Neil George Switkowski v. Courtney Sinclair Archbold

ACCEPTED
15-25-00155-CV
FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
10/20/2025 5:21 PM
IN THE FIFTEENTH COURT OF APPEALS CHRISTOPHER A. PRINE
CLERK
AUSTIN, TEXAS FILED IN
15th COURT OF APPEALS
AUSTIN, TEXAS
Cause No. 15-25-00155-CV 10/20/2025 5:21:02 PM
(On Transfer from the Third Court of Appeals) CHRISTOPHER A. PRINE
Cause No. 03-25-00416-CV Clerk

NEIL GEORGE SWITKOWSKI, Appellant
v.
COURTNEY SINCLAR ARCHBOLD
Appellee

Appellant’s Motion for Leave to File Reply Brief Out
of Time ARCHBOLD 15-25-00155-CV
TO THE HONORABLE JUSTICES OF THE FIFTEENTH COURT OF
APPEALS:
Appellant Neil George Switkowski respectfully moves for leave to file his
Reply Brief six days after the deadline. In support, Appellant shows the following:

I. Request for Leave to File Out of Time
1. Under TRAP 38.6(d) and 10.5(b), this Court may extend the time for filing a
reply brief upon a showing of good cause.
2. Appellant’s reply brief was due October 13, 2025, and was tendered for filing
on October 20, 2025, a delay of approximately six to seven days.
3. Good cause exists. The reply brief addresses multiple constitutional questions
of first impression concerning the Title IV-D enforcement scheme, requiring
extensive research and verification of historical and statutory authorities.
Additionally,
3.A: Appellant encountered unavoidable logistical related delays during final
preparation while moving everything he owns back into storage (now
homeless, again as of the first of November 2025) waiting to go back to jail
IN THE FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
Cause No. 15-25-00155-CV

on the 27th of October 2025 for a contempt hearing that has not been stayed
by the 20th District Court, Milam County TX.
4. Appellant acted diligently and in good faith. No prejudice will result to either
Appellee, and acceptance of the brief will aid the Court’s consideration of the
record.
Certificate of Conference
Pursuant to Texas Rule of Appellate Procedure 10.1(a)(5), Appellant certifies
that no conference with Appellee Courtney Sinclair Archbold has occurred.
Appellee remains in ongoing violation of Texas Penal Code § 25.03 (Interference
with Child Custody), constituting multiple state jail felony offenses. These acts
have deprived Appellant of all access to his minor children for over four years, in
open defiance of the Standard Possession Order.
Given Appellee’s continuing criminal conduct, no meaningful or good-
faith conference can occur until such violations cease and judicial intervention
restores lawful communication between the parties.
This motion does not seek rescheduling or relief requiring mutual consent; it
is fully within the discretion of this Honorable Court and therefore exempt from
ordinary conferencing requirements.

Discretion of the Court
This request lies solely within the discretion of this Honorable Court. Under
the Texas Rules of Appellate Procedure, only the Court may grant leave to file,
accept, or consider a motion outside standard deadline. Appellee has no
authority to consent to or deny such relief, nor can any opposing party exercise
judicial discretion reserved exclusively for the Court. Accordingly, Appellant
respectfully submits this motion to the Court’s sole jurisdiction for consideration
on its merits.

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Appellant’s Motion for Leave to File Reply Brief Out of Time ARCHBOLD
15-25-00155-CV
IN THE FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
Cause No. 15-25-00155-CV

Accordingly, Appellant respectfully requests that the Court grant leave and
deem the Reply Brief timely filed as of October 20, 2025.
III. Prayer
WHEREFORE, Appellant Neil George Switkowski respectfully prays that this
Honorable Court:
1. Grant leave to file the Reply Brief out of time and deem it timely as of
October 20, 2025;
2. Accept the attached Reply Brief for filing and consideration.
Respectfully submitted,

10/20/2025
Neil George Switkowski
Appellant, Pro Se
2203 Post Oak Rd
Rockdale TX 76567
512-850-0531
Ns512atx@gmail.com

3
Appellant’s Motion for Leave to File Reply Brief Out of Time ARCHBOLD
15-25-00155-CV
IN THE FIFTEENTH COURT OF APPEALS
AUSTIN, TEXAS
Cause No. 15-25-00155-CV

Certificate of Service
I certify that on October 20, 2025, a true and correct copy of this Motion was
served by electronic service through the Court’s e-filing system.

Neil George Switkowski
Mr. Deterrean Gamble
Assistant Attorney General
Child Support Division
P. O. Box 12017, Capitol Station
Austin, TX 78711-2017
* DELIVERED VIA E-MAIL *

Ms. Courtney Sinclair Archbold
227 E Bell Ave.
Rockdale, TX 76567
* DELIVERED VIA E-MAIL *

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Appellant’s Motion for Leave to File Reply Brief Out of Time ARCHBOLD
15-25-00155-CV
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: 107067287
Filing Code Description: Other Brief
Filing Description: APPELLANT'S REPLY BRIEF TO THE OFFICE OF
THE ATTORNEY GENERAL'S BRIEF OF APPELLEE
Status as of 10/21/2025 7:08 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

COURTNEY ARCHBOLD Courtneyarchbold@gmail.com 10/20/2025 5:21:02 PM SENT

NEIL G.SWITKOWSKI ns512atx@gmail.com 10/20/2025 5:21:02 PM SENT

Deterrean Gamble deterrean.gamble@oag.texas.gov 10/20/2025 5:21:02 PM SENT