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
9/15/2025 11:43 PM
CHRISTOPHER A. PRINE
CLERK
No. 15-25-00144-CV
FILED IN
15th COURT OF APPEALS
IN THE AUSTIN, TEXAS
9/15/2025 11:43:57 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 UNOPPOSED 1st MOTION FOR AN EXTENSION OF
TIME TO FILE A RESPONSE TO THE COURT’S
TRANSFER ADVISORY

___________________________________________________________

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 UNOPPOSED 1st MOTION FOR AN EXTENSION OF
TIME TO FILE A RESPONSE TO TRANSFER ADVISORY

___________________________________________________________

Sept. 15th, 2025

Pro se appellant Rich Robins hereby files this unopposed 1st motion for a
1 month extension of time to file a response to the court’s pending ejection
notice, postponing his response deadline until October 15th, 2025.

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 1st unopposed motion
for a 1 month extension (until Monday, October 15th 2025) to file a
response to the court’s September 5th, 2025 ejection advisory. His
response is presently due today (September 15th, 2025). As further
background, Appellant Robins mentions the following...

B. Facts

4. A one-month extension to file a response is needed for various
reasons. Appellant Robins is trying to understand the 15th Court of

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Appeals’ reported position, which he received on Saturday September 6th,
2025, that it lacks jurisdiction for matters against the State Bar of Texas
even in the wake of relatively recent jurisprudence. His notice of appeal
(Exhibit 1) helps explain why Appellant Robins presently still believes
there is jurisdiction in the 15th Court of Appeals. He seeks to supplement
the contents of his notice after conducting additional research, however.
Appellant Robins also submits Exhibit 2, his trial court petition filed
pursuant to the Texas Deceptive Trade Practices Act against the State Bar
of Texas, et al.

5. Meanwhile, unfortunately Appellant Robins’ computer did not
respond well to a recent upgrade to Windows 11. Microsoft will, in
approximately a couple of weeks, discontinue support for Windows 10.
The Appellant’s computer “passed away” enduringly earlier this month.
Data rescue and transfer to the computer that he subsequently rushed to
purchase remain ongoing. Some of that data is necessary for Appellant
Robins’ further formulating and fortifying his response to the 15th Court of
Appeals’ recent ejection notice.

C. Argument & Authorities

6. The Court of Appeals has the authority to postpone the relevant
filing deadline, pursuant to TRAP 10.5 (b), etc. As the Supreme Court of
Texas has written, rather than disposing of appeals based on harmless
procedural defects, "appellate courts should reach the merits of an appeal
whenever reasonably possible." Horton v. Stovall, 591 S.W.3d 567 (2019);
TRAP 44.3, etc. Honoring our Constitution's promise of open courts and an
opportunity to be heard, we endeavor to consider every appeal on its merits.

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TEX. CONST. art. I § 13; see Sax v. Votteler, 648 S.W.2d 661, 664 (Tex.
1983) ("[Section 13] is, quite plainly, a due process guarantee.").

7. This extension is sought not to cause undue delay but rather to be
able to improve the brief, for the benefit of all who might decide to read it
or even derive behavior guidance from it. In case opposing counsel
believes a response to his upcoming brief is worth filing, Appellant Robins
would not oppose it. To the contrary, Appellant Robins is a fan of saving
everyone time regarding resolving the relevant issues for the benefit of
future generations. The court’s granting Appellant Robins’ deadline
extension request furthers that goal, especially as the 15th Court of Appeals
increasingly finds its way with help potentially from external legal
authorities. Texas needs a uniformity of interpretations of the State Bar of
Texas’ purported ethics rules, arguably more than it needs different state
appellate courts being innovative with its interpretations such that different
interests are served in different appellate regions while attorneys remain
mystified and unduly pressured by in some cases extortionist bar
prosecutors.

8. Appellant Robins also mentions that Texas caselaw embraces the
policy that "an adjudication on the merits is preferred in Texas." Holt
Atherton Indus., Inc. v. Heine, 835 S.W.2d 80, 86 (Tex.1992). Furthermore,
there is Jones v. City of Houston. Jones v. City of Houston, 976 S.W.2d 676,
677 (1998), as well as TRAP 44.3, etc. Permissible if not obligatory
circumstances for such an accommodation 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
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swiftly approved of any extension request made by the Appellee’s employer
(as former state bar 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

9. Pro se appellant Rich Robins hereby files this motion for a one-
month extension (of until October 15th, 2025) to file a substantive response
to the 15th Court of Appeals’ recent ejection notice which it filed on
September 5th, 2025.

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 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 September 15th, 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 the
abovementioned deadline extension request on September 15th, 2025 and
learned that it 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.

Envelope ID: 105617158
Filing Code Description: Motion
Filing Description: Appellant's 1st extension motion
Status as of 9/16/2025 7:07 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Michael Graham 24113581 Michael.Graham@TEXASBAR.COM 9/15/2025 11:43:57 PM SENT
CAUSE #202510213

RICH ROBINS § IN THE 189th JUDICIAL
§ DISTRICT COURT
§
vs. § OF
§
§
COMMISSION FOR LAWYER DISCIPLINE § HARRIS COUNTY,
dba “TEXAS BAR” § TEXAS
aka “STATE BAR OF TEXAS” §
§

PLAINTIFF’S NOTICE OF APPEAL
Procedural background

1. Plaintiff Rich Robins desires to appeal to the 15th Court of Appeals from a
judgment signed by Judge Tamika Craft-Demming on June 16th, 2025 in the 189th District
Court of Harris County. The case number is #2025-10213. Plaintiff Robins opts for the
appellate index option whereby agreed records are submitted without having to pay $1 per
page, or anything per page. Meanwhile, the judgment hastily dismissed Robins’ Deceptive
Trade Practices Act (DTPA) claims against the Defendants, based on mere TRCP 91a
grounds. Plaintiff Robins subsequently timely filed a request, and later a revived request for
Findings of Fact & Conclusions of Law on July 4th 2025 and August 1st, 2025, respectively.
This notice of appeal is timely filed.

Facts underlying the Defendants’
ethics violation accusations against Plaintiff Robins

2. In part, this case is about the ethics rules-related consequences inflicted by the
Defendants upon Plaintiff Robins. They primarily relate to his having not rushed to
formally declare to an unvisited (by him), faraway court the (undocumented) reported death
of a female client & eventual litigant (Cindy Crisp). She was approximately 59 years old
when Plaintiff Robins worked with her telephonically, without ever meeting her or receiving
any compensation for himself, ever. She needed to try to recover compensation for herself
from an estate vendor in Tyler, Texas who had issued her two bounced checks that he had

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written as the total liquidation amount for her estate. The estate vendor did so around the
time when he also bounced dozens more checks to others. The two checks to the client were
for approximately $7,000. Plaintiff Robins inserted in the lawsuit that the Plaintiff would
settle for twice that amount (approximately $14,000) if no further legal wrangling would
transpire. The client did, after all, repeatedly say that her estate was worth several multiples
of the final checks’ amount. Plaintiff Robins filed the lawsuit in Tyler, Texas, which he has
only visited for a single day, ever, nearly a year after filing the abovementioned lawsuit and
months after Robins took the initiative to report the possibility of the (then still
undocumented) death to the court.

3. No rule, not even TRCP 151, authorized Plaintiff Robins’ disclosing that she was
dead and thereby subjecting her and her family to identity theft risks, and even worse if she
was actually still alive. No obituary was ever published for her, either. Meanwhile, Plaintiff
Robins was officially denied a death certificate when he repeatedly attempted to quietly
obtain one. Her status as living or dead did not matter for her relevant legal rights to recover
on a small ($7,000) claim that Plaintiff Robins pursued for her (or her sons). Plaintiff Robins
knows of no outstanding creditors for her to this day, as the amount of the checks was
smaller than Medicaid’s minimum required for it to wage collections actions. Furthermore,
there is still no way to exclude the possibility that the client is confidentially cryopreserved,
either. Service providers have learned repeatedly that heirs who learn of monetary deposits
financing a relative’s cryopreservation would prefer to “pull the plug” on the deep freeze
container and take the money for themselves.

4. Plaintiff Robins’ religion aligns with that of the Church of Perpetual Life, a science-
based alliance in which death is considered optional thanks to cryonics. Everyone reading
this is welcome to visit www.Perpetual.life. Cryonics or other life extension approaches plus
time travel could someday enable us all to visit with our deceased loved ones. The Bar
defendants in this appeal mocked and scorned Plaintiff Robins’ cryonics-related precautions,
in writing, as he can easily prove.

5. Because of Plaintiff Robins’ taking months to investigate before voluntarily
mentioning the client’s supposed passing to the court months before his lone visit there days

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after a Houston hurricane (Harvey), the Commission for Lawyer Discipline accused him of
misrepresenting, just like it did to its fairly recent grievance prosecution defendants Brent
Webster, Ken Paxton & Sidney Powell (etc.). The Bar defendants inflicted on Plaintiff
Robins the only ethics or criminal prosecution that he has ever endured for anything at all
during his nearly 30 year legal career. So here we are. The corresponding DTPA lawsuit
provides additional details. Meanwhile:

The Fifteenth Court of Appeals’ involvement is needed
to help make CFLD ethics rule interpretations uniform statewide.

6. By litigating this dispute in the 15th Court of Appeals, we can jointly make it clear at
the statewide level what the Bar defendants’ ethics rules actually permissibly mean.
Regarding the Bar defendants’ boundless rule prohibiting attorney misrepresentations, for
example, we can get statewide clarity regarding at what point one must disclose a client’s
rumored but nevertheless undocumented death. Afterwards, perhaps Texas could
subsequently begin to catch up with other U.S. states where cryonics centers exist and (in
some locales) thrive while Texas has endured the (literally) chilling weight of this ethics
dispute as it continues to lack such an active center. The list of U.S. states where active
cryonics facilities serving humans actually exist presently includes Michigan, Arizona,
California and Oregon (and perhaps still Florida), but not Texas. Nevertheless, the prospect
of making death optional has its appeal (now literally). The Fifteenth Court of Appeals,
with its statewide electorate and focus on governmental actions & inactions can help Texas
catch-up especially here in Space City (i.e. Houston). Cryonics breakthroughs are needed to
help make long distance space travel more viable, after all. Ask Elon…

7. Defendant Robins appeals the judgment in this case to the new Fifteenth Court of
Appeals in Austin, Texas. That court has exclusive intermediate appellate jurisdiction over
matters arising out of or related to civil appeals brought by or against the state or a
commission, etc.

8. The 15th Court has exclusive intermediate appellate jurisdiction over certain
enumerated matters, including a list of disputes involving state actors (such as commissions),
and actions “challenging the constitutionality or validity of” certain state rules involving the

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attorney general. Tex. Gov’t Code §22.220(d), (d)(2); §25A.007.

9. The Texas Legislature restricted the 15th Court’s jurisdiction by divesting it of
jurisdiction over criminal matters. In re Dallas Cnty., 2024 WL 3908122, at *15. Nowhere
do the relevant provisions of the Texas Government Code prohibit jurisdiction regarding the
State Bar of Texas or its statewide Commission for Lawyer Discipline, however. See
generally, Tex. Gov’t Code §22.220.

10. Puzzlingly enough, earlier this year the 15th Court of Appeals denied jurisdiction to
unrelated litigation against the Commission for Lawyer Discipline. See Turnbull v.
Commission, 15-24-00095-CV (15th COA, 2024). The list of defendants in that case
includes a variety of individual persons, however. There are other distinguishing
characteristics as well. Additionally, the legal climate has evolved in part due to new
jurisprudence from the Supreme Court of Texas, and new statutory permissiveness based on
statutory authority. It is time to let this jurisdictional debate go directly to the Supreme Court
of Texas, for the good of nearly all Texans.

11. Texas’ Governor Abbott, Senator Huffman and other proponents of the 15th Court
of Appeals’ creation envisioned a Texas where government regulations mean the same in all
14 different state appellate districts. This goal is particularly important in the legal
profession, where presently some ethics rules are interpreted differently depending upon the
appellate district. Sometimes a lawyer’s service cover more than one lone appellate
jurisdiction, as is the case with Robins’ underlying dispute with the State Bar of Texas. One
cannot obey conflicting interpretations of the same rule without running into even more
ethics problems with the profiteering Bar defendants. The resulting unpredictability makes
it more costly to retain legal representation in Texas. That helps almost nobody...

Relevant statutory authority requires that disputes against
the State Bar of Texas (and its progeny) go to the 15th Court of Appeals

12. Texas’ Legislature limited the 15th Court of Appeals’ jurisdiction to specific civil
matters, including:

[M] atters brought by or against the state or a board, commission,
department, office, or other agency in the executive branch of the

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state government…or by or against an officer or employee of the
state or a board, commission, department, office, or other agency
in the executive branch of the state government arising out of that
officer’s or employee’s official conduct….

TEX. GOV’T CODE § 22.220(d)(1). Such appellate matters may be heard only by the

15th Court of Appeals, instead of any other intermediate appellate court. Id.

13. The Legislature’s use of disjunctive “or” in the abovementioned text is

significant. In viewing that text with some emphases inserted, it appears as:

[M] atters brought by or against the state or a board,
commission, department, office, or other agency in the executive
branch of the state government…or by or against an officer or
employee of the state or a board, commission, department,
office, or other agency in the executive branch of the state
government arising out of that officer’s or employee’s official
conduct….

TEX. GOV’T CODE § 22.220(d)(1) (emphasis added). The “or” disjunctions are

important.

14. “Or” as underlined in the abovementioned text disjunctively indicates an

alternative. The two “or” conjunctions, therefore, indicate that the Texas Legislature

intended to divide qualifying civil matters into four categories: (i) by or against the

state; (ii) by or against a board, commission, department, office, or other agency in the

executive branch of this state; (iii) by or against an officer or employee of the state; and

(iv) by or against an officer or employee of a board, commission, department, office,

or other agency in the executive branch of this state. See TEX. GOV’T CODE §

22.220(d)(1). Stated differently, as long as the underlying civil case falls into one of the

abovementioned four categories, the case is within the 15th Court of Appeals’

jurisdiction.
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15. An appeal against the Commission for Lawyer Discipline falls into, at the very least,

category (i) mentioned above. The State Bar and its progeny purport to be, or purport to

be part of a legislatively created public corporation and administrative agency of the

State. See, TEX. GOV’T CODE § 81.011(a). Claims against the Bar defendants fall

into the 15th Court of Appeals’ jurisdiction under category (i) described above: claims

brought by or against the State. TEX. GOV’T CODE § 22.220(d)(1).

The doctrine of last antecedent, as depicted in Texas Supreme Court jurisprudence:

16. The Fifteenth Court of Appeals has seemingly preliminarily interpreted
jurisprudence from the Supreme Court of Texas to mean that the words “executive branch” in
the 15th Court of Appeals’ statutory enabling authorization require that a “commission” must
be part of the executive branch in order to qualify for jurisdiction in the Fifteenth Court of
Appeals. In addressing that interpretation, however, it helps to notice that executive branch
does not necessarily modify even the word “commission.” The Supreme Court of Texas has
embraced the “doctrine of last antecedent” before, including in Spradlin v. Jim Walter Homes,
Inc., 34 SW 3d 578 (2000). In applying that doctrine to this appeal, the modifier “executive
branch” applies merely to the word before it, and not to the entire batch that precedes it
including “commission”.

17. As an illustrative additional example offered for analytical purposes, the grammar
of the relevant enabling statutory provision for the Fifteenth Court of Appeals resembles that
of the following: “Insecticide brand X has not been formally tested on strawberries, grapes,
apples, peaches, citrus fruits or other tree-born fruits (persimmons, cherries, etc.), but it has
on tomatoes.” Not all of the entities preceding “or other tree-born fruits” are tree-born fruits,
but they are nevertheless suitably present in that sentence. The same can be said for
“executive branch” in the statutory authorization of the Fifteenth Court of Appeals. A
commission-related dispute arguably qualifies for the Fifteenth Court of Appeals even if it is
not one in the executive branch.

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Constitutional authorities

18. Furthermore, the Texas Constitution's open courts provision (Article 1, Section
13) states that all courts must be open and that everyone has the right to a remedy through the
due course of law. Interpretations of it vary, admittedly, but Plaintiff Robins’ position is that
he has the right to litigate this appeal in the 15th Court of Appeals. Preventing his access to
the 15th Court of Appeals requires a clear and strong statutory prohibition against it. Such a
prohibition does not exist. Imagining one and applying it to Plaintiff Robins in this case
would be unconstitutional.
19. Meanwhile, the Interstate Commerce clause of the U.S. Constitution (Article I,
Section 8, Clause 3) protects the rights of litigants not to be, among other things, arbitrarily
excluded from protections such as those provided by the 15th Court of Appeals. Plaintiff
Robins has interstate involvement that arguably qualifies him for such protections. He took
the Texas Bar at its word that it would adjudicate not predatorily, but rather helpfully, so that
attorneys could feel comfortable assisting clientele here in Texas. He has found this not to
be the case, and he wants to use a uniquely statewide and specialized court for adjudicating
his disbarment which was preceded by nearly 3 decades of his otherwise ethically spotless
(and still criminally spotless) record.
20. The 15th Court of Appeals has a uniquely statewide audience & electorate, and a
specialized focus that can be particularly useful. Local appellate courts do not have that, nor
are they designed to. Furthermore, the Texas Bar is so under-regulated that a specialized
court is even more necessary when trying to discover ways to bring it into constitutional (and
other) compliance. If anyone doubts this, they are encouraged to visit the website
TexasBarSunset.com.
21. Plaintiff Robins understands that the 15th Court of Appeals might perhaps be
apprehensive that the enabling statutory and rule-based language for the 15th Court of
Appeals do not expressly mention disputes with the government in the judicial branch. He
therefore reiterates that the enabling language also does not expressly and clearly exclude
judiciary disputes from the 15th Court of Appeals, even as it does exclude other sorts of
disputes involving the government. So why exclude this appeal? The Court exists for
matters against the state, after all. Meanwhile, constitutions are made to be respected.

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22. As you know, courts presume that the legislature purposefully chose which words
to include in the statute and which to omit. Lippincott v. Whisenhunt, 462 S.W.3d 507, 509
(Tex. 2015) (per curiam). The Court’s objective in construing a statute is to give effect to
the Legislature's intent, which requires one to look initially to the statute's plain
language. Leland v. Brandal, 257 S.W.3d 204, 206 (Tex.2008). If that language is
unambiguous, one is to interpret the statute according to its plain meaning. Id. The statutory
language involving the 15th Court of Appeals is clear enough.

23. As for the appeal’s logistics, there are no court reporter transcripts to bring along to
the appellate court. Meanwhile, as mentioned above, Plaintiff Robins opts for the appellate
index option whereby agreed records are submitted without having to pay $1 per page, or
anything per page. He looks forward to working with opposing counsel to satisfactorily
generate the agreed record, pursuant to that new option.

Respectfully submitted,

Rich Robins
(Pro se Plaintiff)
2450L ouisiana St. #400-155
Houston, TX 77006-2380
Rich@ConsumerRights.US
Tel. 832-350-1030
_____________________________

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CAUSE #202510213

RICH ROBINS § IN THE JUDICIAL
§ DISTRICT COURT
§
vs. § OF
§
§
COMMISSION FOR LAWYER DISCIPLINE § HARRIS COUNTY,
dba “TEXAS BAR” § TEXAS
aka “STATE BAR OF TEXAS” §
§

PLAINTIFF RICH ROBINS’ 1st AMENDED DPTA PETITION

COMES NOW, Plaintiff Rich Robins (hereinafter “Plaintiff Robins”).

PARTIES

1. Plaintiff Rich Robins is the respondent named as the defendant in the Commission for
Lawyer Discipline’s lawsuit in case #2018-46488 in Harris County District Court #61. He is
also the plaintiff in case #2024-18660, which has been handled by three different judges thus far,
due to noble, unsolicited judicial recusals. That petition was abruptly & involuntarily terminated
when its primary focus was the Texas Religious Freedom Restoration Act (TRFRA) violations by
the Defendants. Plaintiff Robins adaptively added a DTPA-based claim to that petition but the
case was concluded anyway. Along the way, Plaintiff Robins adaptively filed this separate
petition pursuant to the Texas Deceptive Trade Practices Act (DTPA). Tex. Bus. & Com. Code
§ 17.00. Although it has much in common, factually and at times legally with the TRFRA
petition, this 1st amended DTPA petition does not have actual TRFRA-based claims (nor did its
prior version, which Plaintiff Robins filed while the TRFRA petition was still at the trial court
level and before he filed his subsequent notice of appeal for it). Meanwhile, Plaintiff Robins
hereby asserts the following…

2. Plaintiff Robins brings this legal action against the State Bar of Texas (hereinafter
the “Texas Bar”), and its Commission for Lawyer Discipline (hereinafter the “CFLD”). It is
not presently brought against the the Chief Disciplinary Counsel (hereinafter the “CDC”). The

1
actually named Bar defendant parties are referred to in several instances as the “Bar
defendants”.

3. This is the only disciplinary action or prosecution EVER to be pursued against
Plaintiff Robins by any bar association or other authority during his approximately 30 years of
actively practicing law. Plaintiff Robins also has no criminal or even traffic convictions
against him.

BACKGROUND

4. On July 2nd, 2021 the Fifth Circuit Court of Appeals in New Orleans, Louisiana
decisively ruled that the Defendants Texas Bar (& thereby its CFLD & CDC) impermissibly,
unlawfully and enduringly spent attorney members’ coercively extracted annual dues on
ideological and political endeavors that are not germane to regulating or improving the practice
of law here in Texas. See McDonald v. Longley, 4 F.4th 229 (5th Cir. 2021). The Court also
found that the Defendants had similarly unlawfully not given dues-paying members
constitutionally adequate and meaningful notice of how their coercively extracted dues money
would be spent or where their fees would go. Id. Additionally, the Court found that the
Defendants have not given members adequate veto authority over such expenditures. Id.
5. Subsequently the Fifth Circuit issued its relevant mandate on July 26, 2021 (ECF
No. 103). It thereby sided with the amicus brief-submitting Texas Attorney General Ken
Paxton and against the Texas Bar. Perhaps not altogether coincidentally, that bar has since
sought to disbar Attorney General Paxton, in part for allegedly not investigating something
adequately enough before making a statement about it in a court filing. That bar tried to
disbar Attorney Paxton in Collin County District Court’s case # 471-02574-2022, which is
available online at:
https://apps2.collincountytx.gov/judicialrecords/case .
6. As Plaintiff Robins present petition will show, below, the same bar nevertheless
prosecuted Plaintiff Robins for investigating something before nonmandatorily declaring it,
namely word of his client’s death. He heard from someone on the phone whom Plaintiff
Robins had never met, and who had received a considerably valuable inheritance from her as
a result of such a (potentially hasty) declaration. In the process, that source (the client’s son)

2
deprived Medicaid of compensation and quite possibly Plaintiff Robins’ client of her house
while she remained alive, albeit institutionalized. Plaintiff Robins investigated this before
he ultimately disclosed word of a 59 year old client’s death to a court up in Tyler, Texas. He
declared this even as no Texas state statute, state rule of civil procedure or binding state
caselaw requires or allows for such a disclosure in the midst of potent client confidentiality
restrictions (which survive the life of the client). One statutory provision even encourages
one to wait seven years before presuming the death of someone who is not documented as
such. Meanwhile, federal caselaw says no such advisory is even required by the rules.
Plaintiff Robins nevertheless reported this to the court (up in Smith County, Texas) even
though it is undisputed that there has never been an obituary published for the client and even
though he had been repeatedly denied by state authorities a copy of her death certificate (if
one even existed).
7. For decades, the Texas Bar has already had ample notice from the U.S. Supreme
Court and the Texas Government Code that members are not to be coerced into funding
expenditures that are not germane to the permissible purposes of a mandatory bar. See
Keller v. State Bar of California, 496 U.S. 1 (1990). See also TEX. GOV’T CODE
§81.034. The Texas Bar continues to operate an attorney disciplinary system that is not in
compliance with constitutional law, as this dispute helps show.
8. All of the Texas Bar Defendants’ approximately five claims prosecuted against
Plaintiff Robins are based on the incorrect supposition that the Texas Bar can
nondemocratically impose its will on the state of Texas regarding Texas’ otherwise fairly
tolerant and permissive rules and laws. The particularly relevant rules & laws involve the
speed with which a lawyer representing a plaintiff here must report to the assigned court
news of the plaintiff’s death even when independent attempts to verify it did not document
and possibly could not ever document it sufficiently reliably. The Bar defendants allege
that a few months’ delay under such circumstances is deceptive and grounds for disbarment,
even as apparently no state rule, law or case decision labels such hesitation as
impermissible, much less deceptive. In fact, Plaintiff Robins has found caselaw asserting
contrarily that one need not even notify the court that a client has passed away in a pending
case. The closest that any Texas Rule of Civil Procedure comes to the topic is permissible
regarding how Plaintiff Robins handled matters, in fact. (TRCP 151).

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9. The relevant prosecution of Plaintiff Robins emerged about a year after he became
the only attorney to testify critically of the Texas Bar during all three available public
comments opportunities involving the 2016-2017 Sunset Review of the Texas Bar at Texas’
state legislature in Austin. Plaintiff Robins compassionately recommended keeping the
Texas Bar around for another 12 years (as he can easily prove). However, he opposed
granting the Texas Bar the deceptively & sneakily pursued, unrestricted rights to increase
annual dues whenever it likes and as often as it likes. The Texas Bar sought that right despite
having simultaneously mass-mailed all (still compulsory) member attorneys that their
referendum rights remained intact amidst the Sunset process. Referendum restrictions have
existed regarding dues increases for many decades, if not for the entire time that the Texas
Bar has existed with mandatory membership status. Rather than apologize for having
defrauded the membership, the Texas Bar found fault with the attentive observer & candid
caretaker Robins. The Bar defendants viciously attacked his livelihood at the expense of
Plaintiff Robins’ consumer rights including by canceling his bar license. Within a year of
successfully getting Plaintiff Robins disbarred, the Texas Bar awarded itself a dues increase
and without seeking, much less obtaining approval from the still compulsory Texas Bar
membership.

DISCOVERY CONTROL PLAN

10. Plaintiff Robins intends to conduct discovery against the Defendants under
the potentially adaptively tailored Level 3 pursuant to Texas Rule of Civil Procedure 190.4,
etcetera.

PLAINTIFF ROBINS’ AFFIRMATIVE CLAIMS FOR RELIGIOUS
DISCRIMINATION ARE NOT PART OF THIS PENDING PETITION

11. In an effort to avoid deleting facts that are relevant to both Plaintiff Robins’
TDRFA and DTPA claims, Plaintiff Robins mentions that during January of 2023, the
Texas Bar defendants, either directly or indirectly revealed their legally impermissible
intentions in their first, ever, answer to the accused respondent Robins’ request for
disclosures provided to Plaintiff Robins in their ethics prosecution against him. In those

4
disclosures, the CFLD’s and Texas Bar’s and arguably CDC’s prosecutor John Brannon
states:

“Factual Bases….

“[Plaintiff Robins] went on to claim that “any fan of baseball star Ted Williams realizes that a
head can be rather affordably severed from a deceased body and frozen for a desired revival and
bodily regeneration many years later ….” Respondent asserts that “[s]uch procedures have been
known to take place very secretively at the request of heirs who do not tell others in the family,
and who cremate merely the body.” The aforementioned statements by Respondent
evidence the types of salacious, false,dishonest, defamatory, frivolous, and outrageous
claims and positions Respondent took during his representation of Crisp and the
Clinkenbeards.”

12. Although this petition does not include a TRFRA claim (as clarified above), Plaintiff

Robins mentions that he is being discriminated against for his religious views as a longstanding

follower of the Church of Perpetual Life. That nondenominational church is available to the

world at: ChurchOfPerpetualLife.org .

13. That church stands for ideals such as how we are each blessed with one life that has

infinite potential through science. We are joined together through an alliance of potential

universal resuscitation. Furthermore, those who embrace pioneering technologies in

furtherance of such goals are not to be scorned or harmed for it.

14. Plaintiff Robins always wanted what is best for his relevant and reportedly deceased

client, Cindy Crisp. He avoided rushing to declare her dead while he hoped to somehow

discover ways to locate and financially support her. He was polite to her family members and

nonjudgmental, as psychotherapist Karl Rogers preached as part of his Humanist school of

thought. Nevertheless, the Texas Bar defendants made it crystal-clear how hostile they are to

such a supportive approach to life. They have gone to great lengths to penalize, silence and

cancel Plaintiff Robins professionally for it, too, while they continue making a fortune from

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(still compulsory) bar members each year. The Texas Bar’s annual budget is approximately

$60 million but it would be multiples more (at all Texans’ expense) if it had not been for

Plaintiff Robins’ timely written and testimonial efforts during the 2016-2017 Sunset Review

process.

15. Plaintiff Robins shares the following benign & explanatory quote: “[t]he aim of the

cryogenic process is to preserve tissues, organs and the brain after the heart stops beating, with

the body stored head-down in liquid nitrogen at -196C. They are then considered ‘in

suspension’ ahead of possible scientific leaps to revive and return them to good health.”

Source: https://metro.co.uk/2023/01/07/brits-hope-for-life-after-death-by-cryogenically-
freezing-their-bodies-18039920

What is so unacceptable about supporting and assisting anyone’s possible direct involvement
with that pursuit?
16. Here is an example of what can happen to those (such as Robins’ client Cindy Crisp,
who never discharged him as a client…) who do not hide their cryopreservation aspirations from
heirs: Alcor Life Extension Foundation v. Pilgeram.
That relatively recent dispute, now concluded, is included by hyper-link here:

https://www.dailymail.co.uk/news/article-7903137/Sons-legal-fight-dead-fathers-frozen-head-
against-cryogenics-firm-preserving-it.html

Long story short, heirs have been known to try to disrupt a deanimated person’s cryonics-
related plans, in pursuit of the relevant money for themselves.

17. Anyway, the Defendants’ treatment of Plaintiff Robins is in violation of the Texas
Deceptive Trade Practices Act. They canceled his religious freedoms as included in his
practice of law, without sufficient (if any) statutory, common law or civil procedure rule-based
justification. If the Texas Bar is so eager to prevent the expression of members’ concerns
about potentially “biologically paused” or “clinically dead but hopefully not permanently so”
clientele, it should try to amend applicable statutory, civil procedure, and jurisprudential

6
authorities to inform people as much. Instead, the Defendant Texas Bar, CFLD and CDC
consider themselves to be above such “deathist” endeavors, quite possibly because they would
not gain traction with Texans anyway. Texans want to live, not subscribe to the Texas Bar’s
dark view of life. Texans certainly do not want to empower unelected and insufficiently
regulated Bar bureaucrats to determine when other people’s rights should be terminated.

18. Plaintiff Robins’ free exercise of religion was substantially and unlawfully burdened by
the Bar defendants’ actions. Actions from all three have not furthered a compelling
government interest, as one can tell from the absence of statutory or civil procedure rule
authority saying otherwise. Meanwhile, the Texas bar defendants’ actions against Plaintiff
Robins are not the least restrictive means of furthering any compelling interest. For example,
the Texas Bar defendants have not enacted any rules that are expressly on point, nor have they
successfully gotten (or even tried to get) a statutory or civil procedure restriction placed on
conduct involving the (supposedly obligatory) hasty declaration of a client’s death despite the
risks of breach of attorney / client privilege (which indisputably outlives the client), and of
identity theft that could financially adversely affect the whole family. The Bar defendants have
also not prosecuted any other lawyer for doing something similar, as far as Plaintiff Robins can
tell. Incidentally, most lawyers in the USA need not be a member of a state bar in order to
maintain their law licenses. It will be interesting to see how much longer the status quo remains
intact here in Texas, though.

19. Meanwhile, despite federal restrictions upon the Texas Bar’s taking such political
stances, the bar defendants excluded nearly all of Plaintiff Robins’ defenses and evidence from
the fact-finder jury’s access during pre-trial proceedings, with the predictable result’s emerging.
With practically no defenses, the jury was eager to conclude a 3 day trial with at most a ten
minute conference. None of the jury charges adequately resembled the rules allegedly violated,
while every instruction that Plaintiff Robins submitted was similarly excluded from the jury’s
consideration. Needless to say, an appeal is underway. It is also an ongoing burden from
which Plaintiff Robins is entitled to relief pursuant to the DTPA.

Defendant Robins has endured and continues enduring
unlawful treatment by the Bar defendants:

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20. The CFLD, Texas Bar and CDC have prosecuted and punished Defendant Robins to
forfeit his religious views favoring the (hopefully merely) undead, while seeking to punish
him for his having observed and practiced his beliefs in the past as part of his practice of law.
Astonishingly enough, the CFLD petitioner would, even in the documented absence of
statewide law’s, rules’ or jurisprudence’ requiring it, have Defendant Robins rush to
judgment when circumstances are ambiguous as to whether a missing client is potentially
cryo-preserved, i.e. clinically dead (or even just missing perhaps at a Hospice facility) instead
of permanently dead. The petitioner would have had Defendant Robins disclose such a
client’s possible vulnerable legal status even when that client’s well-being remains
insufficiently confirmed, and would consequently be compromised and a source of great
suffering upon a desired revival someday. The petitioner would have even had Defendant
Robins settle a case such as Cindy Crisp’s despite his firm belief that the (possibly cryo-
preserved or simply comatose) client would disapprove upon awakening. As prominent
caselaw says, “[w]here the state conditions receipt of an important benefit upon conduct
proscribed by a religious faith, or where it denies such a benefit because of conduct mandated
by religious belief, thereby putting substantial pressure on an adherent to modify his behavior
and to violate his beliefs, a burden upon religion exists. Adkins v. Kaspar, 393 F.3d 559,
569 (5th Cir. 2004), citing Thomas v. Review Board of the Indiana Employment Security
Division, 450 U.S. 707, 101 S.Ct. 1425, 67 L.Ed.2d 624 (1981).

21. Furthermore, the Code of Federal Relations states, in relevant part:

“In most cases whether or not a practice or belief is religious is not at issue. However, in
those cases in which the issue does exist, the Commission will define religious practices to
include moral or ethical beliefs as to what is right and wrong which are sincerely held with the
strength of traditional religious views. This standard was developed in United States v. Seeger,
380 U.S. 163 (1965) and Welsh v. United States, 398 U.S. 333 (1970).” See §1605.1
“Religious” nature of a practice or belief.

22. Nevertheless, Plaintiff Robins mentions how the Texas Bar / CFLD / CDC prosecutor
John Brannon claimed in a (successful) opposition to a continuance that Defendant Robins did
not refer to his religious views favoring the potentially cryo-preserved client Cindy Crisp during
a 5+ hour deposition of Plaintiff Robins. Nevertheless, the following two exchanges between

8
the CFLD petitioner (“Q”) and Defendant Robins (“A”) are revealing (as are others) as to how
inaccurate such assertions by the Texas Bar defendants were:

Deposition, at page 47:

Q. And so, I want to try to get philosophy, religion, any type of spirituality out of it. And just
focus on that non-sector for a moment, for purposes of this case.
A. Non-sector?
Q. If you would, please. Something that is not spiritual or religious or philosophical. I want
to get -- if you can remove that, you know, from your
vocabulary during the question and answer. That would be very helpful. Okay?

&

Deposition page 134:

A. Yes. But please, realize, there is a difference in my world, between being clinically dead
and permanently so, biologically paused and exterminated.

Texas Bar prosecutor John Brannon is an agent (if not also an employee) of the CDC, as well as
an employee of the CFLD and of the Texas Bar. They work in cahoots with one another.

Sovereign immunity is not applicable:
23. Claims of sovereign immunity do not withstand scrutiny. The following appellate
court case from the Texas Bar headquarters’ backyard of Austin, Texas shows how claims about
sovereign immunity pursuant to its own rules are inadequate under the circumstances:
Commission for Lawyer Discipline v. Rosales, 577 S.W.3d 305, 313-314 (Tex. App.—
Austin 2019, pet. denied). There it states the following:

The Commission further argues that the TCPA does not apply to its disciplinary proceedings
because the Commission is entitled to "absolute immunity." In support of this argument, it
points to the provision providing that the TCPA "does not abrogate or lessen any other ...
immunity available under other constitutional, statutory, case, or common law or rule
provisions," Tex. Civ. Prac. & Rem. Code § 27.011(a), and to Rule 17.09 of the Texas Rules
of Disciplinary Procedure, which provides:

All members of the Commission, the Chief Disciplinary Counsel (including Special Assistant
Disciplinary Counsel appointed by the Commission and attorneys employed on a contract
basis by the Chief Disciplinary Counsel), all members of Committees, all members of the
Board of Disciplinary Appeals, all members of the District Disability Committees, all
officers and Directors of the State Bar, and the staff members of the aforementioned entities

9
are immune from suit for any conduct in the course of their official duties. The immunity is
absolute and unqualified and extends to all actions at law or in equity. Tex. Rules
Disciplinary P. R. 17.09.

According to the Commission, "[a]n obvious purpose of the immunity provided by Rule
1[7].09 is to allow the disciplinary system to discharge their official duties without fear of
being sued or liable for monetary judgments, such as attorneys' fees that can be awarded in
[TCPA] proceedings."

The immunity granted in Rule 17.09, however, is official immunity that
shields governmental employees from personal liability so that they are encouraged to
vigorously perform their official duties. See id.; Telthorster v. Tennell, 92 S.W.3d 457, 460-
61 (Tex. 2002) ("Official immunity is an affirmative defense that shields governmental
employees from personal liability so that they are encouraged to vigorously perform their
official duties.") (citing Kassen v. Hatley, 887 S.W.2d 4, 8 (Tex. 1994)). It is not the same as
sovereign immunity, which protects the State, and government entities like the State Bar,
from lawsuits for money damages unless the immunity has been waived. See, e.g., Reata
Constr. Corp. v. City of Dallas, 197 S.W.3d 371, 374 (Tex. 2006).

22. Incidentally, even the abovementioned rule 17.09 does not purport to immunize the
Commission for Lawyer Discipline or the Texas Bar.
24. Similarly, the Texas Religious Freedom Restoration Act (TRFRA) says, in relevant part:
Sec. 110.008. SOVEREIGN IMMUNITY WAIVED. (a) Subject to Section
110.006 [notice & right to accommodate], sovereign immunity to suit and from liability is
waived and abolished to the extent of liability created by Section 110.005 [remedies], and a
claimant may sue a government agency for damages allowed by that section.

25. Additionally, cases such as Richards v. Mena, 907 S.W.2d 566, 569 (Tex.App.--Corpus
Christi 1995, writ dism’d) are persuasively relevant. CPRC §106.002(b) “provides for an
express waiver of the State’s governmental immunity to those prohibited acts listed in [CPRC]
§106.001.”

26. Plaintiff Robins submits that sovereign immunity does not protect the Bar defendants
from the reach of the DTPA, either. Plaintiff Robins is a “consumer” who naively spent
several hundred dollars per year on the purported goods & services of the Bar defendants.
These include licensing maintenance, continuing legal education (CLE), printed & online
publications, ethics hotline advisories and live course offerings, etcetera. Plaintiff Robins
detrimentally relied in various ways as a deceived consumer while the Bar defendants
continued to pursue ever-increasing revenues for themselves, especially deceptively through

10
the Sunset Commission’s 2016-2017 review. The abovementioned materials and other so-
called services were intentionally misleading and forcibly influential upon Plaintiff Robins
due to the mandatory bar membership privileges that the Bar defendants still enjoy. The
situation has been the kind that the DTPA is designed to address for society’s benefit.

Meanwhile, the Bar defendants are “persons” pursuant to the DTPA. The definition of
“person” in the Texas DTPA clearly includes organizations such as the Bar defendants. The
Bar defendants comprise a group, however organized. Claims of quasi-governmental &
public corporation status do not shield the Bar defendants from what they are: persons,
pursuant to Texas’ DTPA.

Discovery has not begun in this case, and is substantially needed to further
develop the assertions & claims. Nevertheless, the following descriptions apply:

AFFIRMATIVE CLAIMS PURSUANT TO
THE TEXAS DECEPTIVE TRADE PRACTICES ACT
27. Plaintiff Robins incorporates the aforementioned as if set forth fully herein. He
pursues claims against the Defendants pursuant to the Texas Deceptive Trade Practices Act
(DTPA). The Defendants have engaged in false, misleading & deceptive practices at Plaintiff
Robins’ expense, and that of the general public which depends upon legal services that the Texas
Bar has mismanaged and continues to subvert for its own profiteering, in numerous ways.

28. The DTPA mandates that the law “shall be liberally construed and applied to
promote its underlying purposes, some of which are to protect consumers against false,
misleading, and deceptive business practices, unconscionable actions, and breaches of warranty.
Others are to provide efficient and economical procedures to secure such protection.” Tex. Bus.
& Com. Code § 17.44(a) (emphasis added).

29. The DTPA declares unlawful any “[f]alse, misleading, or deceptive acts or practices in
the conduct of any trade or commerce,” Tex. Bus. & Com. Code § 17.46(a), which it defines as
including, inter alia¸ “causing confusion or misunderstanding as to the source, sponsorship,
approval, or certification of goods or services,” id. § 17.46(b)(2), “representing that goods or

11
services have sponsorship, approval, characteristics, ingredients, uses, benefits, or quantities
which they do not have or that a person has a sponsorship, approval, status, affiliation, or
connection which the person does not,” id. § 17.46(b)(5), “advertising goods or services with
intent not to sell them as advertised,” id. § 17.46(b)(9), and “failing to disclose information
concerning goods or services which was known at the time of the transaction if such failure to
disclose such information was intended to induce the consumer into a transaction into which the
consumer would not have entered had the information been disclosed,” id. § 17.46(b)(24).

30. Texas Bus. & Com. Code § 17.45(1) defines “goods” as “tangible chattels or real
property purchased or leased for use.” See also United Postage Corp. v. Kammeyer, 581 S.W.2d
716, 721 (Tex. Civ. App.—Dallas 1979) (“tangible chattels” are “those items of personal
property which may be seen, weighed, measured, felt or touched.”). Texas Bus. & Com. Code §
17.45(2) defines “services” as “work, labor, or service purchased or leased for use, including
services furnished in connection with the sale or repair of goods.” See also Riverside Nat’l Bank
v. Lewis, 603 S.W.2d 169, 174 (Tex. 1980) (“services” means “action or use that furthers some
end or purpose: conduct or performance that assists or benefits someone or something: deeds
useful or instrumental toward some object.”).

31. Texas Bus. & Com. Code § 17.45(6) defines “trade” and “commerce” as “the
advertising, offering for sale, sale, lease, or distribution of any good or service, of any property,
tangible or intangible, real, personal, or mixed, and any other article, commodity, or thing of
value, wherever situated, and shall include any trade or commerce directly or indirectly affecting
the people of this state.”

32. The Texas Bar defendants made various misrepresentations & nondisclosures which
ultimately profited them but substantially harmed Plaintiff Robins. Texas Bus. & Com. Code §
17.46(b)(24) provides that the phrase “false, misleading, or deceptive acts or practices” includes
“failing to disclose information concerning goods or services which was known at the time of the
transaction if such failure to disclose such information was intended to induce the consumer into
a transaction into which the consumer would not have entered had the information been
disclosed.”

Trangressions & lawfare by the Bar defendants…

12
33. The Texas Bar defendants have engaged in, and continue engaging in, various
transgressions that constitute deceptive trade practices acts. The following list is not all-
inclusive, as discovery has not gotten underway in this dispute and we are in a notice pleadings
state. In the mean time, though, Plaintiff Robins reports that the Bar defendants have
represented that they take precautions for the bar members’ benefit which they do not. For
example, they advertise and otherwise mention in bar materials that they provide settlement /
mediation conferences, in part to clarify what (if any) property is to be handed over to the
disgruntled client, whom the bar defendants profit from further irritating at the targeted attorney
members’ expense. The Bar defendants did not make anything like that available for Plaintiff
Robins, though, despite requests by his substitute client (Cindy Crisp’s son) and by Plaintiff
Robins. The Texas Government Code purports to require such settlement-friendly pursuits, too,
but the Texas Bar defendants denied this as the abovementioned grievance trial concluded. They
opportunistically exploited their own deceptiveness to try to make it look like Plaintiff Robins
had been noncompliant when in fact he had been compliant. This situation was misleading, to
say the least. Plaintiff Robins adapted his actions in the litigation based upon the Bar defendants’
false assurances. He also would have never helped the son of his initial (very polite) client
Cindy Crisp, who was stricken with multiple sclerosis but who nevertheless found ways to let
Plaintiff Robins know that her son willingly presents unacceptable hazards to others.

34. The bar defendants have also held themselves out as consistently making an effort to
communicate what their interpretations of (conveniently vague) ethics rules actually require,
when they do not. They make over $13 million annually peddling Continuing Legal Education
(CLE), as well as articles, books and conference attendance “opportunities”. They nevertheless
do not warn compulsory members about all the rule interpretations which they will surprisingly
impose upon the astonished compulsory bar member at trial. In the process, at trial they ignore
authorities requiring that such rules be strictly construed in favor of the attorney. Such bait &
switch tactics are unworthy of the licensing monopoly privileges which the Bar defendants profit
from to the tune of tens of millions of dollars annually. The Bar defendants certainly do not
make an effort to provide restitution to the duped consumers who are still forced to contribute to
the defendants’ annual $60 million dollar budget, either. Although over 80% of the Texas Bar’s
active membership reliably abstains from voting in the annual, internet-enabled bar elections
(usually featuring Bar sycophantic candidates of the Bar defendants’ choosing), that percentage

13
would be far higher if the Bar defendants were transparent & forthcoming all along about their
deceptiveness, unreliability, eagerness to breach warranties and other agreements all along.
Such transgressions by the Bar defendants are not protected by sovereign immunity under other
statutes and they certainly are not pursuant to the DTPA. Transgressors include Bar prosecutors
who violate the same ambiguous ethics rules that they hypocritically use to try to silence and
cancel certain (still compulsory) members. Such rules include the importance of avoiding
driving up the cost of litigation, of avoiding frivolous legal actions, and avoiding being
misrepresenting. Plaintiff Robins has various examples of false assertions and other shameless,
intentionally fatiguing, weaponized claims by various employees of the Bar defendants which
repeatedly remind him how mistaken he was to recommend to the Sunset Commission that the
Bar defendants’ charter be renewed even as most lawyers in the USA need not be bar members to
get to practice law.

35. The Bar defendants’ ethics rules even have written assurances that members will not
be prosecuted for good faith errors in judgment, only for the Bar defendants to bend over
backwards to avoid letting something be called sufficiently reasonable to qualify. Victims, such
as Plaintiff Robins, realize after it is too late that relying upon such assurances by the Bar
defendants was hazardous and even dangerous.

36. Additionally, the Bar defendants do not even attempt to comply sufficiently with
religious freedom requirements imposed on them by statute, including by the State Bar Act, i.e.
Chapter 81 of the Texas Government Code). Nevertheless, they do not readily (or otherwise)
disclose to members ahead of time that they will not comply. One learns it as a surprise from
the Bar defendants at, or right before trial, and subsequently gets heavily penalized for the
privilege.

37. Furthermore, they have purported (through implicit if not explicit warranties) to be in
compliance with applicable laws when, as the 5th Circuit in the abovementioned McDonald v.
Longley case demonstrated, they have been far from it. As Plaintiff Robins’ case demonstrates,
they even remain noncompliant. They generate billable hour documents of permissible fees for
lawyers, only to attack and punish lawyers later who abided accordingly when it suits the Bar
defendants.

14
38. Meanwhile they falsely represent in writing on their website (etcetera) that they
cannot resolve a client’s fee dispute with a member attorney, even as one later discovers that
when it suits the Bar defendants, they are nevertheless willing to meddle, interfere and subvert a
potential conciliation process instead of offering the legally required mediation of grievances.
They avoid such mediation even when both sides requested a peaceful, nonlitigious resolution as
had been the case in Plaintiff Robins’ only prosecution. The Bar defendants even claim,
Plaintiff Robins believes dishonestly, that there is no such conciliation obligation.

39. They also boast being a source of attorney self-rule, only for the opposite to emerge
after years of membership persistence seeking reforms such as grievance reforms proposed by
Larry McDougal before, during and after his state bar presidency. Plaintiff Robins even has
video footage of such Bar deceptiveness which had induced detrimental reliance among people
such as Plaintiff Robins, who thought that vagueness in the Bar ethics rules would finally be
addressed instead of left as-is without even letting the Bar’s board of directors vote on proposed
modifications, much less the membership.

40. Additionally they assert that we should not try to co-opt a judge or justice before
whom we have litigation or other business. The Bar defendants do not practice what they
preach, though. They essentially induce members of the judiciary to be biased in favor of the
Bar defendants, and against the legitimate interests of people such as Plaintiff Robins.

41. The Bar defendants even tried to hide from the Sunset Review Commission the half a
million dollar embezzlement by their membership director just over a decade ago. This at least
implicitly told us members that we must do the same to preserve attorney / client confidences
adequately, especially when there is no written duty to rush to report a client’s supposed but
unproven death. Essentially, the Bar defendants emphasize the importance of preserving client
confidentiality, except when they do not. It is misleading to say the least. Plaintiff Robins
detrimentally relied on such confidentiality that he now realizes was simple parasitic & even
predatory deceptiveness.

42. They also hold themselves out as being fair, only to parlay their co-opting of judges
and justices into excluding so much evidence and testimony that could be exculpatory. Still
compulsory members have no idea that the Texas Bar will behave that way when the opportunity
arises and the incentives to cancel exist. Plaintiff Robins certainly did not know, after years of

15
detrimental reliance and misplaced trust while the Bar defendants increasingly make a fortune
each year out of the annual $60 million dollar Bar budget.

43. All Texans suffer either directly or indirectly from such predatory misdeeds. These
transgressions directly and adversely affected Plaintiff Robins in ways for which he seeks
redress, plus damages & attorney’s fees. Although the Defendants rejected his ongoing request
for license reinstatement and a restored ethically spotless license status, they have categorically
denied it, making further settlement discussions futile. Meanwhile though:

COUNT 2: COMMON LAW FRAUD
44. Plaintiff Robins hereby incorporates by reference the abovementioned assertions for
inclusion in his descriptions of the remaining allegations & assertions.

45. The Bar defendants rrepresented to Plaintiff Robins that they are honest, dependable,
supportive and the like, only to be anything but when they sense that their pot of gold is
potentially threatened.

46. The Defendants’ representations to Plaintiff Robins were material, intentional,
reliance-inducing and ultimately harmful to him.

47. The Defendants’ representations were false statements of fact that surprisingly
enabled the Defendants to do considerable harm to Plaintiff Robins.

48. The Defendants made the false representations while aware of the risk that they would
prove to be false.

49. Plaintiff Robins detrimentally relied on the defendants’ false representations,
ultimately at considerable and ever-increasing expense.

22. The Defendants’ false representations directly and proximately caused enduring
injuries to the plaintiff, which resulted in plaintiffs’ damages that are partially listed in this
lawsuit.

23. The Plaintiff seeks unliquidated damages within the jurisdictional limits of this court.

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JURISDICTION & VENUE
44. This Court has jurisdiction over this case as Plaintiff Robins’ claims involve
encroachments upon his rights here in Harris County, Texas in violation of Texas’ statutory
authority.
45. Venue is similarly proper here, as well, pursuant to Tex. Civ. Prac. & Rem. Code §
15.002(a)(1), Tex. Bus. & Com. Code § 17.47(b). A substantial part of the events or omissions
giving rise to the Plaintiff’s claims occurred and continue to occur in Harris County, Texas.
Venue is also proper because the Plaintiff resides in Harris County.
46. Houston also happens to be where the Texas Bar’s very substantial facility at 4801
Woodway Dr #315w, Houston, TX 77056 remains located. The bar defendants required
Plaintiff Robins to endure a near 5 hour deposition there regarding this dispute, in fact,
before dragging him through a four day trial before a visiting judge here in Harris County.

PRAYER FOR RELIEF

47. The Bar defendants should be held accountable and be compelled to compensate
Plaintiff Robins including with immediately and enduringly ceasing with maintaining its
relevant sanctions against him (disbarment for a first time offender, who had never previously
been prosecuted for anything by any state bar during his approximately 30 year career, and
who has also never been convicted of any crime or even a traffic offense). The Defendants
should also be compelled to make financial reparations including costs and attorney’s fees
available to Plaintiff Robins, as the relevant statutory provisions actually or potentially require.
Plaintiff Robins previously had an ethically spotless bar ethics record.

WHEREFORE, Plaintiff Robins prays that this Court please issue the following relief:

a. A declaratory judgment requiring the bar defendants to reverse the Texas Bar’s
relevant disciplinary actions against him.

b. An order and judgment granting reasonable attorneys’ fees, damages and costs as
well as any other relief that this Court deems just and proper.

PLAINTIFF’S SWORN DECLARATION

17
“My name is Richard Robins. I am over the age of eighteen years old, and am of
sound mind. I have never been convicted of a misdemeanor or felony. I am fully competent
to attest to all of the facts set forth in this sworn declaration and accompanying lawsuit as I
have personal knowledge regarding them. I declare under penalty of perjury that the facts
stated in this lawsuit are true & correct, to the best of my knowledge.

Executed on June 10th, 2025.”

Respectfully submitted,

Rich Robins
(Pro se Plaintiff)
2450L ouisiana St. #400-155
Houston, TX 77006-2380
Rich@ConsumerRights.US
Tel. 832-350-1030
____________________________

Respectfully submitted:

Rich Robins
Pro Se Plaintiff
2450 Louisiana St. #400-155
Houston, TX 77006
Tel. 832-350-1030
Rich@ConsumerRights.US

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