ACCEPTED 15-25-00044-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 9/11/2025 8:51 AM 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 9/11/2025 8:51:54 AM 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’ RESPONSE TO APPELLANT’S MOTION FOR FIVE DAYS’ EXTENSION OF TIME TO COMPLETE AND FILE REPLY BRIEF AND FOR LEAVE TO FILE CORRECTED 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, and file their
RESPONSE TO APPELLEE’S MOTION FOR FIVE DAYS’ EXTENSION OF TIME TO COMPLETE AND FILE
REPLY BRIEF AND FOR LEAVE TO FILE CORRECTED BRIEF, and would show the Court as follows:
APPELLEES’ RESPONSE TO APPELLANT’S MOTION FOR FIVE DAY EXTENSION, et. al. PAGE 1 T:\233\1\1600\71458 Brown\Subpoenas 2024\Appeal\County\Appellees Response to Extension to File Reply.wpd I. Appellant’s misstatement of material facts and refusal to correct same is basis for Appellants’ inability to agree to further “corrections” to Appellant’s Brief
Appellant Ugalahi Offoboche, the sanctioned attorney who is representing herself herein,
has already twice submitted her Brief. See, APPELLANT’S BRIEF, submitted June 24, 2025, and
APPELLANT’S AMENDED BRIEF, submitted June 25, 2025. She now seeks to file what she entitles
her APPELLANT’S CORRECTED (AMENDED) BRIEF as well as seeking a five day extension to file her
Reply Brief.
It is not the requested extension to file her Reply Brief which causes Appellees’ consternation
- it is Appellant’s refusal to correct material mis-statements in her briefing to this Court about her
and her clients role in the Public Information Act requests and resulting Attorney General Opinions.
Appellant represents to this Court that “there is nothing in the attached opinion rulings that shows
appellant was the requestor or was attempting to obtain law enforcement records” See, i.e.
APPELLANT’S AMENDED BRIEF, p. 15. Disappointingly, Appellant certainly knows this is not correct.
See, APPENDIX EX.’S 1-4 attached to BRIEF OF APPELLEES regarding the series of Public Information
Act requests and resulting Texas Attorney General decisions directly related to/from Appellant
and/or her clients. When contacted by Appellant for a conference on her motion, Appellant was
asked to correct her misstatements but she refused. A copy of emails is attached as Exhibit No. 1.
Appellees do not oppose an extension for Appellant to file a Reply Brief but do oppose
Appellant’s ongoing mis-statement of facts to this Court and Appellant’s efforts to minimize briefing
failures and misleading case citations and holdings to this Court. See, i.e., Appellant’s citation to
In re J.M.1 for a holding which does not appear in the case.
1 cited in APPELLANT’S AMENDED BRIEF, p. 41. Appellant’s misrepresentations about the In re J.M. case are discussed in BRIEF OF APPELLEES, p. 11-12.
APPELLEES’ RESPONSE TO APPELLANT’S MOTION FOR FIVE DAY EXTENSION, et. al. PAGE 2 T:\233\1\1600\71458 Brown\Subpoenas 2024\Appeal\County\Appellees Response to Extension to File Reply.wpd II. 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 of Appeals affirm
the January 30, 2025, FINAL JUDGMENT, PROTECTIVE ORDER, AND ORDER OF SANCTIONS AGAINST
COUNSEL UGALAHI OFFOBOCHE; and that Appellees have such other and further relief to which they
may show themselves justly 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
CERTIFICATE OF SERVICE
This is to certify that, pursuant to Tex. R. App. P. 9.5, on this the 10th day of September, 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’ RESPONSE TO APPELLANT’S MOTION FOR FIVE DAY EXTENSION, et. al. PAGE 3 T:\233\1\1600\71458 Brown\Subpoenas 2024\Appeal\County\Appellees Response to Extension to File Reply.wpd From: Ugy Offoboche Sent: Friday, September 5, 2025 5:19 PM To: Bob Davis Cc: Kyle Barry Subject: Re: Conference Requirement: Corrected Brief
LOL...okay.
With Kind Regards,
Ugalahi Ugy Offoboche, Esq. Managing Attorney U. A. C. OFFOBOCHE LAW FIRM 469-315-0358 (Direct) 214-853-5708 (Fax) ugy@uacoffobochelaw.com www.uacoffobochelaw.com "Dedicated & Thorough"
"A man convinced against his will is of the same opinion still." Anonymous "Forgiveness is only beneficial if given to one who does not deserve it." Clairecut
The content of this communication may be confidential and/or proprietary to U.A.C. Offoboche Law Firm. The information transmitted herein is intended only for use by the individual(s) or entity(ies) to which it is addressed and may be information that is legally privileged, confidential and/or exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are hereby notified that any review, transmission or retransmission, dissemination, distribution, copying or other use of, or taking of any action in reliance upon this information is strictly prohibited. If you have received this communication in error, please notify the sender immediately by email and delete the communication.
On Fri, Sep 5, 2025 at 5:13 PM Bob Davis wrote:
Yes
Robert J. Davis
Partner
Matthews, Shiels, Knott, Eden, Davis & Beanland, L.L.P.
8131 LBJ Freeway, Suite 700
Dallas, Texas 75251
(972) 234-3400 From: Ugy Offoboche Sent: Friday, September 5, 2025 5:12 PM To: Bob Davis Cc: Kyle Barry Subject: Re: Conference Requirement: Corrected Brief
That statement is false! I will be requesting 5-days extension to file my reply brief. Are you opposed?
Ugalahi Ugy Offoboche, Esq.
Managing Attorney U. A. C. OFFOBOCHE LAW FIRM
469-315-0358 (Direct) 214-853-5708 (Fax) ugy@uacoffobochelaw.com www.uacoffobochelaw.com "Dedicated & Thorough"
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ACCEPTED 15-25-00044-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 9/11/2025 8:51 AM 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 9/11/2025 8:51:54 AM 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’ RESPONSE TO APPELLANT’S MOTION FOR FIVE DAYS’ EXTENSION OF TIME TO COMPLETE AND FILE REPLY BRIEF AND FOR LEAVE TO FILE CORRECTED 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, and file their
RESPONSE TO APPELLEE’S MOTION FOR FIVE DAYS’ EXTENSION OF TIME TO COMPLETE AND FILE
REPLY BRIEF AND FOR LEAVE TO FILE CORRECTED BRIEF, and would show the Court as follows:
APPELLEES’ RESPONSE TO APPELLANT’S MOTION FOR FIVE DAY EXTENSION, et. al. PAGE 1 T:\233\1\1600\71458 Brown\Subpoenas 2024\Appeal\County\Appellees Response to Extension to File Reply.wpd I. Appellant’s misstatement of material facts and refusal to correct same is basis for Appellants’ inability to agree to further “corrections” to Appellant’s Brief
Appellant Ugalahi Offoboche, the sanctioned attorney who is representing herself herein,
has already twice submitted her Brief. See, APPELLANT’S BRIEF, submitted June 24, 2025, and
APPELLANT’S AMENDED BRIEF, submitted June 25, 2025. She now seeks to file what she entitles
her APPELLANT’S CORRECTED (AMENDED) BRIEF as well as seeking a five day extension to file her
Reply Brief.
It is not the requested extension to file her Reply Brief which causes Appellees’ consternation
- it is Appellant’s refusal to correct material mis-statements in her briefing to this Court about her
and her clients role in the Public Information Act requests and resulting Attorney General Opinions.
Appellant represents to this Court that “there is nothing in the attached opinion rulings that shows
appellant was the requestor or was attempting to obtain law enforcement records” See, i.e.
APPELLANT’S AMENDED BRIEF, p. 15. Disappointingly, Appellant certainly knows this is not correct.
See, APPENDIX EX.’S 1-4 attached to BRIEF OF APPELLEES regarding the series of Public Information
Act requests and resulting Texas Attorney General decisions directly related to/from Appellant
and/or her clients. When contacted by Appellant for a conference on her motion, Appellant was
asked to correct her misstatements but she refused. A copy of emails is attached as Exhibit No. 1.
Appellees do not oppose an extension for Appellant to file a Reply Brief but do oppose
Appellant’s ongoing mis-statement of facts to this Court and Appellant’s efforts to minimize briefing
failures and misleading case citations and holdings to this Court. See, i.e., Appellant’s citation to
In re J.M.1 for a holding which does not appear in the case.
1 cited in APPELLANT’S AMENDED BRIEF, p. 41. Appellant’s misrepresentations about the In re J.M. case are discussed in BRIEF OF APPELLEES, p. 11-12.
APPELLEES’ RESPONSE TO APPELLANT’S MOTION FOR FIVE DAY EXTENSION, et. al. PAGE 2 T:\233\1\1600\71458 Brown\Subpoenas 2024\Appeal\County\Appellees Response to Extension to File Reply.wpd II. 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 of Appeals affirm
the January 30, 2025, FINAL JUDGMENT, PROTECTIVE ORDER, AND ORDER OF SANCTIONS AGAINST
COUNSEL UGALAHI OFFOBOCHE; and that Appellees have such other and further relief to which they
may show themselves justly 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
CERTIFICATE OF SERVICE
This is to certify that, pursuant to Tex. R. App. P. 9.5, on this the 10th day of September, 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’ RESPONSE TO APPELLANT’S MOTION FOR FIVE DAY EXTENSION, et. al. PAGE 3 T:\233\1\1600\71458 Brown\Subpoenas 2024\Appeal\County\Appellees Response to Extension to File Reply.wpd From: Ugy Offoboche Sent: Friday, September 5, 2025 5:19 PM To: Bob Davis Cc: Kyle Barry Subject: Re: Conference Requirement: Corrected Brief
LOL...okay.
With Kind Regards,
Ugalahi Ugy Offoboche, Esq. Managing Attorney U. A. C. OFFOBOCHE LAW FIRM 469-315-0358 (Direct) 214-853-5708 (Fax) ugy@uacoffobochelaw.com www.uacoffobochelaw.com "Dedicated & Thorough"
"A man convinced against his will is of the same opinion still." Anonymous "Forgiveness is only beneficial if given to one who does not deserve it." Clairecut
The content of this communication may be confidential and/or proprietary to U.A.C. Offoboche Law Firm. The information transmitted herein is intended only for use by the individual(s) or entity(ies) to which it is addressed and may be information that is legally privileged, confidential and/or exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are hereby notified that any review, transmission or retransmission, dissemination, distribution, copying or other use of, or taking of any action in reliance upon this information is strictly prohibited. If you have received this communication in error, please notify the sender immediately by email and delete the communication.
On Fri, Sep 5, 2025 at 5:13 PM Bob Davis wrote:
Yes
Robert J. Davis
Partner
Matthews, Shiels, Knott, Eden, Davis & Beanland, L.L.P.
8131 LBJ Freeway, Suite 700
Dallas, Texas 75251
(972) 234-3400 From: Ugy Offoboche Sent: Friday, September 5, 2025 5:12 PM To: Bob Davis Cc: Kyle Barry Subject: Re: Conference Requirement: Corrected Brief
That statement is false! I will be requesting 5-days extension to file my reply brief. Are you opposed?
Ugalahi Ugy Offoboche, Esq.
Managing Attorney U. A. C. OFFOBOCHE LAW FIRM
469-315-0358 (Direct) 214-853-5708 (Fax) ugy@uacoffobochelaw.com www.uacoffobochelaw.com "Dedicated & Thorough"
"A man convinced against his will is of the same opinion still." Anonymous "Forgiveness is only beneficial if given to one who does not deserve it." Clairecut
The content of this communication may be confidential and/or proprietary to U.A.C. Offoboche Law Firm. The information transmitted herein is intended only for use by the individual(s) or entity(ies) to which it is addressed and may be information that is legally privileged, confidential and/or exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are hereby notified that any review, transmission or retransmission, dissemination, distribution, copying or other use of, or taking of any action in reliance upon this information is strictly prohibited. If you have received this communication in error, please notify the sender immediately by email and delete the communication.
On Fri, Sep 5, 2025 at 5:05 PM Bob Davis wrote:
Misstatements about your and your clients role in the Public Information Act requests and corresponding AG opinions. Robert J. Davis
(972) 234-3400
From: Ugy Offoboche Sent: Friday, September 5, 2025 5:05 PM To: Bob Davis Cc: Kyle Barry Subject: Re: Conference Requirement: Corrected Brief
They were no misstatements only human error. I'll let the appellate Court know that you are opposed.
469-315-0358 (Direct) 214-853-5708 (Fax) ugy@uacoffobochelaw.com www.uacoffobochelaw.com "Dedicated & Thorough"
"A man convinced against his will is of the same opinion still." Anonymous "Forgiveness is only beneficial if given to one who does not deserve it." Clairecut
The content of this communication may be confidential and/or proprietary to U.A.C. Offoboche Law Firm. The information transmitted herein is intended only for use by the individual(s) or entity(ies) to which it is addressed and may be information that is legally privileged, confidential and/or exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are hereby notified that any review, transmission or retransmission, dissemination, distribution, copying or other use of, or taking of any action in reliance upon this information is strictly prohibited. If you have received this communication in error, please notify the sender immediately by email and delete the communication.
On Fri, Sep 5, 2025, 5:00 PM Bob Davis wrote:
We are opposed. I would also urge you to correct the misstatements about you and your clients’ role in the Public Information Act requests.
From: Ugy Offoboche Sent: Thursday, September 4, 2025 7:03 PM To: Bob Davis ; Kyle Barry Subject: Conference Requirement: Corrected Brief
Messes David and Barry,
I have read your brief and note the omissions which I had earlier notified the court about in my motion for leave when I was unable to see to correct those. I need to correct the page number for the Medlin case, which should be 285. I also need to include the Medlin case on which I was relying and quoted but omitted to cite after the J. M. case. I would like to file a corrected brief to include the missing page number and to include the Medlin case where it was omitted. I will not be including new arguments in the corrected brief. Will you oppose my filing the corrected brief?
If no, after correcting the brief then I will file a reply brief. Does this work for you? With Kind Regards,
469-315-0358 (Direct) 214-853-5708 (Fax) ugy@uacoffobochelaw.com www.uacoffobochelaw.com "Dedicated & Thorough"
"A man convinced against his will is of the same opinion still." Anonymous "Forgiveness is only beneficial if given to one who does not deserve it." Clairecut
The content of this communication may be confidential and/or proprietary to U.A.C. Offoboche Law Firm. The information transmitted herein is intended only for use by the individual(s) or entity(ies) to which it is addressed and may be information that is legally privileged, confidential and/or exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are hereby notified that any review, transmission or retransmission, dissemination, distribution, copying or other use of, or taking of any action in reliance upon this information is strictly prohibited. If you have received this communication in error, please notify the sender immediately by email and delete the communication. 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: 105480624 Filing Code Description: Response Filing Description: APPELLEES??? RESPONSE TO APPELLANT???S MOTION FOR FIVE DAYS??? EXTENSION OF TIME TO COMPLETE AND FILE REPLY BRIEF AND FOR LEAVE TO FILE CORRECTED BRIEF Status as of 9/11/2025 8:56 AM CST
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Ugalahi UgyOffoboche ugy@uacoffobochelaw.com 9/11/2025 8:51:54 AM SENT
Robert J.Davis bdavis@mssattorneys.com 9/11/2025 8:51:54 AM SENT
Robert J.Davis bdavis@mssattorneys.com 9/11/2025 8:51:54 AM SENT
Robert J.Davis bdavis@mssattorneys.com 9/11/2025 8:51:54 AM SENT
Kyle T.Barry kbarry@mssattorneys.com 9/11/2025 8:51:54 AM SENT
Kyle T.Barry kbarry@mssattorneys.com 9/11/2025 8:51:54 AM SENT