Whittney Ford v. the University of Texas at Austin

ACCEPTED
15-25-00123-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
8/25/2025 9:59 PM
NO. 15-25-00123-CV CHRISTOPHER A. PRINE
CLERK
In the Fifteenth Court of Appeals FILED IN
15th COURT OF APPEALS
Austin, Texas AUSTIN, TEXAS
8/25/2025 9:59:19 PM
CHRISTOPHER A. PRINE
Clerk
WHITTNEY FORD,
APPELLANT,

v.
THE UNIVERSITY OF TEXAS AT AUSTIN AND JIM DAVIS, IN HIS
OFFICIAL CAPACITY AS PRESIDENT OF THE UNIVERSITY OF TEXAS
AT AUSTIN,
APPELLEES.

Interlocutory Appeal from the 261st Judicial District Court of Travis County, Texas
Trial Court Cause No. D-1-GN-24-002171
The Honorable Maria Cantu Hexsel, Judge Presiding

MOTION TO OBFUSCATE

Whittney Ford
Pro Se
4151 Wellborn Road, Apt#1101A
Bryan, Texas 77801
(979) 264 – 4944
wjacksonford@gmail.com
TO THE HONORABLE FIFTEENTH COURT OF APPEALS:
Comes now Whittney Ford, Appellant, complaining of the admission of Ken
Paxton’s Amended Plea to the Jurisdiction within this appellate record.
On July 17, 2025, Travis County, 261st Judicial District Court, filed an order

granting the plea to the jurisdiction of The University of Texas at Austin in case No.

D-1-GN-24-002171. On July 23, 2025, Travis County accepted my notice of appeal,

and this court noticed the notice on July 24, 2025. Since my appeal is pursuant to

Tex. Civ. P. & Rem. Code § 51.014(a)(8), all proceedings in the trial court were

stayed on July 23, 2025. Tex. Civ. P. & Rem. Code § 51.014(b). Therefore, Ken

Paxton’s Amended Plea to the Jurisdiction filed in the trial courts on July 24, 2025,

was not before the trail court when the interlocutory order was signed, nor when I

appealed it. I believe it to be improper to be included in this appellate record and

request that it be stricken and either entirely whitewashed or blacked out and

obfuscated in its entirety for the duration of this interlocutory appeal. This

obfuscation is to include the Supplemental Clerk’s Record pages 199-199.

Moreover, any pleading by Ken Paxton as a party defendant in D-1-GN-24-002171

I request to be completely obscured from this appellate record, as Ken Paxton and

the Attorney General’s Office is not a party to the interlocutory order appealed from.

I request the supplemental clerk’s records pages 19-24, 100-104, 416-425, and 774-

793 be completely obscured from view during this appeal and most importantly 774-
793 as Ken Paxton and the Office of the Attorney general as party defendants were

not parties to the order appealed from currently.

Dated: 8/25/2025 Respectfully submitted,

By: /s/ Whittney Ford

Whittney Ford
Pro Se
4151 Wellborn Road, Apt#1101A
Bryan, Texas 77801
(979) 264 – 4944
wjacksonford@gmail.com
Certificate of Service
In accordance with Rule 21 of Texas Rules of Civil Procedure, I Whittney Ford
certify that a copy of this Motion To Obfuscate and my Amended Appellate Brief
was served on The University of Texas at Austin and its President through their
counsel, via email, via EFILETEXAS.GOV on August 25, 2025, at the email
addresses below:

Rachel L. Behrendt
Texas Bar No. 24130871
Assistant Attorney General
P.O. Box 12548, Capitol Station
Austin, Texas 78711-2548
Telephone: (512) 475-4112
Facsimile: (512) 320-0667
Rachel.Behrendt@oag.texas.gov

Zachary Rhines
Texas Bar No. 24116957
Special Counsel
Special Litigation Division
Office of the Texas Attorney General
P.O. Box 12548 (MC 009)
Austin, Texas 78711-2548
Telephone: (512) 696-8186
Facsimile: (512) 457-4410
Zachary.Rhines@oag.texas.gov

Attorneys For U.T. Austin and
Its President

/s/ Whittney Ford
Whittney Ford
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.

Envelope ID: 104830644
Filing Code Description: Motion - Exempt
Filing Description: motion_to_strike
Status as of 8/26/2025 9:43 AM CST

Associated Case Party: The University of Texas at Austin

Name BarNumber Email TimestampSubmitted Status

Zachary Rhines 24116957 zachary.rhines@oag.texas.gov 8/25/2025 9:59:19 PM SENT

Martin Cohick 24134042 martin.cohick@oag.texas.gov 8/25/2025 9:59:19 PM SENT

Rachel Behrendt 24130871 rachel.behrendt@oag.texas.gov 8/25/2025 9:59:19 PM SENT

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Wolfgang P.Hirczy de Mino wphdmphd@gmail.com 8/25/2025 9:59:19 PM SENT