No: 03-14-00665-CV
IN THE COURT OF APPEALS FOR
THE THIRD JUDICIAL DISTRICT OF TEXAS
ERIC DRAKE
Plaintiff-Appellant January 15, 2015
TRAVELERS, ET AL
Defendant-Appellee
ON APPEAL FROM THE 200™ DISTRICT COURT
TRAVIS COUNTY TEXAS
TRIAL COURT NUMBER: D-l-GN-14-001215
Motion for Extension to File Brief of Appellant Eric Drake
Eric Drake
Pro-Se
Appellant
PO Box 833688
Richardson, Texas 75083
214-477-9288
f/RECEIVEDN
JAN 1 5 2015
THIRD COURT OF APPEALS.
\ JEFFREY D.KYLE /
APPELLANT ERIC DRAKE'S MOTION FOR
EXTENSION OF TIME TO FILE BRIEF
TO HONORABLE JUSTICES OF SAID COURT:
Appellant Eric Drake respectfully requests that the Court extend the
time to file his brief in the above reference cause of action.
Drake requests a motion to continue because Appellant requested on
October 27, 2014 of Rhonda Watson of the 353rd Judicial District Court in
Travis Country, Texas that she prepare the August 19, 2014 Defendant
Willing motion to declare Appellant as a vexatious litigant. That record has
not been filed with this Court. Appellant spoke with the clerk of this Court
on January 12, 2015 and he confirmed that the Recorders Record of the
hearing of Judge Charles Ramsay was not in the Court's record. Appellant
cannot complete his brief without the aforementioned recorders record.
Appellant must have a complete record in order to properly plea and
argue his case before this Court. Drake respectfully requests that the Court
orders the court reporter Ronda Watson and the trial courts clerk of court to
file the "Recorders Records" of the hearing before Judge Charles Ramsey
that was conducted on August 19, 2014, declaring Appellant as vexatious.
Drake believes that this Court and the trial court are treating him wrongfully
APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE BRIEF PAGE 1
on account of his race and there will be litigation filed before this case is
decided. Appellant believes that he has been discriminated and conspired
against.
WHEREFORE, APPELLANT, ERIC DRAKE respectfully requests
the Court to grant his extension of time to file his briefs in cause number:
03-14-00665-CV until March 1, 2015, to cover any further actions by the
trial court to purposely delay filing the correct documents in the Courts
record to impede the Appellant's brief. Appellant therefore file his motion
for extension of time.
Respectfully submitted:
Eric Drake
PO Box 25565
Dallas, Texas 75225
214-477-9288
APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE BRIEF PAGE 2
CERTIFICATION OF SERVICE
I HEREBY certify that a true and correct copy of the foregoing
document has been delivered to the defendant's/appellees through their
attorney of record via US Mail on this the 12th day of January 2015.
Eric Drake
APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE BRIEF PAGE 3
CERTIFICATION OF CONFERENCE
I ERIC DRAKE, Appellant, on this the 11th day of January 2015,
certify that I attempted to make contact with Kristina Kastl, and on January
12, 2015 on two occasions to conference with her regarding this motion,
however, she has failed to respond. Likewise, I attempted to conference with
Scot Graydon, his secretary hung up the telephone and when I called back
she had an attitude. Appellant left yet another message on Mr. Graydon's
voice mail with no avail. On January 12, 2015, attempted to contact David
Harris, and Appellant was told that he is not employed there. On January 12,
2015, I contacted Frank Waite and he responded; he is unopposed to the
motion. Thus, I file this motion with the Court for its decision and ruling.
APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE BRIEF PAGE 4
Eric Drake
PO Box 833688
Richardson, Texas 75083
January 12,2015
Jeffrey D. Kyle
Clerk of Court
Third Court of Appeals
PO Box 12547
Austin, Texas 78711
RE: In re Eric Drake. Cause Number: 03-14-00665-CV
Dear Honorable Kyle:
Please find my second motion for extension of time to file my original brief because
unfortunately as we conference over on January 12, 2015, the recorders record which I
requested of the August 19, 2014 hearing before Judge Charles Ramsay has not been
filed with the Court. This is the most important document in the case.
Please order the clerk of court and Rhonda Watson to file this recorders record into the
Court's record so I can finish my brief. Ms. Watson has already transcribed the record but
has refused to file it into your court's records. I cannot brief this case without the
recorders record for the January 12, 2014 hearing before Charles Ramsay. Please stamp
file the enclosed copy and return to me. Thank you.
If there are any questions or comments please contact me at the above address, or by
telephone at: 214-477-9288 or by email at: emike899@gmail.com
Yours truly,
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