Carolyn Barnes v. the Third Court of Appeals and the Supreme Court of Texas

Summarize Case

Related Cases

June 17, 2016 NO.03-15-00630-CV IN THE THIRD COURT OF APPEALS AUSTIN, TEXAS ^RECEIVED \ M 1 7 2016 CAROLYN BARNES, ET AL, APPELLANT \ THIRD COURT OfAPPEALS V \._ JEFFREY QCTj,E_X JEFF ROSE, THIRD COURT OF APPEALS AND NATHAN HECHT, TEXAS SUPREME COURT, APPELLEE MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF On Appeal From Cause No. D-1-GN-15-000877 From The 419th Judicial District Court Of Travis County, Texas TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, CAROLYN BARNES, et al, hereinafter referred to as BARNES, and files this motion to extend time for filing Appellant's Brief, and in support thereof would show the court as follows: 1. Barnes has ten briefs due because of the nature of the manner in which this case was handled by the trial court, the complete suspension of constitutional rights by the licensed attorneys and employees of this State, and the judicial edicts that are being issued sua sponte without any due process by Jeffrey Kyle. 2. It is not humanly possible to produce adequate, effective, or quality briefs in this manner and the court and licensed attorneys know it. ' Opposing counsel has not agreed to an extension of 90 days for filing Appellant's Brief. Appellant sent an email seeking an agreement, but received no response. The Texas Attorney General is a co-defendant in this case, and despite the clear conflict of interest, continues to advance the object of this conspiracy and cover-up the complicity and collusion between the executive, the judicial, and the unconstitutional "quasi-judicial" branches of the government. 3. Barnes is requesting 90 days to complete and file the eight briefs due in these appeals, since she has two others due in other pending cases in addition to the eight due in this case. Barnes will file the briefs as they are ready, but requires 90 days to file them all. This extension of time would make the Appellant's briefs due on September 17,2016. 4. This request is being made in good faith and not merely for delay. Good cause exists to extend the time for filing the Appellant's Briefs in all the pending appeals arising out of D-l-GN-15-00877 so that they are due on September 17,2016. 5. Barnes request that the time for filing Appellant's Briefs be extended to September 17,2016. BARNES prays for such other and further relief to which she may be entitled, whether at law or in equity. Respectfully submitted, Carolyn Barnes 419 Indian Trail Leander, Texas 78641 Barnes. legalguidance@gmai1.com 512-817-8014 JURAT COUNTY OF WILLIAMSON STATE OF TEXAS Pursuant to Texas Civil Practices and Remedies Code Sec. 132.001, I, Carolyn Barnes, do hereby swear and affirm that the facts stated above are true and correct based on personal knowledge. I aver that "My name is Carolyn Barnes, by date of birth is January 12, 1957, and my address is 419 Indian Trail, Leander, Texas 78641 in the United States of America. I swear under penalty of perjury that all the facts stated herein are within my personal knowledge and true and correct. I have read the foregoing Motion for Extension of Time to File the Appellant's Briefs arising from the numerous appeals from D-l-GN-15- 00877 and the facts stated within are true and correct to the best of her knowledge. SWORN TO BEFORE ME ON THIS 16th day of June 2016. Carolyn Barnes CERTIFICATE OF CONFERENCE Barnes conferred with Texas Attorney General, the co-defendant and attorney for JEFF ROSE and NATHAN HECHT, but did not receive a response to the email seeking an agreement for extension of time for a period of 90 days to file the Appellant's Briefs due in these appellate cases arising out of Cause No. D-l-GN-15-00877. Carolyn Barnes CERTIFICATE OF SERVICE By my signature above, I hereby certify that a true and correct copy of the foregoing document has been served pursuant to Rule 21a of the Texas Rules of Civil Procedure on all counsel of record on this the 16th day of June 2016. Carolyn Barnes 419 Indian Trail Leander, TX 78641 Barnes.legalguidance@gmail.com (512)817-8014 June 16,2016 Jeffrey D. Kyle, Clerk Third Court of Appeals PO Box 12547 ,/receivedN Austin, Texas 78711 Price Daniel Sr. Building JUN 1 7 2016 209 West 14th Street, Room 101