David Lancaster v. Barbara Lancaster

ACCEPTED 01-14-00845-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 12/29/2014 12:21:30 PM CHRISTOPHER PRINE CLERK No. 01-14-00845-CV IN THE COURT OF APPEALS FOR THE FIRST DISTRICT OF TEXAS FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS DAVID LANCASTER 12/29/2014 12:21:30 PM Appellant, CHRISTOPHER A. PRINE vs. Clerk BARBARA LANCASTER Appellee. Appeal from 247th Judicial District Court, Harris County, Texas, the Hon. Bonnie Crane Hellums, Presiding APPELLANT’S FIRST MOTION TO EXTEND TIME TO FILE BRIEF TO THE HONORABLE TEXAS FIRST COURT OF APPEALS: Appellant DAVID LANCASTER, (“Appellant”) files this First Motion to Extend Time to File Brief in the above-referenced appeal pursuant to Texas Rules Appellate Procedure 38.6 (d) and 10.5 (b) as follows: (A) the deadline for filing the item in question; is stated to be December 29th 2014 by the clerk of courts record. Although Appellant believes it to be January 23 rd 2015 based upon the trial clerks record amended December 23rd 2014. (B) the length of the extension sought; is 30 days Until January 28th 2015. (C) the facts relied on to reasonably explain the need for an extension; 1. The original clerks record was requested on October 20th 2014. 2. The original Clerks record was filed on November 6th 2014. 3. An request for Pro Se access to the appellate record was filed November 19th 2014 and appellant received the original record on November 21st 2014. 4. After review and realization that the record filed was insufficient per appellants first request appellant filed for First Supplemented Clerks Record on November 24th 2014. 5. On December 5th 2014 the 247th Judicial District Court modified its judgment in cause 2013-05066. 6. On December 16th 2014 the First Court of Appeals Noticed appellant that he must cause to be filed an amended clerks’ record to include the judgments of December 5th 2014. 7. On December 23rd 2014 the First Supplemented clerks record was filed. And that same day the second supplement to clerks record was requested. APPELLANT’S FIRST MOTION TO EXTEND TIME TO FILE BRIEF Page 1 of 3 Per the schedule above appellant has not yet received first supplement to the clerks record for review and inclusion in brief. Neither the appellant nor the Court of Appeals has received the second supplemented record as required by the Court of Appeals on December 16th 2014. Submission of brief without the complete clerks record would fail to inform the court of appeals of all issues presented in appeal and possibly deny appellant opportunity for relief due from appeal. (D) the number of previous extensions granted regarding the item in question is zero. This is the first motion to extend time to file brief. David Lancaster, requests an extension of time until Wednesday January 28, 2015 to file his Appellate Brief in this case and for such other and further relief to which Appellant may be justly entitled. Respectfully submitted, David Lancaster, Appellant Pro Se /s/ David Lancaster PO Box 722 Gray, La. 70359 David.lancaster50@gmail.com 502-693-8011 APPELLANT’S FIRST MOTION TO EXTEND TIME TO FILE BRIEF Page 2 of 3 CERTIFICATION I David Lancaster am The person filing the FIRST MOTION TO EXTEND TIME TO FILE BRIEF I have reviewed the motion and concluded that every factual statement in the motion Is within my personal knowledge and is supported by the trial courts record and the appeals courts record. /s/ David Lancaster Certificate of Service I certify that a true copy of the above was served on each attorney of record or in accordance with the Texas Rules of Appellate Procedure on December 29th 2014. Via efile Texas Mary K. Quinn Attorney at Law 1314 Texas Street, Suite 1515 Houston, TX 77002 Phone: 713-225-0094 Fax: 713-225-0099 1314 Texas St #1515, Houston, TX 77002 (713) 225-0094 APPELLANT’S FIRST MOTION TO EXTEND TIME TO FILE BRIEF Page 3 of 3