No: 03-14-00665-CV
IN THE COURT OF APPEALS FOR
THE THIRD JUDICIAL DISTRICT OF TEXAS
ERIC DRAKE
Plaintiff-Appellant February 12, 2015
v.
TRAVELERS, ET AL
Defendant—Appellee
ON APPEAL FROM THE 200™ DISTRICT COURT
TRAVIS COUNTY TEXAS
TRIAL COURT NUMBER: D-l-GN-14-001215
Motion to Exceed Word Count in Appellant Eric Drake Brief
Eric Drake
Pro-Se
Appellant
PO Box 833688
Richardson, Texas 75083
214-477-9288
APPELLANT ERIC DRAKE'S MOTION TO
EXCEED WORD COUNT IN ORIGINAL BRIEF
TO HONORABLE JUSTICES OF SAID COURT:
Appellant Eric Drake respectfully requests that the Court allow him to
exceed the maximum word count in his original brief.
Appellant Eric Drake finally received the recorders record from the
August 19, 2014 hearing before Judge Charles Ramsay. Appellant has
finished his ruff-draft of his brief and he estimates that he will go over the
required maximum word count—thus, he makes this request to exceed the
word count as provided by the Appellate Rules of Civil Procedure 9.4.
The Appellant's original brief should not exceed 15,000 words not
counting the exclusions. But the trial court judges made so many errors and
abuses of their discretions that the Appellant needs to exceed the word count
to properly brief those errors made by the trial court, Judge Charles Ramsay
and the events surrounding his appointment to hear Appellees Willing
motion to declare Appellant as a vexatious litigant, Seanna Willing actions
through her counsel of record: an assistant attorney general by the name of
Scot Graydon who committed perjury, and other parties.
Therefore, Appellant requests that he be allow to exceed the
maximum word count from 15,000 to 19,500 in his original brief.
MOTION TO EXCEED WORD COUNT IN APPELLANT'S BRIEF PAGE 1
WHEREFORE, APPELLANT, ERIC DRAKE respectfully requests
the Court to grant his requests to exceed the required maximum word count
in his original brief pursuant to cause number: 03-14-00665-CV. And that
the Court would grant Appellate to exceed the required maximum word
count from 15,000 words to 19,500 words.
Respectfully submitted:
Eric Drake
PO Box 833688
Richardson, Texas 75083
214-477-9288
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 ofrecord via US Mail on this the / / -^ day ofFebruary 2015.
Eric Drake
MOTION TO EXCEED WORD COUNT IN APPELLANT'S BRIEF PAGE 2
CERTIFICATION OF CONFERENCE
I ERIC DRAKE, Appellant, attempted to make contact with Kristina
Kastl, and on February, 9th, and twice on the 10th, 2015 to conference with
her regarding this motion, however, she has failed to respond. Likewise,
Appellant attempted to conference with Scot Graydon, but Mr. Graydon has
refused to conference with the Appellant in the past, though Drake attempted
to conference with him on February, 9th, and twice on the 10th, but he never
replied to my requests to no avail. Appellant have been previously advised
that David Harris is no longer an assistant attorney general. On February11,
2015, Appellant contacted Frank Waite and he did respond; he is unopposed
to the motion. Thus, I file this motion with the Court for its decision and
ruling.
Eric Drake
MOTION TO EXCEED WORD COUNT IN APPELLANT'S BRIEF PAGE 3
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