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

ACCEPTED
15-25-00144-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
10/20/2025 11:57 PM
CHRISTOPHER A. PRINE
CLERK
No. 15-25-00144-CV
FILED IN
15th COURT OF APPEALS
IN THE AUSTIN, TEXAS
10/20/2025 11:57:18 PM
15th COURT OF APPEALS CHRISTOPHER A. PRINE
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
___________________________________________________________

APPELLANT’S 1st MOTION FOR AN EXTENSION

___________________________________________________________

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 1st MOTION FOR AN EXTENSION

___________________________________________________________

October 20th, 2025

Appellant Richard Robins hereby files this 1st motion for a deadline
extension to file the opening brief.

A. Introduction

1. The Appellee (Plaintiff at the trial court level) is 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 files this first motion for an
extension.

B. Facts

4. Appellant Robins has worked earnestly to try to understand the
15th Court of Appeals’ reported position that it lacks jurisdiction for matters
against the State Bar of Texas even in the wake of relatively recent
jurisprudence.

5. Appellant Robins would prefer to know which appellate court will
be the audience for his upcoming brief before he finishes drafting it

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accordingly and submits it. The identity of the destined appellate court is
not yet clear, though. Appellant Robins hopes that either the 15 th Court of
Appeals will decide to keep this appeal or to involve the Supreme Court of
Texas so that that Court can rightly affirm this appeal’s destination in the
15th Court of Appeals.

6. The appellant’s brief was originally due on September 29th, 2025
with the 15 day post-deadline extension date being October 14th, 2025. By
that date, however, the 15th Court of Appeals issued a deadline of until
October 20th, 2025 to, among other options, file a motion for an extension.
Appellant Robins seeks a sua sponte stay from the Court while it decides
what it will do regarding its (surprising) decision not to grant this case
jurisdiction. That is what the Court did in Baumgardner v. Brazos River
Auth., No. 15-24-00070-CV, 2025 WL 4771427 (Tex. App.—Austin June
27, 2025, no pet. h.). In the alternative, Appellant Robins seeks an
extension of until November 20th, 2025.

C. Argument & Authorities

7. The Court of Appeals has the authority to postpone the relevant
filing deadline pursuant to TRAP 10.5 (b) & 38.6(d).

8. This first request for an extension to file the appellate brief is
sought not to cause undue delay but rather to be able to improve the brief,
for the benefit of all who decide to read it.

9. Appellant Robins also mentions that considerable caselaw exists
to entitle appellants to extensions under at least some circumstances. Such
caselaw includes Jones v. City of Houston, authored by (then) Justice
Nathan Hecht. Jones v. City of Houston, 976 S.W.2d 676, 677 (1998).
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Permissible if not obligatory circumstances for an extension can include
(but are not limited to) brief-filing, especially when the opposing side is
not unfairly prejudiced by the extension request’s granting. Head v.
Twelfth Ct. of Appeals, 811 S.W. 2d 570, 571 (Tex. 1991). Meanwhile
Appellant Robins has always swiftly approved of any extension request
made by the Appellee (as former counsel Matt Greer can confirm). All of
this makes the motion’s respectfully requested granting seem within the
realm of lawful permissibility, please.

D. Conclusion

10. Pro se appellant Rich Robins hereby files this first motion for an
extension. He invites the Court to issue a stay, sua sponte, like it did in
Baumgardner v. Brazos River Auth., No. 15-24-00070-CV, 2025 WL
4771427 (Tex. App.—Austin June 27, 2025, no pet. h.) while striving for a
final decision as to jurisdiction. In the alternative, an extension of until
November 20th, 2025 is requested, please.

Sincerely submitted:

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

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No. 15-25-00144-CV

CERTIFICATE OF SERVICE

I do hereby certify that a true and correct copy of the above and
foregoing Appellant’s 1st 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 October 20th, 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

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No. 15-25-00144-CV

CERTIFICATE OF CONFERENCE

Appellant Robins e-mailed Appellee’s counsel Michael Graham about a 1 st
deadline extension request on October 14th, 2025. Appellant Robins
received no opposition from opposing counsel, who did not respond.
Perhaps that is because Appellant Robins mentioned in that e-mailed
conferencing that there seems to be a customary automatic granting of the
first extension request in appellate courts here in Texas. At any rate, the
motion is unopposed.

Sincerely submitted:

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

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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.

Rich Robins on behalf of Rich Robins
Bar No. 00789589
rich@RichRobins.com
Envelope ID: 107074950
Filing Code Description: Motion
Filing Description: Appellant's 1st motion for an extension or a stay, sua
sponte
Status as of 10/21/2025 7:11 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Michael Graham 24113581 Michael.Graham@TEXASBAR.COM 10/20/2025 11:57:18 PM SENT