Ugalahi Offoboche v. Collin County, Texas, Collin County Sheriff's Deputies Mounger, Watson, and McMillan and Former Collin County Chief Deputy Constable Rumfield

ACCEPTED
15-25-00044-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
9/11/2025 8:51 AM
CAUSE NO. 15-25-00044-CV CHRISTOPHER A. PRINE
CLERK
IN THE COURT OF APPEALS FILED IN
15th COURT OF APPEALS
AUSTIN, TEXAS
FOR THE FIFTEENTH DISTRICT OF TEXAS
9/11/2025 8:51:54 AM
CHRISTOPHER A. PRINE
AUSTIN, TEXAS Clerk

________________________________________________________________________

UGALAHI OFFOBOCHE
Appellant

VS.

COLLIN COUNTY, TEXAS, COLLIN COUNTY SHERIFF’S DEPUTIES
MOUNGER, WATSON, McMILAN AND FORMER COLLIN COUNTY CHIEF
DEPUTY CONSTABLE RUMFIELD

Appellees

________________________________________________________________________

Appeal from Cause No. 429-08578-2024, 429TH Judicial District Court,
Collin County, Texas, The Honorable Jill Willis, Judge Presiding
______________________________________________________________________________

APPELLEES’ RESPONSE TO APPELLANT’S MOTION
FOR FIVE DAYS’ EXTENSION OF TIME TO COMPLETE
AND FILE REPLY BRIEF AND FOR LEAVE TO FILE CORRECTED BRIEF
______________________________________________________________________________

TO THE HONORABLE FIFTEENTH COURT OF APPEALS:

COME NOW Collin County, Texas, Collin County Sheriff’s Deputies Joshua

Mounger, Mark Watson, Lee McMillan and former Collin County Chief Deputy

Constable Mike Rumfield, Appellees herein and movants in the trial court, and file their

RESPONSE TO APPELLEE’S MOTION FOR FIVE DAYS’ EXTENSION OF TIME TO COMPLETE AND FILE

REPLY BRIEF AND FOR LEAVE TO FILE CORRECTED BRIEF, and would show the Court as follows:

APPELLEES’ RESPONSE TO APPELLANT’S MOTION FOR FIVE DAY EXTENSION, et. al. PAGE 1
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I.
Appellant’s misstatement of material facts and refusal to correct same is basis
for Appellants’ inability to agree to further “corrections” to Appellant’s Brief

Appellant Ugalahi Offoboche, the sanctioned attorney who is representing herself herein,

has already twice submitted her Brief. See, APPELLANT’S BRIEF, submitted June 24, 2025, and

APPELLANT’S AMENDED BRIEF, submitted June 25, 2025. She now seeks to file what she entitles

her APPELLANT’S CORRECTED (AMENDED) BRIEF as well as seeking a five day extension to file her

Reply Brief.

It is not the requested extension to file her Reply Brief which causes Appellees’ consternation

- it is Appellant’s refusal to correct material mis-statements in her briefing to this Court about her

and her clients role in the Public Information Act requests and resulting Attorney General Opinions.

Appellant represents to this Court that “there is nothing in the attached opinion rulings that shows

appellant was the requestor or was attempting to obtain law enforcement records” See, i.e.

APPELLANT’S AMENDED BRIEF, p. 15. Disappointingly, Appellant certainly knows this is not correct.

See, APPENDIX EX.’S 1-4 attached to BRIEF OF APPELLEES regarding the series of Public Information

Act requests and resulting Texas Attorney General decisions directly related to/from Appellant

and/or her clients. When contacted by Appellant for a conference on her motion, Appellant was

asked to correct her misstatements but she refused. A copy of emails is attached as Exhibit No. 1.

Appellees do not oppose an extension for Appellant to file a Reply Brief but do oppose

Appellant’s ongoing mis-statement of facts to this Court and Appellant’s efforts to minimize briefing

failures and misleading case citations and holdings to this Court. See, i.e., Appellant’s citation to

In re J.M.1 for a holding which does not appear in the case.

1
cited in APPELLANT’S AMENDED BRIEF, p. 41. Appellant’s misrepresentations about the In re J.M. case are
discussed in BRIEF OF APPELLEES, p. 11-12.

APPELLEES’ RESPONSE TO APPELLANT’S MOTION FOR FIVE DAY EXTENSION, et. al. PAGE 2
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II.
Prayer for Relief

WHEREFORE, PREMISES CONSIDERED, Appellees Collin County, Texas, Collin

County Sheriff’s Deputies Joshua Mounger, Mark Watson, Lee McMillan and former Collin

County Chief Deputy Constable Mike Rumfield pray that this Honorable Court of Appeals affirm

the January 30, 2025, FINAL JUDGMENT, PROTECTIVE ORDER, AND ORDER OF SANCTIONS AGAINST

COUNSEL UGALAHI OFFOBOCHE; and that Appellees have such other and further relief to which they

may show themselves justly entitled.
Respectfully submitted,

By: /s/ Robert J. Davis
ROBERT J. DAVIS
State Bar No. 05543500
KYLE T. BARRY
State Bar No. 24122284
MATTHEWS, SHIELS, KNOTT,
EDEN, DAVIS & BEANLAND, L.L.P.
8131 LBJ Freeway, Suite 700
Dallas, Texas 75251
972/234-3400 (office)
972/234-1750 (telecopier
bdavis@mssattorneys.com
kbarry@mssattorneys.com

ATTORNEY FOR MOVANTS/APPELLEES
COLLIN COUNTY, TEXAS, COLLIN
COUNTY DEPUTIES JOSHUA MOUNGER,
MARK WATSON, LEE McMILLAN, and
CHIEF DEPUTY CONSTABLE MICHAEL
RUMFIELD

CERTIFICATE OF SERVICE

This is to certify that, pursuant to Tex. R. App. P. 9.5, on this the 10th day of September, 2025, a true
and correct copy of the foregoing instrument was served upon Appellant’s counsel via e-service.

/s/ Robert J. Davis
ROBERT J. DAVIS

APPELLEES’ RESPONSE TO APPELLANT’S MOTION FOR FIVE DAY EXTENSION, et. al. PAGE 3
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From: Ugy Offoboche <ugy@uacoffobochelaw.com>
Sent: Friday, September 5, 2025 5:19 PM
To: Bob Davis <bdavis@mssattorneys.com>
Cc: Kyle Barry <kbarry@mssattorneys.com>
Subject: Re: Conference Requirement: Corrected Brief

LOL...okay.

With Kind Regards,

Ugalahi Ugy Offoboche, Esq.
Managing Attorney
U. A. C. OFFOBOCHE LAW FIRM
469-315-0358 (Direct)
214-853-5708 (Fax)
ugy@uacoffobochelaw.com
www.uacoffobochelaw.com
"Dedicated & Thorough"

"A man convinced against his will is of the same opinion still." Anonymous
"Forgiveness is only beneficial if given to one who does not deserve it." Clairecut

The content of this communication may be confidential and/or proprietary to U.A.C.
Offoboche Law Firm. The information transmitted herein is intended only for use by the
individual(s) or entity(ies) to which it is addressed and may be information that is legally
privileged, confidential and/or exempt from disclosure under applicable law. If the reader
of this message is not the intended recipient, you are hereby notified that any review,
transmission or retransmission, dissemination, distribution, copying or other use of, or
taking of any action in reliance upon this information is strictly prohibited. If you have
received this communication in error, please notify the sender immediately by email and
delete the communication.

On Fri, Sep 5, 2025 at 5:13 PM Bob Davis <bdavis@mssattorneys.com> wrote:

Yes

Robert J. Davis

Partner

Matthews, Shiels, Knott, Eden, Davis & Beanland, L.L.P.

8131 LBJ Freeway, Suite 700

Dallas, Texas 75251

(972) 234-3400
From: Ugy Offoboche <ugy@uacoffobochelaw.com>
Sent: Friday, September 5, 2025 5:12 PM
To: Bob Davis <bdavis@mssattorneys.com>
Cc: Kyle Barry <kbarry@mssattorneys.com>
Subject: Re: Conference Requirement: Corrected Brief

That statement is false! I will be requesting 5-days extension to file my reply brief. Are
you opposed?

With Kind Regards,

Ugalahi Ugy Offoboche, Esq.

Managing Attorney
U. A. C. OFFOBOCHE LAW FIRM

469-315-0358 (Direct)
214-853-5708 (Fax)
ugy@uacoffobochelaw.com
www.uacoffobochelaw.com
"Dedicated & Thorough"

"A man convinced against his will is of the same opinion still." Anonymous
"Forgiveness is only beneficial if given to one who does not deserve it." Clairecut

The content of this communication may be confidential and/or proprietary to U.A.C.
Offoboche Law Firm. The information transmitted herein is intended only for use by the
individual(s) or entity(ies) to which it is addressed and may be information that is legally
privileged, confidential and/or exempt from disclosure under applicable law. If the reader
of this message is not the intended recipient, you are hereby notified that any review,
transmission or retransmission, dissemination, distribution, copying or other use of, or
taking of any action in reliance upon this information is strictly prohibited. If you have
received this communication in error, please notify the sender immediately by email and
delete the communication.

On Fri, Sep 5, 2025 at 5:05 PM Bob Davis <bdavis@mssattorneys.com> wrote:

Misstatements about your and your clients role in the Public Information Act requests and
corresponding AG opinions.
Robert J. Davis

Partner

Matthews, Shiels, Knott, Eden, Davis & Beanland, L.L.P.

8131 LBJ Freeway, Suite 700

Dallas, Texas 75251

(972) 234-3400

From: Ugy Offoboche <ugy@uacoffobochelaw.com>
Sent: Friday, September 5, 2025 5:05 PM
To: Bob Davis <bdavis@mssattorneys.com>
Cc: Kyle Barry <kbarry@mssattorneys.com>
Subject: Re: Conference Requirement: Corrected Brief

They were no misstatements only human error. I'll let the appellate Court know that you
are opposed.

With Kind Regards,

Ugalahi Ugy Offoboche, Esq.

Managing Attorney
U. A. C. OFFOBOCHE LAW FIRM

469-315-0358 (Direct)
214-853-5708 (Fax)
ugy@uacoffobochelaw.com
www.uacoffobochelaw.com
"Dedicated & Thorough"

"A man convinced against his will is of the same opinion still." Anonymous
"Forgiveness is only beneficial if given to one who does not deserve it." Clairecut

The content of this communication may be confidential and/or proprietary to U.A.C.
Offoboche Law Firm. The information transmitted herein is intended only for use by the
individual(s) or entity(ies) to which it is addressed and may be information that is legally
privileged, confidential and/or exempt from disclosure under applicable law. If the reader
of this message is not the intended recipient, you are hereby notified that any review,
transmission or retransmission, dissemination, distribution, copying or other use of, or
taking of any action in reliance upon this information is strictly prohibited. If you have
received this communication in error, please notify the sender immediately by email and
delete the communication.

On Fri, Sep 5, 2025, 5:00 PM Bob Davis <bdavis@mssattorneys.com> wrote:

We are opposed. I would also urge you to correct the misstatements about you and your clients’
role in the Public Information Act requests.

Robert J. Davis

Partner

Matthews, Shiels, Knott, Eden, Davis & Beanland, L.L.P.

8131 LBJ Freeway, Suite 700

Dallas, Texas 75251

(972) 234-3400

From: Ugy Offoboche <ugy@uacoffobochelaw.com>
Sent: Thursday, September 4, 2025 7:03 PM
To: Bob Davis <bdavis@mssattorneys.com>; Kyle Barry <kbarry@mssattorneys.com>
Subject: Conference Requirement: Corrected Brief

Messes David and Barry,

I have read your brief and note the omissions which I had earlier notified the court about in
my motion for leave when I was unable to see to correct those. I need to correct the page
number for the Medlin case, which should be 285. I also need to include the Medlin case
on which I was relying and quoted but omitted to cite after the J. M. case. I would like to file
a corrected brief to include the missing page number and to include the Medlin case where
it was omitted. I will not be including new arguments in the corrected brief. Will you oppose
my filing the corrected brief?

If no, after correcting the brief then I will file a reply brief. Does this work for you?
With Kind Regards,

Ugalahi Ugy Offoboche, Esq.

Managing Attorney
U. A. C. OFFOBOCHE LAW FIRM

469-315-0358 (Direct)
214-853-5708 (Fax)
ugy@uacoffobochelaw.com
www.uacoffobochelaw.com
"Dedicated & Thorough"

"A man convinced against his will is of the same opinion still." Anonymous
"Forgiveness is only beneficial if given to one who does not deserve it." Clairecut

The content of this communication may be confidential and/or proprietary to U.A.C.
Offoboche Law Firm. The information transmitted herein is intended only for use by the
individual(s) or entity(ies) to which it is addressed and may be information that is legally
privileged, confidential and/or exempt from disclosure under applicable law. If the reader
of this message is not the intended recipient, you are hereby notified that any review,
transmission or retransmission, dissemination, distribution, copying or other use of, or
taking of any action in reliance upon this information is strictly prohibited. If you have
received this communication in error, please notify the sender immediately by email and
delete the communication.
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.

Robert Davis on behalf of Robert Davis
Bar No. 05543500
bdavis@mssattorneys.com
Envelope ID: 105480624
Filing Code Description: Response
Filing Description: APPELLEES??? RESPONSE TO APPELLANT???S
MOTION FOR FIVE DAYS??? EXTENSION OF TIME TO COMPLETE
AND FILE REPLY BRIEF AND FOR LEAVE TO FILE CORRECTED
BRIEF
Status as of 9/11/2025 8:56 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Ugalahi UgyOffoboche ugy@uacoffobochelaw.com 9/11/2025 8:51:54 AM SENT

Robert J.Davis bdavis@mssattorneys.com 9/11/2025 8:51:54 AM SENT

Robert J.Davis bdavis@mssattorneys.com 9/11/2025 8:51:54 AM SENT

Robert J.Davis bdavis@mssattorneys.com 9/11/2025 8:51:54 AM SENT

Kyle T.Barry kbarry@mssattorneys.com 9/11/2025 8:51:54 AM SENT

Kyle T.Barry kbarry@mssattorneys.com 9/11/2025 8:51:54 AM SENT