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
9/22/2025 1:30 AM
CHRISTOPHER A. PRINE
CLERK
No. 15-25-00144-CV
FILED IN
15th COURT OF APPEALS
IN THE AUSTIN, TEXAS
9/22/2025 1:30:33 AM
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 MOTION TO FILE HIS AMENDED RESPONSE IN
OPPOSITION 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

1
___________________________________________________________

APPELLANT’S MOTION TO FILE HIS AMENDED RESPONSE IN
OPPOSITION TO THE COURT’S TRANSFER ADVISORY

___________________________________________________________

Sept. 22nd, 2025

Pro se appellant Rich Robins hereby files this motion to file his amended
response to the court’s pending ejection notice.

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 motion to have his
AMENDED response to the 15th Court of Appeals’ advisory of transfer
accepted. He is filing it moments after filing this motion. As further
background, Appellant Robins mentions the following...

B. Facts

4. Appellant Robins has worked earnestly to try to understand the
15th Court of 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. While he
e-filed a timely response by the deadline date of Friday, September 19 th,
2
2025, it needed improvement. Amidst recent computer woes reiterated
below, Appellant Robins somehow inadvertently inserted as his exhibit his
next-to-last (instead of his most recent) petition filed with the trial court
here in Harris County. He has remedied that, while also clarifying a few
points made in his response.

5. Last week, Appellant Robins sought an extension of one month,
but only got 4 days. He adapted as best he could to those, and other
challenging circumstances though. As previously mentioned,
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 even
today. Some of that data has been necessary for Appellant Robins’ further
formulating and fortifying his response to the 15th Court of Appeals’ recent
ejection notice. Its inaccessibility is unfortunate.

C. Argument & Authorities

6. The Court of Appeals has the authority to amend a brief, etc.
pursuant to TRAP 38.7. etc. Fortunately the amended version is being filed
contemporaneously with this motion, though. 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.

3
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 amendment has been 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. 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’ 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
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
4
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 to have his
amended response accepted. It is being filed contemporaneously (albeit
separately) from this motion.

Sincerely submitted:

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

5
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 to amend his response 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 22nd, 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

6
No. 15-25-00144-CV

CERTIFICATE OF CONFERENCE

Appellant Robins e-mailed Appellee’s counsel Michael Graham about a
deadline extension request of up until October of 2025, back on September
15th, 2025. Although it was unopposed, Appellant Robins only received a 4
day extension from the court. Appellant Robins needs to e-file this ASAP,
before opposing counsel will re-awaken. It seems axiomatic, though, that
his having already approved until October the filing of this response means
that the modification submitted early in the morning of the first business day
after the (satisfied, yet much more brief) deadline is approved by opposing
counsel. If not, he is welcome to comment accordingly when he re-
awakens.

Sincerely submitted:

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

7
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: 105876949
Filing Code Description: Motion
Filing Description: Motion to have accompanying amended response
accepted.
Status as of 9/22/2025 7:31 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Michael Graham 24113581 Michael.Graham@TEXASBAR.COM 9/22/2025 1:30:33 AM SENT