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
9/19/2025 11:57 PM
CHRISTOPHER A. PRINE
CLERK
No. 15-25-00144-CV
FILED IN
15th COURT OF APPEALS
IN THE AUSTIN, TEXAS
9/19/2025 11:57:05 PM
CHRISTOPHER A. PRINE
15th COURT OF APPEALS 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 RESPONSE RESPECTFULLY OPPOSING THE
COURT’S EJECTION NOTICE REGARDING THIS CASE

___________________________________________________________

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 RESPONSE RESPECTFULLY OPPOSING THE
COURT’S EJECTION NOTICE REGARDING THIS CASE

___________________________________________________________

Sept. 19th, 2025

Pro se appellant Rich Robins hereby files this opposition response to the
court’s pending ejection notice regarding his case.

A. Introduction

1. The Appellees (Plaintiffs at the trial court level) are 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 respectfully files this opposition
to the Court’s pending ejection of this case. As further background,
Appellant Robins mentions the following...

B. Facts

4. Appellant Robins includes Exhibit 1, below, as his trial court
petition filed pursuant to the Texas Deceptive Trade Practices Act against
the State Bar of Texas, et al.

C. Argument & Authorities

Procedural background

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5. Appellant 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. The judgment very hastily dismissed Robins’
Deceptive Trade Practices Act (DTPA) claims against the Appellees, based
on mere TRCP 91a grounds. Appellant 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. Tamika Craft
filed no response whatsoever while the 1st Court of Appeals still refrains
from ruling on a longstanding case there which challenges the legitimacy
of her purported and very narrow electoral victory of 2022. See Erin
Lunceford v. Tamika Craft, No. 01-23-00921-CV (Tex. App.—Houston [1st
Dist.] Dec. 12th, 2023). More than one justice in that court is not only a
member of the State Bar of Texas but also an officer in it. Appellant
Robins has previously politely filed a motion to recuse Andrew Johnson in
that court regarding Robins’ underlying dispute with the Texas Bar, and it
was expeditiously denied. The 1st Court of Appeals similarly demanded
that his administrative case transfer attempt to the 15th Court of Appeals
(initially approved by the 15th Court of Appeals, too) be denied, too.

Facts underlying the Appellees’
ethics violation accusations against Appellant Robins

6. In part, this case is about the ethics rules-related consequences
inflicted by the Appellees upon Appellant Robins. They primarily relate
to his having not rushed to formally declare to a never-visited (by him),
faraway court up in Tyler, Texas the (undocumented) reported death of a
female client & eventual litigant (Cindy Crisp). She was approximately 59

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years old when Appellant 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 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. Appellant Robins
inserted in the lawsuit that the Appellant 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. Appellant Robins filed the lawsuit
in Tyler, which he has since only visited for a single day, ever, nearly a
year after filing the abovementioned lawsuit and months after Robins had
already taken the initiative to report the possibility of the (then still
undocumented) death to the court.

7. No rule, not even TRCP 151, authorized Appellant Robins’
disclosing that she was reportedly dead and thereby subjecting her and her
family to identity theft risks, and even worse if she was actually still alive
(such as a forced hospitalized death for organ donation purposes). No
obituary was ever published for her, either. Meanwhile, Appellant Robins
was officially and repeatedly 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
Appellant Robins pursued for her. Appellant 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 file collections actions.

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Furthermore, there is still no way to exclude the possibility that the client
is confidentially cryopreserved, either. Cryonics 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.

8. Appellant 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 appellees in this appeal mocked and scorned Appellant Robins’
cryonics-related precautions, in writing, as he can easily prove.

9. Because of Appellant Robins’ taking months to investigate
before voluntarily mentioning the client’s supposed passing to the court
months before his lone visit there days after a devastating Houston
hurricane (Harvey), the Commission for Lawyer Discipline accused him of
misrepresenting, just like it did to its fairly recent grievance prosecution
appellees Brent Webster, Ken Paxton & Sidney Powell (etc.). The
Texas Bar appellees inflicted on Appellant 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 (Exhibit 1) provides additional details. Meanwhile:

The Fifteenth Court of Appeals’ involvement is needed to help make
the State Bar of Texas’ ethics rule interpretations uniform statewide.

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10. By litigating this dispute in the 15th Court of Appeals, we can
jointly make it clear at the statewide level what the Bar appellees’ ethics
rules actually permissibly mean. Regarding the Bar appellees’ boundless
rule prohibiting attorney misrepresentations, for example, we can get
statewide clarity regarding at what point one may even disclose a client’s
rumored but nevertheless undocumented death despite intimidatingly strict
ethics rules protecting client confidentiality. 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, Oregon and 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 state agencies,
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…

11. Appellant Robins appeals the judgment in this DTPA 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.

12. The 15th Court has exclusive intermediate appellate jurisdiction
over certain enumerated matters. Tex. Gov’t Code §22.220(d); §25A.007.

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13. 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.

14. 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 legal climate has since evolved, though, in part due to
new jurisprudence from the Supreme Court of Texas. It is time to let this
jurisdictional debate regarding the State Bar of Texas go directly to the
Supreme Court of Texas, for the good of nearly all Texans who want
governmental rules (such as attorney ethics ones) to be interpreted
similarly throughout the entire state.

15. 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 substantially differently,
depending upon the appellate district. Sometimes a lawyer’s services
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 appellees. The resulting

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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

16. 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 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.

17. The Legislature’s use of a 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

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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.

18. “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.

19. An appeal against the State Bar of Texas falls into, at the very

least, category (i) mentioned above (“by or against the state”). The

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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 State Bar appellees 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:

20. 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”.

21. 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: “I will only eat
apples or bananas grown in my garden." There the phrase "grown in my

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garden" is understood to modify only "bananas," not "apples," according to
the doctrine of last antecedent. A more elaborate example is “[i]nsecticide
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 matter against
the state qualifies for the Fifteenth Court of Appeals even if it is not one in
the executive branch.

22. Those who feel intimidated with a perception that the presence
of the words “executive branch” in the jurisdictional sentence beginning
with “matters against the state” yields ambiguity can find solace in the
following news. The Supreme Court of Texas has recently stated in
Kelley v. Homminga that if constitutional or statutory “language is
susceptible of two constructions, one of which will carry out and the other
defeat its manifest object, courts should apply the former construction.”
Dallas County, 697 S.W.3d at 159 (cleaned up) (quoting SCALIA &
GARNER, supra, at 63). Kelley v. Homminga, 706 S.W. 39 829, 832 (Tex
2025).

23. What is the statutory language’s “manifest object” then? In
looking back to Senate Bill 1045 from the 88 th regular legislative session
of Texas, the Senate Research Center’s bill analysis expressly states the
following:

Under the current judicial system, appeals in cases of statewide significance are
decided by one of Texas's 14 intermediate appellate courts. These courts have

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varying levels of experience with the complex legal issues involved in cases of
statewide significance, resulting in inconsistent results for litigants.

S.B. 1045 addresses these problems by establishing an intermediate court of
appeals with exclusive jurisdiction over cases to which the state, a state agency,
or a state official is a party. The justices on this new Fifteenth Court of Appeals
are elected statewide, ensuring that all Texans have a voice in the selection of
judges who decide cases of statewide importance. See Texas Senate Research
Center, Bill Analysis for S.B. 1045, 88th Leg., R.S., (2023).

Is it not remarkable that the legislative intent behind the bill is to grant
exclusive jurisdiction to the 15th Court of Appeals for cases to which “a
state agency” is a party? Nowhere in that entire bill analysis does the
Senate Research Center even so much as hint at an exclusion or
exemption for the state agency known as the State Bar of Texas. Why
should it?

24. The State Bar of Texas readily refers to itself as a state
agency, too, while clinging to sovereign immunity to the detriment of
arguably nearly all Texans. Indeed, through a combination of a sovereign
immunity claim and an astonishing disbarment pursuit against Appellant
Robins, the State Bar of Texas eventually got Appellant Robins’ federal
class action lawsuit against that bar dismissed. In the process, this
rendered fellow compulsory bar members without compensatory remedies
even after the McDonald v. Longley outcome from the 5th Circuit
established that that bar had been noncompliant and unconstitutional. See:
McDonald v. Longley, 4 F 4th 229 (5th Cir. 2021). See generally
https://www.reuters.com/legal/legalindustry/state-bar-texas-faces-fresh-
challenge-mandatory-dues-2021-08-31/ . The Texas Bar may not have its
cake and eat it too, though...

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Constitutional authorities

25. 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 Appellant 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. To the contrary, statutory
authority requires access for Robins’ matter against the State Bar of Texas.
Applying an imaginary prohibition by making matters against the state be
applicable only to the executive branch would arguably be
unconstitutional.

26. 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. Appellant Robins has
interstate involvement that arguably qualifies him for such protections. He
took the State Bar of Texas at its word that it would adjudicate not
predatorily, but rather helpfully, so that attorneys could feel comfortable
assisting an increasing amount of clients 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 the disbarment that the State Bar of Texas demanded
against him which was preceded by nearly 3 decades of his otherwise
ethically spotless (and still criminally spotless) record.

27. The 15th Court of Appeals has a uniquely statewide audience &
electorate, and a specialized focus that can be particularly useful. Local
13
appellate courts do not have that, nor are they designed to. Furthermore,
the State Bar of Texas 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. See also: McDonald v.
Longley, 4 F 4th 229 (5th Cir. 2021) & Boudreaux v. La. State Bar Ass'n,
86 F.4th 620 (5th Cir. 2023).

28. Indeed, the 5th Circuit Court of Federal Appeals has has
adjudicated substantially against activities previously zealously embraced
by the State Bar of Texas. Meanwhile, the State Bar of Texas “forgot” to
even mention its rampant embezzlement problem during the most recent
Sunset Review (2016-17), as we document here:
http://www.TexasBarSunset.com/embezzling . Fortunately we were there
to help remind them. In fact, Appellant Robins was the only one to even
mention the rampant bar theft problem (which lasted nearly a decade) in all
of the public comments filed. See
https://web.archive.org/web/20210501083002/https://www.sunset.texas.go
v/reviews-and-reports/agencies/comments/1331. The State Bar of Texas
gave awards to legal counsel who represented 9/11/01 terrorists, but only
gave lawfare to Appellant Robins for having protected the public from that
bar’s cloaked attempts to get unlimited dues-increase authority pursuant to
the Sunset Review, without even notifying (much less seeking referendum
approval from) still compulsory bar members.

29. Incidentally, bar lawfare has become increasingly interesting to
entities ranging from the Federalist Society:

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https://fedsoc.org/events/ethics-or-ideology-bar-associations-and-the-
boundaries-of-professional-discipline

to the White House: http://www.EastmanDilemma.com

30. Appellant 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 jurisdiction of the 15 th Court of Appeals, even
as it does exclude other sorts of disputes involving the government,
especially in criminal law. So why exclude Appellant Robins’ appeal?
The 15th Court of Appeals exists for matters against the state, after all.
Meanwhile, constitutions are made to be respected.

31. 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.

32. Furthermore, the Supreme Court of Texas has stated that when
construing a statute, we give effect to all its words and, if possible, do not
treat any statutory language as mere surplusage. Cont'l Cas. Ins. Co. v.
Functional Restoration Assocs., 19 S.W.3d 393, 402 (Tex.2000).

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33. In Baumgardner v. Brazos River Authority, the Supreme Court
recently expressly referred to “jurisdiction-exercising state agencies.”
Baumgardner v. Brazos River Authority, 714 S.W.3d 597, 604 (2025)
(emphasis added). Is there anyone reading this appellant opposition to
transfer letter who somehow doubts that that phrase means to the
Supreme Court of Texas that if an entity is a state agency, it has
jurisdiction in the 15th Court of Appeals? The Court found that the
Brazos River Authority is not a part of the executive branch. However,
that does not mean that the Court is asserting that a matter against the
state must directly involve the executive branch.

2 prior misdirections:

34. While it is true that the Supreme Court of Texas initially denied
Appellant Robins motion to transfer his administrative case vs. the State
Bar of Texas over to the 15th Court of Appeals, they have yet to rule on his
request for a rehearing which he e-mailed them within a day, or so, of
randomly discovering the basically unannounced denial, back during the
Christmas holiday of 2024. The 1st Court of Appeals had demanded that
Robins’ administrative case transfer attempt to the 15th Court of Appeals
(initially approved by the 15th Court of Appeals, too) be denied. The
Supreme Court subsequently gave no explanation for its initial denial, but
the matter’s having had the 1st Court of Appeals’ thumb on the scales may
be the reason. At any rate, Robins’ pending administrative case slightly
predated the creation of the 15th Court of Appeals, to which Appellant
Robins zealously sought a transfer on the court’s opening morning. Thus,
that matter is distinguishable from the present one.

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35. So is Appellant Robins’ subsequent attempt to transfer his
Religious Freedom Restoration Act (RFRA) case from the 14th (where it
was never intended to go before a court clerk mysteriously mis-directed it)
to the 15th Court of Appeals. District Court judge Tamika Craft summarily
dismissed that case, too, again with no explanation and while the 1st Court
of Appeals continues to bestow upon her a victory through eventual
mootness at the expense of Harris County voters who want answers,
especially former judge Erin Lunceford who awaits her ruling. See Erin
Lunceford v. Tamika Craft, No. 01-23-00921-CV (Tex. App.—Houston [1st
Dist.] Dec. 12th, 2023). Meanwhile Robins’ letter request for a
reconsideration in the 14th Court of Appeals remains pending, as one does
in the Supreme Court of Texas.

D. Conclusion

36. Pro se appellant Rich Robins hereby thanks the Court for
considering this opposition and asks that the 15th Court of Appeals retain his
appeal. In the alternative, he asks that it do what is needed so that this
matter be conveyed to the Supreme Court of Texas before being (Robins
believes) unlawfully ejected back to a regional appellate court.

Sincerely submitted,

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

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Exhibit 1: Robins’ DTPA lawsuit:

CAUSE #202418660

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 RICH ROBINS’ 2ND AMENDED PETITION, ADDING
A CLAIM

COMES NOW, Plaintiff Rich Robins (hereinafter “Plaintiff Robins”,
the respondent named as the defendant in the Commission for Lawyer
Discipline’s lawsuit in case #2018-46488 in Harris County District Court
#61). Plaintiff Robins files this amended petition pursuant to Chapters 106
& 110 of Texas’ Civil Practice & Remedies Code. Chapter 110 comprises
Texas’ Religious Freedom Restoration Act (hereinafter the “RFRA”) and
Chapter 106 seemingly does, as well, albeit to a lesser extent. Plaintiff
Robins ALSO files this amended petition to add a claim against the
Defendants, pursuant to the Texas Deceptive Trade Practices Act. Plaintiff
Robins hereby asserts the following…

1. Plaintiff Robins brings this legal action against the State Bar of
Texas (hereinafter the “Texas Bar”), its Commission for Lawyer
Discipline (hereinafter the “CFLD”), and the Chief Disciplinary Counsel
(hereinafter the “CDC”); (hereinafter the “Bar defendants”). This is the
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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.

2. The denial of Plaintiff Robins’ request to get his RFRA claims
heard by the fact-finder in his abovementioned disciplinary trial is
presently on appeal. The RFRA’s applicability is also independently
pursued in district court, however. This is out of an abundance of caution
in case that appeal is not successful at getting the RFRA claims ever
addressed due to the Bar defendants’ puzzling claim of a lack of subject
matter jurisdiction in a grievance proceeding. The visiting trial court
judge granted the Texas Bar defendants’ request to exclude (Plaintiff)
Robins’ RFRA claims & defenses, thereby depriving the jury of the
opportunity to hear or see them and Mr. Robins of his right to a jury trial
on such matters, at the very least as a defense.
3. The Texas Bar in Austin, indeed, received Plaintiff Robins’
notice of the relevant RFRA accommodation period, and of its CFLD
petitioner’s allegedly discriminatory actions against him. The U.S.
Postal Service delivered that notice to the Texas Bar / CDC / CFLD there
on January 24th, 2023. Plaintiff Robins had previously stated in at least
one prior filing during the grievance proceedings that “[t]he Texas Bar in
Austin has received my notice of this RFRA accommodation period, and
of its CFLD petitioner’s pending & discriminatory actions against me.
The U.S. Postal Service delivered it to the Texas Bar on January 24 th,
2023. Here is the tracking number:
70212720000186333742
Meanwhile the confirmation of return card’s tracking number is:
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9590940272191284536905”

The notice politely included relevant court records, etc.

4. Such notice is not even required under all circumstances, as both
CPRC §106 & §110 state. See generally CPRC §110.006 and CPRC
§106.

BACKGROUND

5. 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.
6. 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
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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 . As this petition
will show, below, the same bar nevertheless prosecuted Plaintiff Robins
for investigating something, namely word of his client’s death from
someone on the phone whom Plaintiff Robins had never met, and who
received a hefty inheritance from her as a result of such a potentially
hasty declaration, thereby depriving Medicaid of compensation and quite
possibly 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 the court even as no
Texas state statute, state rule of civil procedure or binding state caselaw
requires or allows for such a disclosure. One statutory provision even
encourages one to wait seven years, while 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 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 case helps show.
8. All of the Texas Bar’s CFLD’s & CDC’s approximately five
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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 months’ delay under such circumstances is deceptive and grounds
for disbarment, even as apparently no state rule, law or case decision
labels it 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.
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 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
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
22
candid caretaker Robins, and viciously attacked his livelihood at the
expense of Plaintiff Robins’ religious rights including by depriving his
license as prohibited by religious freedom protections delineated at
CPRC §106.001. 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.

AFFIRMATIVE CLAIMS FOR RELIGIOUS
DISCRIMINATION

10. Plaintiff Robins mentions that during January of 2023, the
Texas Bar defendants, either directly or indirectly, revealed their
discriminatory 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 disclosures, the
CFLD’s and Texas Bar’s and arguably CDC’s prosecutor John
Brannon states (and bold faced text is included, verbatim):
“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.”

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11. Plaintiff Robins mentions that he did not even have to add the

emboldened nature of that concluding text. Plaintiff Robins 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 .

12. 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.

13. 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 (still

compulsory) bar members each year.

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14. 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?
15. Here is an example of what can happen to those (such as Robins’
client Cindy Crisp, who never discharged him…) 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.

16. Anyway, the Defendants’ treatment of Plaintiff Robins is in clear
violation of religious freedom protections that exist in the Texas Civil
Practice & Remedies Code's Chapter 110 and arguably Chapter

25
106.001 as well. 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 authorities. 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.

17. 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, and of identity theft that could
financially adversely affect the whole family. The Texas Bar has also not
prosecuted any other lawyer for doing something similar, as far as Plaintiff

26
Robins can tell.

18. 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’s access during pre-trial
proceedings, with the predictable result’s emerging. An appeal is
underway, and is an ongoing burden from which Plaintiff Robins is entitled
to relief.

Defendant Robins has endured and continues enduring
ongoing religious discrimination from the CFLD, the Texas Bar and
the CDC:

19. 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
27
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).

20. 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.

21. 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 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:

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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. As discovery has not gotten underway
yet (per a Rule 11 agreement recently submitted in opposition to the
Defendants’ motion to dismiss), it is not yet possible to provide elaborate
detail while the dismissal motion nevertheless purports to fault Plaintiff
Robins for that fact regarding this new lawsuit.

Sovereign immunity is waived:

22. Claims of sovereign immunity do not withstand scrutiny. The
RFRA 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
29
sue a government agency for damages allowed by that section.

Additionally, cases such as Richards v. Mena, 907 S.W.2d 566, 569
(Tex.App.--Corpus Christi 1995, writ dism’d) are 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.”

23. Additionally, the following case from the Texas Bar headquarters’
backyard of Austin, Texas further 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 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
30
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).

AFFIRMATIVE CLAIMS PURSUANT TO
THE TEXAS DECEPTIVE TRADE PRACTICES ACT
24. Plaintiff Robins incorporates the aforementioned as if set forth
fully herein. He also pursues claims against the Defendants pursuant to the
Texas Deceptive Trade Practices Act. The Defendants have engaged in
false, misleading & deceptive practices at Plaintiff Robins’ expense, and that
of the general public.

25. 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).

31
26. 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 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).

27. 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.”).

28. 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

32
benefits someone or something: deeds useful or instrumental toward some
object.”).

29. 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.”

30. 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
“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.”

31. The Texas Bar defendants have engaged 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. In the mean
time, though, they have represented that they take precautions for the bar
members’ benefit which they do not. They 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.
Additionally, they do not even attempt to comply sufficiently with religious
freedom requirements imposed on them by statute, even as they do not
readily (or otherwise) disclose that they will not comply. Furthermore, they
33
have purported to be in compliance with applicable laws when, as the 5 th
Circuit in McDonald v. Longley demonstrated, they have been far from it.
Meanwhile they falsely represent in writing that they cannot resolve a
client’s fee dispute with a member attorney, even as they nevertheless
meddle, interfere and subvert such a process in lieu of offering the legally
required mediation of grievances (especially when both sides requested a
peaceful, nonlitigious resolution). They also boast being a source of
attorney self-rule, only for the opposite to emerge after years of membership
persistence seeking precisely that. Additionally, they generate and provide
guidance materials which they reject when it suits their profit-seeking,
dissent-stifling, intimidating purposes. 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. Admittedly the Defendants deserve the 60 day
period contemplated in the statute to try to come into compliance…
Meanwhile though:

JURISDICTION & VENUE
32. This Court has jurisdiction over this case pursuant to, for
example, CPRC §110 as the Plaintiff’s claims involve encroachments
upon his rights here in Texas in violation of Texas’ statutory authority.
33. Venue is proper here, as well, because 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 lives in Harris County.
34. Houston also happens to be where the Texas Bar’s very
substantial facility at 4801 Woodway Dr #315w, Houston, TX 77056

34
remains located. The bar defendants required Plaintiff Robins to endure
a near 5 hour deposition there regarding this dispute, in fact.

PRAYER FOR RELIEF

35. 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

“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
35
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 February 10th, 2025.”

Respectfully submitted,

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

No. 15-25-00144-CV

CERTIFICATE OF SERVICE
36
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 19th, 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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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: 105865622
Filing Code Description: Letter
Filing Description: Opposition
Status as of 9/22/2025 7:28 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Michael Graham 24113581 Michael.Graham@TEXASBAR.COM 9/19/2025 11:57:05 PM SENT