Sammy Tawakkol v. Sheila Vasquez, in Her Official Capacity as Manager of the Texas Department of Public Safety- Sex Offender Registration Bureau; And Steven McCraw, in His Official Capacity as Director of the Texas Department of Public Safety

Opinion

ACCEPTED 15-25-00009-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 3/31/2025 2:39 PM Court of Appeals Number: 15-25-00009-CV CHRISTOPHER A. PRINE CLERK Trial Court Number: D-1-GN-24-001566 FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS _________________ 3/31/2025 2:39:32 PM CHRISTOPHER A. PRINE IN THE COURT OF APPEALS Clerk FOR THE FIFTEENTH JUDICIAL DISTRICT OF TEXAS __________________

SAMMY TAWKKOL, Appellant

vs.

SHEILA VASQUEZ, in her Official Capacity as Manager of the Texas Department of Public Safety -Sex Offender Registration Bureau;

and STEVEN McCRAW, in his Official Capacity as Director of the Texas Department of Public Safety

Appellees ___________________

ON APPEAL FROM THE 200th JUDICIAL DISTRICT COURT, TRAVIS COUNTY, TEXAS THE HONORABLE JAMES CARROLL, J., PRESIDING ____________________

APPELLANT’S UNOPPOSED FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF ____________________

TO THE HONORABLE CHIEF JUSTICE AND ASSOCIATE JUSTICES

OF THE FIFTEENTH COURT OF APPEALS:

1 COMES NOW Sammy Tawakkol, Appellant in the above captioned

and numbered appeal, and, pursuant to Rules 9 and 10.5(b) of the Texas

Rules of Appellate Procedure, files this Unopposed First Motion for

Extension of Time to File Appellant’s Brief, and in this connection would

respectfully show unto the Court of Appeals as follows:

1.

The Appellant’s Brief on this appeal is due Monday, April 7, 2025.

Since the filing of the Reporter’s Record in this case on March 6, 2025, and

the filing of the District Clerk’s Record on March 7, 2025, Appellant’s

counsel has been unexpectedly submerged while fulfilling his trial and

appellate obligations in other pending cases. These other obligations, in both

size and complexity, have been extraordinary in relation to undersigned

counsel’s usual workload; and they have rendered it impossible for

Appellant’s counsel to adequately prepare and file Appellant’s brief within

the time previously allotted for this appeal (30 days). The Appellant does not

anticipate any further extension of time will be necessary or requested by

Appellant. Due to the aforementioned circumstances, Appellant moves the

Court of Appeals to grant him an extension of time to file Appellant’s Brief,

for a period of 30 days, to and including Tuesday, May 6, 2025.

2 2.

As reflected by the certificate of conference below, this motion is

unopposed by all Appellees on this appeal.

WHEREFORE, PREMISES CONSIDERED, the Appellant prays this

Unopposed First Motion for Extension of Time to File Appellant’s Brief will

be granted as requested herein.

/s/Richard Gladden State Bar No. 07991330 Law Office of Richard Gladden 1204 West University Dr., Ste. 307 Denton, Texas 76201 940/323-9300 (Voice) 940/539-0093 (Fax) richscot1@hotmail.com (email)

CERTIFICATE OF CONFERENCE

This is to certify that on Monday, March 31, 2025, I

communicated by email with the Attorney of Record for all Appellees on

this appeal, Assistant Attorney General of Texas Christopher Lindsey, and

that during the said conference Mr. Lindsey authorized me to inform the

Fifteenth Court of appeals of Texas that the Appellees do not oppose this

motion.

/s/Richard Gladden

3 CERTIFICATE OF SERVICE

This is to certify that a true and correct copy of this brief was served

by electronic service using the TexFile system, on the Attorney of Record

for all Appellees on this appeal, Christopher Lindsey, by use of his email

address registered on the said filing system, on this 31st day of March, 2025,

in accordance with Rule 9.5 of the Texas Rules of Appellate Procedure.

/s/Richard Gladden

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.

Richard Gladden Bar No. 07991330 richscot1@hotmail.com Envelope ID: 99085916 Filing Code Description: Motion Filing Description: Appellant's First Motion for an Extension of Time to File Brief Status as of 3/31/2025 3:11 PM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Richard Gladden richscot1@hotmail.com 3/31/2025 2:39:32 PM SENT

Christopher Lindsey 24065628 Christopher.Lindsey@oag.texas.gov 3/31/2025 2:39:32 PM SENT

Terri Sparks terri.with.gladdenlaw@gmail.com 3/31/2025 2:39:32 PM SENT