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

Court of Appeals of Texas·Decided July 17, 2025·No. 15-25-00044-CV·Published

Opinion

ACCEPTED 15-25-00044-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 7/17/2025 2:04 PM CAUSE NO. 15-25-00044-CV CHRISTOPHER A. PRINE CLERK IN THE COURT OF APPEALS FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS FOR THE FIFTEENTH DISTRICT OF TEXAS 7/17/2025 2:04:21 PM CHRISTOPHER A. PRINE AUSTIN, TEXAS Clerk

________________________________________________________________________

UGALAHI OFFOBOCHE Appellant

VS.

COLLIN COUNTY, TEXAS, COLLIN COUNTY SHERIFF’S DEPUTIES MOUNGER, WATSON, McMILAN AND FORMER COLLIN COUNTY CHIEF DEPUTY CONSTABLE RUMFIELD

Appellees

________________________________________________________________________

Appeal from Cause No. 429-08578-2024, 429TH Judicial District Court, Collin County, Texas, The Honorable Jill Willis, Judge Presiding ______________________________________________________________________________

APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF ______________________________________________________________________________

TO THE HONORABLE FIFTEENTH COURT OF APPEALS:

COME NOW Collin County, Texas, Collin County Sheriff’s Deputies Joshua

Mounger, Mark Watson, Lee McMillan and former Collin County Chief Deputy

Constable Mike Rumfield, Appellees herein and movants in the trial court, pursuant to TEX. R.

APP. P 10.5(b) and TEX. R. APP. P 38.6(d), and file their UNOPPOSED MOTION FOR EXTENSION OF

TIME TO FILE BRIEF, and would show the Court as follows:

APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF PAGE 1 T:\233\1\1600\71458 Brown\Subpoenas 2024\Appeal\County\Motion to Extend Brief Deadline.wpd I. Grounds for Extension under Appellate Rules of Procedure 10.5(b)

Texas Rules of Appellate Procedure 10.5(b) describes the contents of a Motion for extension

of time. Thus, Appellees would show as follows.

A. 10.5(b)(1)(A) Current Deadline: July 25, 2025

The current deadline for the filing of Appellees’ Brief is Friday, July 25, 2025.

B. 10.5(b)(1)(B) Length of Extension Sought: Twenty Eight (28) days, until August 22, 2025

Appellees request a twenty eight (28) day extension, until Friday, August 22, 2025.

C. 10.5(b)(1)(C) Facts justifying need for extension

The need for the extension is based on many things, including the intervening Fourth of July

Holiday combined with the particularly busy litigation schedule of Undersigned Counsel, as follows.

First, since the filing of the Appellants’ Amended Brief on June 25, 2025, and through the requested

extension deadline of August 22, 2025, the Undersigned has and or will have participated in three

mediations, conducted eight depositions, appeared in eight hearings in State and/or Federal Court,

prepared four answers in State and/or Federal Court, completed substantial written discovery in

multiple cases, prepared numerous requests for Attorney General decisions, all in addition to a

plethora of other day to day litigation demands.

D. 10.5(b)(1)(D) Previous Extensions: None

This is the first request for any extension by Appellees, although Appellant requested and

received two prior extensions.

APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF PAGE 2 T:\233\1\1600\71458 Brown\Subpoenas 2024\Appeal\County\Motion to Extend Brief Deadline.wpd III. Certificate of Conference

The Undersigned conferred with Appellant’s Counsel on July 16, 2025, and she is

unopposed to the requested extension. Thus, this motion is presented as unopposed.

IV. Prayer for Relief

WHEREFORE, PREMISES CONSIDERED, Appellees Collin County, Texas, Collin

County Sheriff’s Deputies Joshua Mounger, Mark Watson, Lee McMillan and former

Collin County Chief Deputy Constable Mike Rumfield pray that this Honorable Court grant

their UNOPPOSED MOTION FOR EXTENSION OF TIME and allow the Appellees until August 22, 2025,

to file their Reply Brief; and for any such other relief to which they may be entitled.

Respectfully submitted,

By: /s/ Robert J. Davis ROBERT J. DAVIS State Bar No. 05543500 KYLE T. BARRY State Bar No. 24122284 MATTHEWS, SHIELS, KNOTT, EDEN, DAVIS & BEANLAND, L.L.P. 8131 LBJ Freeway, Suite 700 Dallas, Texas 75251 972/234-3400 (office) 972/234-1750 (telecopier bdavis@mssattorneys.com kbarry@mssattorneys.com

ATTORNEY FOR MOVANTS/APPELLEES COLLIN COUNTY, TEXAS, COLLIN COUNTY DEPUTIES JOSHUA MOUNGER, MARK WATSON, LEE McMILLAN, and CHIEF DEPUTY CONSTABLE MICHAEL RUMFIELD

APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF PAGE 3 T:\233\1\1600\71458 Brown\Subpoenas 2024\Appeal\County\Motion to Extend Brief Deadline.wpd CERTIFICATE OF SERVICE

This is to certify that, pursuant to Tex. R. App. P. 9.5, on this the 17th day of July, 2025, a true and correct copy of the foregoing instrument was served upon Appellant’s counsel via e-service.

/s/ Robert J. Davis ROBERT J. DAVIS

APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF PAGE 4 T:\233\1\1600\71458 Brown\Subpoenas 2024\Appeal\County\Motion to Extend Brief Deadline.wpd 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.

Robert Davis on behalf of Robert Davis Bar No. 05543500 bdavis@mssattorneys.com Envelope ID: 103268398 Filing Code Description: Motion Filing Description: APPELLEES??? UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF Status as of 7/17/2025 2:19 PM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Ugalahi UgyOffoboche ugy@uacoffobochelaw.com 7/17/2025 2:04:21 PM SENT

Robert J.Davis bdavis@mssattorneys.com 7/17/2025 2:04:21 PM SENT

Kyle T.Barry kbarry@mssattorneys.com 7/17/2025 2:04:21 PM SENT

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________________________________________________________________________

UGALAHI OFFOBOCHE Appellant

VS.

COLLIN COUNTY, TEXAS, COLLIN COUNTY SHERIFF’S DEPUTIES MOUNGER, WATSON, McMILAN AND FORMER COLLIN COUNTY CHIEF DEPUTY CONSTABLE RUMFIELD

Appellees

________________________________________________________________________

APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF ______________________________________________________________________________

TO THE HONORABLE FIFTEENTH COURT OF APPEALS:

COME NOW Collin County, Texas, Collin County Sheriff’s Deputies Joshua

Mounger, Mark Watson, Lee McMillan and former Collin County Chief Deputy

Constable Mike Rumfield, Appellees herein and movants in the trial court, pursuant to TEX. R.

APP. P 10.5(b) and TEX. R. APP. P 38.6(d), and file their UNOPPOSED MOTION FOR EXTENSION OF

TIME TO FILE BRIEF, and would show the Court as follows:

Texas Rules of Appellate Procedure 10.5(b) describes the contents of a Motion for extension

of time. Thus, Appellees would show as follows.

A. 10.5(b)(1)(A) Current Deadline: July 25, 2025

The current deadline for the filing of Appellees’ Brief is Friday, July 25, 2025.

B. 10.5(b)(1)(B) Length of Extension Sought: Twenty Eight (28) days, until August 22, 2025

Appellees request a twenty eight (28) day extension, until Friday, August 22, 2025.

C. 10.5(b)(1)(C) Facts justifying need for extension

The need for the extension is based on many things, including the intervening Fourth of July

Holiday combined with the particularly busy litigation schedule of Undersigned Counsel, as follows.

First, since the filing of the Appellants’ Amended Brief on June 25, 2025, and through the requested

extension deadline of August 22, 2025, the Undersigned has and or will have participated in three

mediations, conducted eight depositions, appeared in eight hearings in State and/or Federal Court,

prepared four answers in State and/or Federal Court, completed substantial written discovery in

multiple cases, prepared numerous requests for Attorney General decisions, all in addition to a

plethora of other day to day litigation demands.

D. 10.5(b)(1)(D) Previous Extensions: None

This is the first request for any extension by Appellees, although Appellant requested and

received two prior extensions.

APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF PAGE 2 T:\233\1\1600\71458 Brown\Subpoenas 2024\Appeal\County\Motion to Extend Brief Deadline.wpd III. Certificate of Conference

The Undersigned conferred with Appellant’s Counsel on July 16, 2025, and she is

unopposed to the requested extension. Thus, this motion is presented as unopposed.

IV. Prayer for Relief

WHEREFORE, PREMISES CONSIDERED, Appellees Collin County, Texas, Collin

County Sheriff’s Deputies Joshua Mounger, Mark Watson, Lee McMillan and former

Collin County Chief Deputy Constable Mike Rumfield pray that this Honorable Court grant

their UNOPPOSED MOTION FOR EXTENSION OF TIME and allow the Appellees until August 22, 2025,

to file their Reply Brief; and for any such other relief to which they may be entitled.

Respectfully submitted,

ATTORNEY FOR MOVANTS/APPELLEES COLLIN COUNTY, TEXAS, COLLIN COUNTY DEPUTIES JOSHUA MOUNGER, MARK WATSON, LEE McMILLAN, and CHIEF DEPUTY CONSTABLE MICHAEL RUMFIELD

APPELLEES’ UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF PAGE 3 T:\233\1\1600\71458 Brown\Subpoenas 2024\Appeal\County\Motion to Extend Brief Deadline.wpd CERTIFICATE OF SERVICE

This is to certify that, pursuant to Tex. R. App. P. 9.5, on this the 17th day of July, 2025, a true and correct copy of the foregoing instrument was served upon Appellant’s counsel via e-service.

/s/ Robert J. Davis ROBERT J. DAVIS

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Ugalahi UgyOffoboche ugy@uacoffobochelaw.com 7/17/2025 2:04:21 PM SENT

Robert J.Davis bdavis@mssattorneys.com 7/17/2025 2:04:21 PM SENT

Kyle T.Barry kbarry@mssattorneys.com 7/17/2025 2:04:21 PM SENT

Ugalahi Offoboche v. Collin County, Texas, Collin County Sheriff's Deputies Mounger, Watson, and McMillan and Former Collin County Chief Deputy Constable Rumfield, (Tex. Ct. App. 2025).

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