Sammy Tawakkol v. Sheila Vasquez, in Her Official Capacity as Manager of the Texas Department of Public Safety- Sex Offender Registration Bureau; And Freeman F. Martin, in His Official Capacity as Director of the Texas Department of Public SafetySammy Tawakkol v. Sheila Vasquez, in Her Official Capacity as Manager of the Texas Department of Public Safety- Sex Offender Registration Bureau; And Freeman F. Martin, in His Official Capacity as Director of the Texas Department of Public Safety
Case Information
*0 FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS 5/12/2025 9:33:15 AM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 15-25-00009-CV FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 5/12/2025 9:33 AM Court of Appeals Number: 15-25-00009-CV CHRISTOPHER A. PRINE _________________ CLERK IN THE COURT OF APPEALS FOR THE FIFTEENTH JUDICIAL DISTRICT OF TEXAS SAMMY TAWAKKOL ,
Appellant ,
v. SHEILA VASQUEZ , in her Official Capacity as Manager of the Texas Department of Public Safety- Sex Offender Registration Bureau; and, FREEMAN F. MARTIN , in his Official Capacity as Director of the Texas Department of Public Safety; [*] Appellees
____________________ APPELLANT’S UNOPPOSED MOTION FOR LEAVE TO FILE CORRECTED BRIEF ____________________
TO THE HONORABLE PRESIDING JUSTICE AND ASSOCIATE JUSTICES
OF THE COURT OF APPEALS FOR THE FIFTEENTH DISTRICT OF TEXAS:
COMES NOW Sammy Tawakkol, Appellant on the above-referenced appeal, and, pursuant to the Texas Rules of Civil Procedure, files this Unopposed
Motion for Leave to File Corrected Brief , and in this connection would respectfully
show unto the Court as follows:
*2 1.
On May 6, 2025, Appellant Sammy Tawakkol (“Appellant”) timely submitted his brief on appeal in this case. However, after his brief was accepted
and filed by the Clerk, Appellant discovered the index to his brief mistakenly
includes a heading that inadvertently contains a remnant (one sentence) from the
index to a brief previously filed in an unrelated case. The Appellant seeks leave to
file a corrected brief that deletes this error. † The corrected brief, which has been
contemporaneously submitted with this motion as a separate “lead” document,
contains no other alteration of the brief previously submitted by Appellant.
PRAYER
WHERFORE PREMISES CONSIDERED, Appellant Tawakkol prays this
motion for leave to file his corrected brief will in all things be granted.
Respectfully submitted, /s/Richard Gladden Texas Bar No. 07991330 Attorney-in-Charge for Appellant 1204 West University Dr. Ste. 307 Denton, Texas 76201 940/323-9300 (voice) 940/539-0093 (fax) richscot1@hotmail.com (email) † To view the sentence to be deleted in the corrected brief, see Appellant’s first brief, at page ii, ¶
VI (a)(1) (“ The District Court Erred by Granting Plaintiff’s Motion to Strike Defendant-
Intervenor’s Petition in Intervention without First Determining Whether it had Jurisdiction over
Plaintiff’s Original Petition. ”).
CERTIFICATE OF CONFERENCE This is to certify that on May 7, 2025, undersigned counsel for Appellant Tawakkol communicated via email with Christopher Lindsey, Counsel of Record
on this appeal for Defendants Sheila Vasquez and Freeman F. Martin, and that on
that date Mr. Lindsey authorized me to advise the Court that the Defendants DO
NOT OPPOSE the relief sought by Appellant Tawakkol in this motion.
/s/ Richard Gladden CERTIFICATE OF SERVICE This is to certify that a true copy of the foregoing motion was served on the Defendants by use of the electronic filing system, E-File Texas, on their attorney of
record on this appeal Christopher Lindsey, on this 12 th day of May, 2025, in
accordance with the Texas Rules of Appellate Procedure.
/s/ Richard Gladden *4 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.
Richard Gladden
Bar No. 07991330
richscot1@hotmail.com
Envelope ID: 100695664
Filing Code Description: Motion
Filing Description: Appellant's Unopposed Motion for Leave to File
Corrected Brief
Status as of 5/12/2025 9:56 AM CST
Associated Case Party: Sammy Tawakkol
Name BarNumber Email TimestampSubmitted Status
Richard Gladden richscot1@hotmail.com 5/12/2025 9:33:15 AM SENT
Terri Sparks terri.with.gladdenlaw@gmail.com 5/12/2025 9:33:15 AM SENT
Associated Case Party: Steven McCraw
Name BarNumber Email TimestampSubmitted Status
Christopher Lindsey 24065628 Christopher.Lindsey@oag.texas.gov 5/12/2025 9:33:15 AM SENT
Associated Case Party: Sheila Vasquez
Name BarNumber Email TimestampSubmitted Status
Christopher Lindsey 24065628 Christopher.Lindsey@oag.texas.gov 5/12/2025 9:33:15 AM SENT
Case Contacts
Name BarNumber Email TimestampSubmitted Status
Eric Abels Eric.Abels@oag.texas.gov 5/12/2025 9:33:15 AM SENT
Notes
[*] Steven McCraw, who in his official capacity as Director of the Texas Department of Public Safety was previously a named defendant in this case, was succeeded by Freeman F. Martin on December 2, 2024. In accordance with Rule 7.2(a) of the Texas Rules of Appellate Procedure, Director Freeman has been automatically substituted in Director McCraw’s place on this appeal.