in order to qualify for jurisdiction in the Fifteenth Court of Appeals. In addressing that interpretation, however, it helps to notice that executive branch does not necessarily modify even the word “commission.” The Supreme Court of Texas has embraced the “doctrine of last antecedent” before, including in Spradlin v. Jim Walter Homes, Inc., 34 SW 3d 578 (2000). In applying that doctrine to this appeal, the modifier “executive branch” applies merely to the word before it, and not to the entire batch that precedes it including “commission”.

21. As an illustrative additional example offered for analytical purposes, the grammar of the relevant enabling statutory provision for the Fifteenth Court of Appeals resembles that of the following: “I will only eat apples or bananas grown in my garden." There the phrase "grown in my

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garden" is understood to modify only "bananas," not "apples," according to the doctrine of last antecedent. A more elaborate example is “[i]nsecticide brand X has not been formally tested on strawberries, grapes, apples, peaches, citrus fruits or other tree-born fruits (persimmons, cherries, etc.), but it has on tomatoes.” Not all of the entities preceding “or other tree- born fruits” are tree-born fruits, but they are nevertheless suitably present in that sentence. The same can be said for “executive branch” in the statutory authorization of the Fifteenth Court of Appeals. A matter against the state qualifies for the Fifteenth Court of Appeals even if it is not one in the executive branch.

22. Those who feel intimidated with a perception that the presence of the words “executive branch” in the jurisdictional sentence beginning with “matters against the state” yields ambiguity can find solace in the following news. The Supreme Court of Texas has recently stated in Kelley v. Homminga that if constitutional or statutory “language is susceptible of two constructions, one of which will carry out and the other defeat its manifest object, courts should apply the former construction.” Dallas County, 697 S.W.3d at 159 (cleaned up) (quoting SCALIA & GARNER, supra, at 63). Kelley v. Homminga, 706 S.W. 39 829, 832 (Tex 2025).

23. What is the statutory language’s “manifest object” then? In looking back to Senate Bill 1045 from the 88 th regular legislative session of Texas, the Senate Research Center’s bill analysis expressly states the following:

Under the current judicial system, appeals in cases of statewide significance are decided by one of Texas's 14 intermediate appellate courts. These courts have

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varying levels of experience with the complex legal issues involved in cases of statewide significance, resulting in inconsistent results for litigants.

S.B. 1045 addresses these problems by establishing an intermediate court of appeals with exclusive jurisdiction over cases to which the state, a state agency, or a state official is a party. The justices on this new Fifteenth Court of Appeals are elected statewide, ensuring that all Texans have a voice in the selection of judges who decide cases of statewide importance. See Texas Senate Research Center, Bill Analysis for S.B. 1045, 88th Leg., R.S., (2023).

Is it not remarkable that the legislative intent behind the bill is to grant exclusive jurisdiction to the 15th Court of Appeals for cases to which “a state agency” is a party? Nowhere in that entire bill analysis does the Senate Research Center even so much as hint at an exclusion or exemption for the state agency known as the State Bar of Texas. Why should it?

24. The State Bar of Texas readily refers to itself as a state agency, too, while clinging to sovereign immunity to the detriment of arguably nearly all Texans. Indeed, through a combination of a sovereign immunity claim and an astonishing disbarment pursuit against Appellant Robins, the State Bar of Texas eventually got Appellant Robins’ federal class action lawsuit against that bar dismissed. In the process, this rendered fellow compulsory bar members without compensatory remedies even after the McDonald v. Longley outcome from the 5th Circuit established that that bar had been noncompliant and unconstitutional. See: McDonald v. Longley, 4 F 4th 229 (5th Cir. 2021). See generally https://www.reuters.com/legal/legalindustry/state-bar-texas-faces-freshchallenge -mandatory-dues-2021-08-31/ . The Texas Bar may not have its cake and eat it too, though...

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Constitutional authorities

25. Furthermore, the Texas Constitution's open courts provision (Article 1, Section 13) states that all courts must be open and that everyone has the right to a remedy through the due course of law. Interpretations of it vary, admittedly, but Appellant Robins’ position is that he has the right to litigate this appeal in the 15th Court of Appeals. Preventing his access to the 15th Court of Appeals requires a clear and strong statutory prohibition against it. Such a prohibition does not exist. To the contrary, statutory authority requires access for Robins’ matter against the State Bar of Texas. Applying an imaginary prohibition by making matters against the state be applicable only to the executive branch would arguably be unconstitutional.

26. Meanwhile, the Interstate Commerce clause of the U.S.

Constitution (Article I, Section 8, Clause 3) protects the rights of litigants not to be, among other things, arbitrarily excluded from protections such as those provided by the 15th Court of Appeals. Appellant Robins has interstate involvement that arguably qualifies him for such protections. He took the State Bar of Texas at its word that it would adjudicate not predatorily, but rather helpfully, so that attorneys could feel comfortable assisting an increasing amount of clients here in Texas. He has found this not to be the case, and he wants to use a uniquely statewide and specialized court for adjudicating the disbarment that the State Bar of Texas demanded against him which was preceded by nearly 3 decades of his otherwise ethically spotless (and still criminally spotless) record.

27. The 15th Court of Appeals has a uniquely statewide audience & electorate, and a specialized focus that can be particularly useful. Local

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appellate courts do not have that, nor are they designed to. Furthermore, the State Bar of Texas is so under-regulated that a specialized court is even more necessary when trying to discover ways to bring it into constitutional (and other) compliance. If anyone doubts this, they are encouraged to visit the website TexasBarSunset.com. See also: McDonald v. Longley, 4 F 4th 229 (5th Cir. 2021) & Boudreaux v. La. State Bar Ass'n, 86 F.4th 620 (5th Cir. 2023).

28. Indeed, the 5th Circuit Court of Federal Appeals has has adjudicated substantially against activities previously zealously embraced by the State Bar of Texas. Meanwhile, the State Bar of Texas “forgot” to even mention its rampant embezzlement problem during the most recent Sunset Review (2016-17), as we document here: http://www.TexasBarSunset.com/embezzling . Fortunately we were there to help remind them. In fact, Appellant Robins was the only one to even mention the rampant bar theft problem (which lasted nearly a decade) in all of the public comments filed. See https://web.archive.org/web/20210501083002/https://www.sunset.texas.go v/reviews-and-reports/agencies/comments/1331. The State Bar of Texas gave awards to legal counsel who represented 9/11/01 terrorists, but only gave lawfare to Appellant Robins for having protected the public from that bar’s cloaked attempts to get unlimited dues-increase authority pursuant to the Sunset Review, without even notifying (much less seeking referendum approval from) still compulsory bar members.

29. Incidentally, bar lawfare has become increasingly interesting to entities ranging from the Federalist Society:

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https://fedsoc.org/events/ethics-or-ideology-bar-associations-and-theboundaries -of-professional-discipline

to the White House: http://www.EastmanDilemma.com

30. Appellant Robins understands that the 15th Court of Appeals might perhaps be apprehensive that the enabling statutory and rule-based language for the 15th Court of Appeals do not expressly mention disputes with the government in the judicial branch. He therefore reiterates that the enabling language also does not expressly and clearly exclude judiciary disputes from the jurisdiction of the 15 th Court of Appeals, even as it does exclude other sorts of disputes involving the government, especially in criminal law. So why exclude Appellant Robins’ appeal? The 15th Court of Appeals exists for matters against the state, after all. Meanwhile, constitutions are made to be respected.

31. As you know, courts presume that the legislature purposefully chose which words to include in the statute and which to omit. Lippincott v. Whisenhunt, 462 S.W.3d 507, 509 (Tex. 2015) (per curiam). The Court’s objective in construing a statute is to give effect to the Legislature's intent, which requires one to look initially to the statute's plain language. Leland v. Brandal, 257 S.W.3d 204, 206 (Tex.2008). If that language is unambiguous, one is to interpret the statute according to its plain meaning. Id. The statutory language involving the 15th Court of Appeals is clear enough.

32. Furthermore, the Supreme Court of Texas has stated that when construing a statute, we give effect to all its words and, if possible, do not treat any statutory language as mere surplusage. Cont'l Cas. Ins. Co. v. Functional Restoration Assocs., 19 S.W.3d 393, 402 (Tex.2000).

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33. In Baumgardner v. Brazos River Authority, the Supreme Court recently expressly referred to “jurisdiction-exercising state agencies.” Baumgardner v. Brazos River Authority, 714 S.W.3d 597, 604 (2025) (emphasis added). Is there anyone reading this appellant opposition to transfer letter who somehow doubts that that phrase means to the Supreme Court of Texas that if an entity is a state agency, it has jurisdiction in the 15th Court of Appeals? The Court found that the Brazos River Authority is not a part of the executive branch. However, that does not mean that the Court is asserting that a matter against the state must directly involve the executive branch.

2 prior misdirections:

34. While it is true that the Supreme Court of Texas initially denied Appellant Robins motion to transfer his administrative case vs. the State Bar of Texas over to the 15th Court of Appeals, they have yet to rule on his request for a rehearing which he e-mailed them within a day, or so, of randomly discovering the basically unannounced denial, back during the Christmas holiday of 2024. The 1st Court of Appeals had demanded that Robins’ administrative case transfer attempt to the 15th Court of Appeals (initially approved by the 15th Court of Appeals, too) be denied. The Supreme Court subsequently gave no explanation for its initial denial, but the matter’s having had the 1st Court of Appeals’ thumb on the scales may be the reason. At any rate, Robins’ pending administrative case slightly predated the creation of the 15th Court of Appeals, to which Appellant Robins zealously sought a transfer on the court’s opening morning. Thus, that matter is distinguishable from the present one.

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35. So is Appellant Robins’ subsequent attempt to transfer his Religious Freedom Restoration Act (RFRA) case from the 14th (where it was never intended to go before a court clerk mysteriously mis-directed it) to the 15th Court of Appeals. District Court judge Tamika Craft summarily dismissed that case, too, again with no explanation and while the 1st Court of Appeals continues to bestow upon her a victory through eventual mootness at the expense of Harris County voters who want answers, especially former judge Erin Lunceford who awaits her ruling. See Erin Lunceford v. Tamika Craft, No. 01-23-00921-CV (Tex. App.—Houston [1st Dist.] Dec. 12th, 2023). Meanwhile Robins’ letter request for a reconsideration in the 14th Court of Appeals remains pending, as one does in the Supreme Court of Texas.

D. Conclusion

36. Pro se appellant Rich Robins hereby thanks the Court for considering this opposition and asks that the 15th Court of Appeals retain his appeal. In the alternative, he asks that it do what is needed so that this matter be conveyed to the Supreme Court of Texas before being (Robins believes) unlawfully ejected back to a regional appellate court.

Sincerely submitted,

Rich Robins (Pro se Appellant) 2450L ouisiana St. #400-155 Houston, TX 77006-2380 Rich@RichRobins.com Tel. 832-350-1030

_____________________________

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Exhibit 1: Robins’ DTPA lawsuit:

CAUSE #202418660

RICH ROBINS § IN THE 189th JUDICIAL § DISTRICT COURT § vs. § OF § § COMMISSION FOR LAWYER DISCIPLINE § HARRIS COUNTY, dba “TEXAS BAR” § TEXAS aka “STATE BAR OF TEXAS” § §

PLAINTIFF RICH ROBINS’ 2ND AMENDED PETITION, ADDING A CLAIM

COMES NOW, Plaintiff Rich Robins (hereinafter “Plaintiff Robins”, the respondent named as the defendant in the Commission for Lawyer Discipline’s lawsuit in case #2018-46488 in Harris County District Court #61). Plaintiff Robins files this amended petition pursuant to Chapters 106 & 110 of Texas’ Civil Practice & Remedies Code. Chapter 110 comprises Texas’ Religious Freedom Restoration Act (hereinafter the “RFRA”) and Chapter 106 seemingly does, as well, albeit to a lesser extent. Plaintiff Robins ALSO files this amended petition to add a claim against the Defendants, pursuant to the Texas Deceptive Trade Practices Act. Plaintiff Robins hereby asserts the following…

1. Plaintiff Robins brings this legal action against the State Bar of Texas (hereinafter the “Texas Bar”), its Commission for Lawyer Discipline (hereinafter the “CFLD”), and the Chief Disciplinary Counsel (hereinafter the “CDC”); (hereinafter the “Bar defendants”). This is the

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only disciplinary action or prosecution EVER to be pursued against Plaintiff Robins by any bar association or other authority during his approximately 30 years of actively practicing law. Plaintiff Robins also has no criminal or even traffic convictions against him.

2. The denial of Plaintiff Robins’ request to get his RFRA claims heard by the fact-finder in his abovementioned disciplinary trial is presently on appeal. The RFRA’s applicability is also independently pursued in district court, however. This is out of an abundance of caution in case that appeal is not successful at getting the RFRA claims ever addressed due to the Bar defendants’ puzzling claim of a lack of subject matter jurisdiction in a grievance proceeding. The visiting trial court judge granted the Texas Bar defendants’ request to exclude (Plaintiff) Robins’ RFRA claims & defenses, thereby depriving the jury of the opportunity to hear or see them and Mr. Robins of his right to a jury trial on such matters, at the very least as a defense.

3. The Texas Bar in Austin, indeed, received Plaintiff Robins’

notice of the relevant RFRA accommodation period, and of its CFLD petitioner’s allegedly discriminatory actions against him. The U.S. Postal Service delivered that notice to the Texas Bar / CDC / CFLD there on January 24th, 2023. Plaintiff Robins had previously stated in at least one prior filing during the grievance proceedings that “[t]he Texas Bar in Austin has received my notice of this RFRA accommodation period, and of its CFLD petitioner’s pending & discriminatory actions against me. The U.S. Postal Service delivered it to the Texas Bar on January 24 th, 2023. Here is the tracking number:

70212720000186333742 Meanwhile the confirmation of return card’s tracking number is:

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9590940272191284536905”

The notice politely included relevant court records, etc.

4. Such notice is not even required under all circumstances, as both CPRC §106 & §110 state. See generally CPRC §110.006 and CPRC §106.

BACKGROUND

5. On July 2nd, 2021 the Fifth Circuit Court of Appeals in New Orleans, Louisiana decisively ruled that the Defendants Texas Bar (& thereby its CFLD & CDC) impermissibly, unlawfully and enduringly spent attorney members’ coercively extracted annual dues on ideological and political endeavors that are not germane to regulating or improving the practice of law here in Texas. See McDonald v. Longley, 4 F.4th 229 (5th Cir. 2021). The Court also found that the Defendants had similarly unlawfully not given dues-paying members constitutionally adequate and meaningful notice of how their coercively extracted dues money would be spent or where their fees would go. Id. Additionally, the Court found that the Defendants have not given members adequate veto authority over such expenditures. Id.

6. Subsequently the Fifth Circuit issued its relevant mandate on July 26, 2021 (ECF No. 103). It thereby sided with the amicus briefsubmitting Texas Attorney General Ken Paxton and against the Texas Bar. Perhaps not altogether coincidentally, that bar has since sought to disbar Attorney General Paxton, in part for allegedly not investigating something adequately enough before making a statement about it in a

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court filing. That bar tried to disbar Attorney Paxton in Collin County District Court’s case # 471-02574-2022, which is available online at: https://apps2.collincountytx.gov/judicialrecords/case . As this petition will show, below, the same bar nevertheless prosecuted Plaintiff Robins for investigating something, namely word of his client’s death from someone on the phone whom Plaintiff Robins had never met, and who received a hefty inheritance from her as a result of such a potentially hasty declaration, thereby depriving Medicaid of compensation and quite possibly Robins’ client of her house while she remained alive, albeit institutionalized. Plaintiff Robins investigated this before he ultimately disclosed word of a 59 year old client’s death to the court even as no Texas state statute, state rule of civil procedure or binding state caselaw requires or allows for such a disclosure. One statutory provision even encourages one to wait seven years, while federal caselaw says no such advisory is even required by the rules. Plaintiff Robins nevertheless reported this to the court (up in Smith County, Texas) even though there has never been an obituary published for the client and even though he had been repeatedly denied by state authorities a copy of her death certificate (if one even existed).

7. For decades, the Texas Bar has already had ample notice from the U.S. Supreme Court and the Texas Government Code that members are not to be coerced into funding expenditures that are not germane to the permissible purposes of a mandatory bar. See Keller v. State Bar of California, 496 U.S. 1 (1990). See also TEX. GOV’T CODE §81.034. The Texas Bar continues to operate an attorney disciplinary system that is not in compliance with constitutional law, as this case helps show.

8. All of the Texas Bar’s CFLD’s & CDC’s approximately five

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claims prosecuted against Plaintiff Robins are based on the incorrect supposition that the Texas Bar can nondemocratically impose its will on the state of Texas regarding Texas’ otherwise fairly tolerant and permissive rules and laws. The particularly relevant rules & laws involve the speed with which a lawyer representing a plaintiff here must report to the assigned court news of the plaintiff’s death even when independent attempts to verify it did not document and possibly could not ever document it sufficiently reliably. The Bar defendants allege that months’ delay under such circumstances is deceptive and grounds for disbarment, even as apparently no state rule, law or case decision labels it as impermissible, much less deceptive. In fact, Plaintiff Robins has found caselaw asserting contrarily that one need not even notify the court that a client has passed away in a pending case.

9. The relevant prosecution of Plaintiff Robins emerged about a year after he became the only attorney to testify critically of the Texas Bar during all three available public comments opportunities involving the 2016-2017 Sunset Review of the Texas Bar at Texas’ state legislature in Austin. Plaintiff Robins compassionately recommended keeping the Texas Bar around for another 12 years (as he can easily prove). However, he opposed granting the Texas Bar the unrestricted rights to increase annual dues whenever it likes and as often as it likes. The Texas Bar sought that right despite having simultaneously mass-mailed all member attorneys that their referendum rights remained intact amidst the Sunset process. Referendum restrictions have existed regarding dues increases for many decades, if not for the entire time that the Texas Bar has existed with mandatory membership status. Rather than apologize for having defrauded the membership, the Texas Bar found fault with the

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candid caretaker Robins, and viciously attacked his livelihood at the expense of Plaintiff Robins’ religious rights including by depriving his license as prohibited by religious freedom protections delineated at CPRC §106.001. Within a year of successfully getting Plaintiff Robins disbarred, the Texas Bar awarded itself a dues increase and without seeking, much less obtaining approval from the still compulsory Texas Bar membership.

AFFIRMATIVE CLAIMS FOR RELIGIOUS DISCRIMINATION

10. Plaintiff Robins mentions that during January of 2023, the Texas Bar defendants, either directly or indirectly, revealed their discriminatory intentions in their first, ever, answer to the accused respondent Robins’ request for disclosures provided to Plaintiff Robins in their ethics prosecution against him. In those disclosures, the CFLD’s and Texas Bar’s and arguably CDC’s prosecutor John Brannon states (and bold faced text is included, verbatim):

“Factual Bases….

“[Plaintiff Robins] went on to claim that “any fan of baseball star Ted Williams realizes that a head can be rather affordably severed from a deceased body and frozen for a desired revival and bodily regeneration many years later ….” Respondent asserts that “[s]uch procedures have been known to take place very secretively at the request of heirs who do not tell others in the family, and who cremate merely the body.” The aforementioned statements by Respondent evidence the types of salacious, false, dishonest, defamatory, frivolous, and outrageous claims and positions Respondent took during his representation of Crisp and the Clinkenbeards.”

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11. Plaintiff Robins mentions that he did not even have to add the

emboldened nature of that concluding text. Plaintiff Robins is being

discriminated against for his religious views as a longstanding follower of

the Church of Perpetual Life. That nondenominational church is available

to the world at: ChurchOfPerpetualLife.org .

12. That church stands for ideals such as how we are each blessed

with one life that has infinite potential through science. We are joined

together through an alliance of potential universal resuscitation.

Furthermore, those who embrace pioneering technologies in furtherance of

such goals are not to be scorned or harmed for it.

13. Plaintiff Robins always wanted what is best for his relevant and

reportedly deceased client, Cindy Crisp. He avoided rushing to declare her

dead while he hoped to somehow discover ways to locate and financially

support her. He was polite to her family members and nonjudgmental, as

psychotherapist Karl Rogers preached as part of his Humanist school of

thought. Nevertheless, the Texas Bar defendants made it crystal-clear

how hostile they are to such a supportive approach to life. They have gone

to great lengths to penalize, silence and cancel Plaintiff Robins

professionally for it, too, while they continue making a fortune from (still

compulsory) bar members each year.

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14. Plaintiff Robins shares the following benign & explanatory

quote: “[t]he aim of the cryogenic process is to preserve tissues, organs and

the brain after the heart stops beating, with the body stored head-down in

liquid nitrogen at -196C. They are then considered ‘in suspension’ ahead of

possible scientific leaps to revive and return them to good health.”

Source: https://metro.co.uk/2023/01/07/brits-hope-for-life-after-death-bycryogenically -freezing-their-bodies-18039920

What is so unacceptable about supporting and assisting anyone’s possible direct involvement with that pursuit?

15. Here is an example of what can happen to those (such as Robins’

client Cindy Crisp, who never discharged him…) who do not hide their cryopreservation aspirations from heirs: Alcor Life Extension Foundation v. Pilgeram. That relatively recent dispute, now concluded, is included by hyper-link here:

https://www.dailymail.co.uk/news/article-7903137/Sons-legal-fight-deadfathers -frozen-head-against-cryogenics-firm-preserving-it.html

Long story short, heirs have been known to try to disrupt a deanimated person’s cryonics-related plans, in pursuit of the relevant money for themselves.

16. Anyway, the Defendants’ treatment of Plaintiff Robins is in clear violation of religious freedom protections that exist in the Texas Civil Practice & Remedies Code's Chapter 110 and arguably Chapter

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106.001 as well. They canceled his religious freedoms as included in his practice of law, without sufficient (if any) statutory, common law or civil procedure rule-based justification. If the Texas Bar is so eager to prevent the expression of members’ concerns about potentially “biologically paused” or “clinically dead but hopefully not permanently so” clientele, it should try to amend applicable statutory, civil procedure, and jurisprudential authorities. Instead, the Defendant Texas Bar, CFLD and CDC consider themselves to be above such “deathist” endeavors, quite possibly because they would not gain traction with Texans anyway. Texans want to live, not subscribe to the Texas Bar’s dark view of life. Texans certainly do not want to empower unelected and insufficiently regulated Bar bureaucrats to determine when other people’s rights should be terminated.

17. Plaintiff Robins’ free exercise of religion was substantially and unlawfully burdened by the Bar defendants’ actions. Actions from all three have not furthered a compelling government interest, as one can tell from the absence of statutory or civil procedure rule authority saying otherwise. Meanwhile, the Texas bar defendants’ actions against Plaintiff Robins are not the least restrictive means of furthering any compelling interest. For example, the Texas Bar defendants have not enacted any rules that are expressly on point, nor have they successfully gotten (or even tried to get) a statutory or civil procedure restriction placed on conduct involving the (supposedly obligatory) hasty declaration of a client’s death despite the risks of breach of attorney / client privilege, and of identity theft that could financially adversely affect the whole family. The Texas Bar has also not prosecuted any other lawyer for doing something similar, as far as Plaintiff

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Robins can tell.

18. Meanwhile, despite federal restrictions upon the Texas Bar’s taking such political stances, the bar defendants excluded nearly all of Plaintiff Robins’ defenses and evidence from the fact-finder’s access during pre-trial proceedings, with the predictable result’s emerging. An appeal is underway, and is an ongoing burden from which Plaintiff Robins is entitled to relief.

Defendant Robins has endured and continues enduring ongoing religious discrimination from the CFLD, the Texas Bar and the CDC:

19. The CFLD, Texas Bar and CDC have prosecuted and punished Defendant Robins to forfeit his religious views favoring the (hopefully merely) undead, while seeking to punish him for his having observed and practiced his beliefs in the past as part of his practice of law. Astonishingly enough, the CFLD petitioner would, even in the documented absence of statewide law’s, rules’ or jurisprudence’ requiring it, have Defendant Robins rush to judgment when circumstances are ambiguous as to whether a missing client is potentially cryo-preserved, i.e. clinically dead (or even just missing perhaps at a Hospice facility) instead of permanently dead. The petitioner would have had Defendant Robins disclose such a client’s possible vulnerable legal status even when that client’s well-being remains insufficiently confirmed, and would consequently be compromised and a source of great suffering upon a desired revival someday. The petitioner would have even had Defendant Robins settle a case such as Cindy Crisp’s despite his firm belief that the (possibly cryo-preserved or simply

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comatose) client would disapprove upon awakening. As prominent caselaw says, “[w]here the state conditions receipt of an important benefit upon conduct proscribed by a religious faith, or where it denies such a benefit because of conduct mandated by religious belief, thereby putting substantial pressure on an adherent to modify his behavior and to violate his beliefs, a burden upon religion exists. Adkins v. Kaspar, 393 F.3d 559, 569 (5th Cir. 2004), citing Thomas v. Review Board of the Indiana Employment Security Division, 450 U.S. 707, 101 S.Ct. 1425, 67 L.Ed.2d 624 (1981).

20. Furthermore, the Code of Federal Relations states, in relevant part:

“In most cases whether or not a practice or belief is religious is not at issue. However, in those cases in which the issue does exist, the Commission will define religious practices to include moral or ethical beliefs as to what is right and wrong which are sincerely held with the strength of traditional religious views. This standard was developed in United States v. Seeger, 380 U.S. 163 (1965) and Welsh v. United States, 398 U.S. 333 (1970).” See §1605.1 “Religious” nature of a practice or belief.

21. Nevertheless, Plaintiff Robins mentions how the Texas Bar / CFLD / CDC prosecutor John Brannon claimed in a (successful) opposition to a continuance that Defendant Robins did not refer to his religious views favoring the potentially cryo-preserved client Cindy Crisp during a 5+ hour deposition of Plaintiff Robins. Nevertheless, the following two exchanges between the CFLD petitioner (“Q”) and Defendant Robins (“A”) are revealing (as are others) as to how inaccurate such assertions by the Texas Bar defendants were:

Deposition, at page 47:

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Q. And so, I want to try to get philosophy, religion, any type of spirituality out of it. And just focus on that non-sector for a moment, for purposes of this case. A. Non-sector? Q. If you would, please. Something that is not spiritual or religious or philosophical. I want to get -- if you can remove that, you know, from your vocabulary during the question and answer. That would be very helpful. Okay?

&

Deposition page 134:

A. Yes. But please, realize, there is a difference in my world, between being clinically dead and permanently so, biologically paused and exterminated.

Texas Bar prosecutor John Brannon is an agent (if not also an employee) of the CDC, as well as an employee of the CFLD and of the Texas Bar. They work in cahoots with one another. As discovery has not gotten underway yet (per a Rule 11 agreement recently submitted in opposition to the Defendants’ motion to dismiss), it is not yet possible to provide elaborate detail while the dismissal motion nevertheless purports to fault Plaintiff Robins for that fact regarding this new lawsuit.

Sovereign immunity is waived:

22. Claims of sovereign immunity do not withstand scrutiny. The RFRA says, in relevant part:

Sec. 110.008. SOVEREIGN IMMUNITY WAIVED. (a)

Subject to Section 110.006 [notice & right to accommodate], sovereign immunity to suit and from liability is waived and abolished to the extent of liability created by Section 110.005 [remedies], and a claimant may

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sue a government agency for damages allowed by that section.

Additionally, cases such as Richards v. Mena, 907 S.W.2d 566, 569 (Tex.App.--Corpus Christi 1995, writ dism’d) are relevant. CPRC §106.002(b) “provides for an express waiver of the State’s governmental immunity to those prohibited acts listed in [CPRC] §106.001.”

23. Additionally, the following case from the Texas Bar headquarters’

backyard of Austin, Texas further shows how claims about sovereign immunity pursuant to its own rules are inadequate under the circumstances: Commission for Lawyer Discipline v. Rosales, 577 S.W.3d 305, 313-314 (Tex. App.—Austin 2019, pet. denied). There it states the following:

The Commission further argues that the TCPA does not apply to its disciplinary proceedings because the Commission is entitled to "absolute immunity." In support of this argument, it points to the provision providing that the TCPA "does not abrogate or lessen any other ... immunity available under other constitutional, statutory, case, or common law or rule provisions," Tex. Civ. Prac. & Rem. Code § 27.011(a), and to Rule 17.09 of the Texas Rules of Disciplinary Procedure, which provides:

All members of the Commission, the Chief Disciplinary Counsel (including Special Assistant Disciplinary Counsel appointed by the Commission and attorneys employed on a contract basis by the Chief Disciplinary Counsel), all members of Committees, all members of the Board of Disciplinary Appeals, all members of the District Disability Committees, all officers and Directors of the State Bar, and the staff members of the aforementioned entities are immune from suit for any conduct in the course of their official duties. The immunity is absolute and unqualified and extends to all actions at law or in equity. Tex. Rules Disciplinary P. R. 17.09.

According to the Commission, "[a]n obvious purpose of the immunity provided by Rule 1[7].09 is to allow the disciplinary system to discharge their official duties without fear of being sued or liable for monetary

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judgments, such as attorneys' fees that can be awarded in [TCPA] proceedings."

The immunity granted in Rule 17.09, however, is official immunity that shields governmental employees from personal liability so that they are encouraged to vigorously perform their official duties. See id.; Telthorster v. Tennell, 92 S.W.3d 457, 460-61 (Tex. 2002) ("Official immunity is an affirmative defense that shields governmental employees from personal liability so that they are encouraged to vigorously perform their official duties.") (citing Kassen v. Hatley, 887 S.W.2d 4, 8 (Tex. 1994)). It is not the same as sovereign immunity, which protects the State, and government entities like the State Bar, from lawsuits for money damages unless the immunity has been waived. See, e.g., Reata Constr. Corp. v. City of Dallas, 197 S.W.3d 371, 374 (Tex. 2006).

AFFIRMATIVE CLAIMS PURSUANT TO THE TEXAS DECEPTIVE TRADE PRACTICES ACT 24. Plaintiff Robins incorporates the aforementioned as if set forth fully herein. He also pursues claims against the Defendants pursuant to the Texas Deceptive Trade Practices Act. The Defendants have engaged in false, misleading & deceptive practices at Plaintiff Robins’ expense, and that of the general public.

25. The DTPA mandates that the law “shall be liberally construed and applied to promote its underlying purposes, some of which are to protect consumers against false, misleading, and deceptive business practices, unconscionable actions, and breaches of warranty. Others are to provide efficient and economical procedures to secure such protection.” Tex. Bus. & Com. Code § 17.44(a) (emphasis added).

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26. The DTPA declares unlawful any “[f]alse, misleading, or deceptive acts or practices in the conduct of any trade or commerce,” Tex. Bus. & Com. Code § 17.46(a), which it defines as including, inter alia¸ “causing confusion or misunderstanding as to the source, sponsorship, approval, or certification of goods or services,” id. § 17.46(b)(2), “representing that goods or services have sponsorship, approval, characteristics, ingredients, uses, benefits, or quantities which they do not have or that a person has a sponsorship, approval, status, affiliation, or connection which the person does not,” id. § 17.46(b)(5), “advertising goods or services with intent not to sell them as advertised,” id. § 17.46(b)(9), and “failing to disclose information concerning goods or services which was known at the time of the transaction if such failure to disclose such information was intended to induce the consumer into a transaction into which the consumer would not have entered had the information been disclosed,” id. § 17.46(b)(24).

27. Texas Bus. & Com. Code § 17.45(1) defines “goods” as “tangible chattels or real property purchased or leased for use.” See also United Postage Corp. v. Kammeyer, 581 S.W.2d 716, 721 (Tex. Civ. App.—Dallas 1979) (“tangible chattels” are “those items of personal property which may be seen, weighed, measured, felt or touched.”).

28. Texas Bus. & Com. Code § 17.45(2) defines “services” as “work, labor, or service purchased or leased for use, including services furnished in connection with the sale or repair of goods.” See also Riverside Nat’l Bank v. Lewis, 603 S.W.2d 169, 174 (Tex. 1980) (“services” means “action or use that furthers some end or purpose: conduct or performance that assists or

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benefits someone or something: deeds useful or instrumental toward some object.”).

29. Texas Bus. & Com. Code § 17.45(6) defines “trade” and “commerce” as “the advertising, offering for sale, sale, lease, or distribution of any good or service, of any property, tangible or intangible, real, personal, or mixed, and any other article, commodity, or thing of value, wherever situated, and shall include any trade or commerce directly or indirectly affecting the people of this state.”

30. The Texas Bar defendants made various misrepresentations & nondisclosures which ultimately profited them but substantially harmed Plaintiff Robins. Texas Bus. & Com. Code § 17.46(b)(24) provides that “false, misleading, or deceptive acts or practices” includes “failing to disclose information concerning goods or services which was known at the time of the transaction if such failure to disclose such information was intended to induce the consumer into a transaction into which the consumer would not have entered had the information been disclosed.”

31. The Texas Bar defendants have engaged in various transgressions that constitute deceptive trade practices acts. The following list is not allinclusive , as discovery has not gotten underway in this dispute. In the mean time, though, they have represented that they take precautions for the bar members’ benefit which they do not. They have also held themselves out as consistently making an effort to communicate what their interpretations of (conveniently vague) ethics rules actually require, when they do not. Additionally, they do not even attempt to comply sufficiently with religious freedom requirements imposed on them by statute, even as they do not readily (or otherwise) disclose that they will not comply. Furthermore, they

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have purported to be in compliance with applicable laws when, as the 5 th Circuit in McDonald v. Longley demonstrated, they have been far from it. Meanwhile they falsely represent in writing that they cannot resolve a client’s fee dispute with a member attorney, even as they nevertheless meddle, interfere and subvert such a process in lieu of offering the legally required mediation of grievances (especially when both sides requested a peaceful, nonlitigious resolution). They also boast being a source of attorney self-rule, only for the opposite to emerge after years of membership persistence seeking precisely that. Additionally, they generate and provide guidance materials which they reject when it suits their profit-seeking, dissent-stifling, intimidating purposes. All Texans suffer either directly or indirectly from such predatory misdeeds. These transgressions directly and adversely affected Plaintiff Robins in ways for which he seeks redress, plus damages & attorney’s fees. Admittedly the Defendants deserve the 60 day period contemplated in the statute to try to come into compliance… Meanwhile though:

JURISDICTION & VENUE 32. This Court has jurisdiction over this case pursuant to, for example, CPRC §110 as the Plaintiff’s claims involve encroachments upon his rights here in Texas in violation of Texas’ statutory authority.

33. Venue is proper here, as well, because a substantial part of the events or omissions giving rise to the Plaintiff’s claims occurred and continue to occur in Harris County, Texas. Venue is also proper because the Plaintiff lives in Harris County.

34. Houston also happens to be where the Texas Bar’s very substantial facility at 4801 Woodway Dr #315w, Houston, TX 77056

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remains located. The bar defendants required Plaintiff Robins to endure a near 5 hour deposition there regarding this dispute, in fact.

PRAYER FOR RELIEF

35. The Bar defendants should be held accountable and be compelled to compensate Plaintiff Robins including with immediately and enduringly ceasing with maintaining its relevant sanctions against him (disbarment for a first time offender, who had never previously been prosecuted for anything by any state bar during his approximately 30 year career, and who has also never been convicted of any crime or even a traffic offense). The Defendants should also be compelled to make financial reparations including costs and attorney’s fees available to Plaintiff Robins, as the relevant statutory provisions actually or potentially require. Plaintiff Robins previously had an ethically spotless bar ethics record.

WHEREFORE, Plaintiff Robins prays that this Court please issue the

following relief:

a. A declaratory judgment requiring the bar defendants to reverse the Texas Bar’s relevant disciplinary actions against him.

b. An order and judgment granting reasonable attorneys’ fees, damages and costs as well as any other relief that this Court deems just and proper.

PLAINTIFF’S SWORN DECLARATION

“My name is Richard Robins. I am over the age of eighteen years old, and am of sound mind. I have never been convicted of a misdemeanor or felony. I am fully competent to attest to all of the facts

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set forth in this sworn declaration and accompanying lawsuit as I have personal knowledge regarding them. I declare under penalty of perjury that the facts stated in this lawsuit are true & correct, to the best of my knowledge.

Executed on February 10th, 2025.”

Respectfully submitted,

Rich Robins (Pro se Plaintiff) 2450L ouisiana St. #400-155 Houston, TX 77006-2380 Rich@RichRobins.com Tel. 832-350-1030

____________________________

No. 15-25-00144-CV

CERTIFICATE OF SERVICE

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I do hereby certify that a true and correct copy of the above and foregoing Appellant’s 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 September 19th, 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

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.

Envelope ID: 105865622 Filing Code Description: Letter Filing Description: Opposition Status as of 9/22/2025 7:28 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Michael Graham 24113581 Michael.Graham@TEXASBAR.COM 9/19/2025 11:57:05 PM SENT