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

Opinion

ACCEPTED 15-25-00044-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 4/23/2025 12:41 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 4/23/2025 12:41:06 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 FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF

TO THE HONORABLE JUSTICES: Appellant, Ugalahi Offoboche, files this Unopposed 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 April 25, 2025.

2. This is the Appellant’s first 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 May 25, 2025.

4. Good cause for granting this motion is that counsel’s workload and pre-existing

time sensitive commitments prevent the timely completion of the brief by the

deadline including:

a. Trial Preparation in Cause No. CC-24-05436-A Gillespie v. Shore before the

County Court at Law No. 1 set for Monday April 28, 2025 and hearing set for

April 25, 2025;

b. Responding to four dispositive motions in Tarmo v. Noseff et al, No. 4:25-cv-

00109 before the Eastern District of Texas;

c. Preparing time sensitive immigration applications for several individuals; and

d. Preparing pleadings and completing probate investigations as an ad litem for

the Statutory Probate Courts in Dallas for appointments made between

October 2024 and February 2025.

5. As a result of the above obligations and more, Counsel is unable to reach the brief

on April 25, 2025, as scheduled and must seek this extension.

6. Appellees are not opposed and will not suffer any prejudice from the deadline

being extended by 30 days up to and including April 25, 2025.

7. This motion is filed, not for delay, but in the interest of justice so that the Court

may hear this case on the merits.

Page 2 of 4 8. All supporting facts are made from the personal knowledge of appellant who is

also an attorney and are true and correct.

For the above reasons, Appellant humbly requests that this Motion be granted

extending the time for them to file appellant’s brief by 30 days, from April 25, 2025,

up to and including May 25, 2025.

Dated this 23rd day of April 2025.

Respectfully Submitted:

U. A. C. OFFOBOCHE LAW FIRM

/s/ Ugalahi Agbo Claire Offoboche Ugalahi Agbo Claire Offoboche State Bar No. 24068619 675 Town Square Blvd., Bldg. 1A, Ste. 200, Garland, TX 75040 Ph: 469-315-0358 Fax: 214-853-5708 ugy@uacoffobochelaw.com 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 has indicated that the

Motion is unopposed.

/s/ Ugalahi Agbo Claire Offoboche Ugalahi Agbo Claire Offoboche Page 3 of 4 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 bdavis@mssattorneys.com kbarry@mssattorneys.com 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 ugy@uacoffobochelaw.com Envelope ID: 99988310 Filing Code Description: Motion Filing Description: UNOPPOSED APPELLANT'S FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF Status as of 4/23/2025 1:42 PM CST

Associated Case Party: Ugalahi Offoboche

Name BarNumber Email TimestampSubmitted Status

Ugalahi UgyOffoboche ugy@uacoffobochelaw.com 4/23/2025 12:41:06 PM SENT

Associated Case Party: Collin County, Texas

Robert J.Davis bdavis@mssattorneys.com 4/23/2025 12:41:06 PM SENT

Associated Case Party: Collin County Sheriff's Deputy Mounger

Kyle T.Barry kbarry@mssattorneys.com 4/23/2025 12:41:06 PM SENT

Associated Case Party: Collin County Sheriff's Deputy Watson

Kyle T.Barry kbarry@mssattorneys.com 4/23/2025 12:41:06 PM SENT

Associated Case Party: Collin County Sheriff's Deputy McMillan

Robert J.Davis bdavis@mssattorneys.com 4/23/2025 12:41:06 PM SENT

Associated Case Party: Former Collin County Chief Deputy Constable Rumfield 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 ugy@uacoffobochelaw.com Envelope ID: 99988310 Filing Code Description: Motion Filing Description: UNOPPOSED APPELLANT'S FIRST MOTION FOR EXTENSION OF TIME TO FILE BRIEF Status as of 4/23/2025 1:42 PM CST

Associated Case Party: Former Collin County Chief Deputy Constable Rumfield

Robert J.Davis bdavis@mssattorneys.com 4/23/2025 12:41:06 PM SENT