June 17, 2016
NO. 03-15-00720-CV
IN THE THIRD COURT OF APPEALS
AUSTIN, TEXAS
CAROLYN BARNES, ET AL, APPELLANT
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BURT CARNES, APPELLEE
MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF
On Appeal From Cause No. D-l-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 flue
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.
6. BARNES prays for such other and further relief to which she
may be entitled, whether at law or in equity.
Respectfully submitted,
$y
Carolyn Barnes
419 Indian Trail
Leander, Texas 78641
Barnes.legalguidance@gmail.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 ofJune 2016.
Carolyn
CERTIFICATE OF CONFERENCE
Barnes conferred with Texas Attorney General, the co-defendant and
attorney for BURT CARNES, 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 THIRD COURT OF APPEALS^
Austin, Texas 78701 \ JEFFREY a K-'tE /
RE: Case No. 03-15-700-CV Richard Coons;
Case No. 03-15-719-CV Dusty Humes;
Case No. 03-15-720-CV Burt Carnes;
Case No. 03-15-593-CV Guilford Jones, John Delaney, Elizabeth Cunningham,
Marty Griffith;
Case No. 03-15-605-CV Kirk Cole, Ken Paxton;
Case No. 03-15-630-CV Jeff Rose, Nathan Hecht;
Case No. 03-16-125-CV Alan Hickman Schreiber
All arising out of Cause No. D-l-GN-15-000877
Carolyn Barnes, at al v. Texas Attorney General, et al
Dear Sir or Madame:
Enclosed for filing in the above captioned cause, please find seven Motions to Extend
Time for Filing Appellee's Briefs in each of the above captioned cases.
If you require anything further from me or if there are any deficiencies or defects in these
documents, please advise me immediately. Thank you for your time and attention in this
matter. If you have any problems, concerns, or questions, please contact me.
TIME IS OF THE ESSENCE.
truly yours,
Barnes
Enclosures
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T0 JEFFREY D KYLE, CLERK
THIRD COURT OF APPEALS
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AUSTIN TX 78701
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