Chase Carmen Hunter v. Texas Department of Insurance and David Mattax, in His Official Capacity as Commissioner of Insurance

ACCEPTED 03-14-00737-CV 4356662 THIRD COURT OF APPEALS AUSTIN, TEXAS 3/3/2015 4:09:52 PM JEFFREY D. KYLE CLERK No. 03-14-00737-cv _____________________________________ FILED IN 3rd COURT OF APPEALS IN THE THIRD COURT OF APPEALSAUSTIN, TEXAS 3/3/2015 4:09:52 PM AUSTIN, TEXAS JEFFREY D. KYLE Clerk _____________________________________ CHASE CARMEN HUNTER, APPELLANT v. ELEANOR KITZMAN IN HER OFFICIAL CAPACITY AS COMMISSIONER OF INSURANCE, JULIA RATHGEBER IN HER OFFICIAL CAPACITY AS COMMISSIONER OF INSURANCE, AND THE TEXAS DEPARTMENT OF INSURANCE, APPELLEES SECOND MOTION TO EXTEND TIME FOR FILING MOTION FOR REVIEW OF TRIAL COURT’S ORDER DATED FEBRUARY 19, 2015, SUSTAINING CONTEST TO MOTION TO APPEAL IN FORMA PAUPERIS From Cause D-1-GN-13001957 In The 250th District Travis County, Texas, The Honorable John K. Dietz Presiding Chase Carmen Hunter, pro se 340 S. Lemon Ave. #9039 Walnut, CA 91789 Telephone: 707-706-3647 Facsimile: 703-997-5999 Chase_Hunter@yahoo.com -1- CERTIFICATION. I, Chase Carmen Hunter, state under penalty of perjury that the following facts and argument are true and correct. March 3, 2015 TEXAS RULE OF APPELLATE PROCEDURE 10.5(b)(1)(A) Deadline: 10 days from February 19, 2015, which is March 2, 2015 TEXAS RULE OF APPELLATE PROCEDURE 10.5(b)(1)(B) LENGTH OF EXTENSION: 60 DAYS from March 2, 2015. TEXAS RULE OF APPELLATE PROCEDURE 10.5(b)(1)(C) Facts: The Appellant is indigent. The Appellant is unable to pay a lawyer and is acting pro se. The issues are complicated and involve issues of extrinsic fraud, jurisdiction, gross errors, violations of the United States Constitution, violations of state and federal laws, violations of the Appellants civil rights and human rights, and much more. For these reasons, care must be taken in filing a motion for review; and -2- the Appellant needs time to prepare said motion for review. TEXAS RULE OF APPELLATE PROCEDURE 10.5(b)(1)(D) One previous extension was granted on March 2, 2015, by the deputy clerk of this court. The extension granted was far less than the extension requested. Hunter requested on March 1, 2015, an extension of 60 days and the deputy clerk granted an extension of only 10 days; and this is not a sufficient extension. WHEREFORE, the Appellant requests that this motion for an extension be granted. Respectfully Submitted, /s/ Chase Carmen Hunter Chase Carmen Hunter Appellant, pro se 340 S. Walnut Ave. #9039 Walnut, CA 91789 Tel: 707-706-3647, Fax: 703-997-5999 Email: Chase_Hunter@yahoo.com CERTIFICATION I, Chase Carmen Hunter, swear under penalty of perjury that the foregoing statements are true and correct. __________________ 3/3/2015 Chase Carmen Hunter -3- CERTIFICATION PURSUANT TEX R. APP. P. 10.1(a)(5) I, Chase Carmen Hunter, certify that I did attempt to get the Appellees’ agreement for an extension as described herein. I contacted Cynthia Morales, counsel for the Appellees, by telephone the afternoon of March 2, 2015, to discuss the issues described herein prior to filing this motion; and I received no response from Ms. Morales as of 3:13pm CST on March 3, 2015. __________________ 3/3/2015 Chase Carmen Hunter CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing Motion was served upon the parties shown below as indicated: Cynthia A. Morales Assistant Attorney General By Email on March 3, 2015 at Cynthia.Morales@texasattorneygeneral.gov Chase Carmen Hunter -4-