ACCEPTED
03-15-00324-CV
6982811
THIRD COURT OF APPEALS
AUSTIN, TEXAS
9/17/2015 5:53:05 PM
JEFFREY D. KYLE
CLERK
NO. 03-15-00324-CV
IN THE MATTER OF § IN THE COURT OFFILED
APPEALS
IN
3rd COURT OF APPEALS
AUSTIN, TEXAS
THE MARRIAGE OF § 9/17/2015 5:53:05 PM
JEFFREY D. KYLE
§ Clerk
JEAN-MICHEL GUERIN § THIRD DISTRICT
AND §
TINA GUERIN § OF TEXAS
APPELLANT’S MOTION TO
EXTEND TIME TO FILE APPELLANT’S BRIEF
NOW Comes Appellant, JEAN-MICHEL GUERIN, and pursuant to Texas
Rule of Appellate Procedure 38.6 (d), requests that the Court grant additional time
in which to file Appellant’s Brief as related to an order issued on February 27,
2015, in Cause No. 263,324-E, Jean-Michel Guerin v. Tina Guerin, in the 426 th
Judicial District, Bell County, Texas.
1. The deadline to file the Appellant’s Brief is September 16, 2015.
2. Appellant requests an additional 45 days to file Appellant’s Brief,
extending the time until October 30, 2015.
3. Appellant has never sought or received a prior extension to file the
Appellant’s Brief.
4. Appellant needs additional time to file the Appellant’s Brief because he
has been unable to adequately prepare and research a brief for this case due to:
a. His waiting for the additional findings of fact and conclusions of
law that he timely requested from the Trial Court on July 26, 2015.
b. His military duty requirements, as the chief of strategy and
policy for his command, where he is responsible for developing and publishing
his command’s theater campaign plan for fiscal year’s 2017 – 2021, no later
than October 1, 2015.
c. His other pleading(s) in this case; specifically a Writ for
Mandamus filed concurrently with this motion.
5. For these reasons, Appellant asks the Court to grant an extension of
time to file Appellant’s Brief until October 30, 2015.
6. This extension of time is sought so that justice may be done and not for
purposes of delay.
Respectfully submitted,
/s/ Jean-Michel Guerin
JEAN-MICHEL GUERIN
Appellant, Pro Se
CERTIFICATE OF CONFERENCE
I certify that I have attempted to confer with Tina Leone (formerly known
as Tina Guerin) once by email and once by USPS on September 14, 2015, but
she has not responded to my attempts.
/s/ Jean-Michel Guerin
JEAN-MICHEL GUERIN
Appellant, Pro Se
CERTIFICATE OF SERVICE
I hereby certify that a true copy of the foregoing was delivered on
September 14, 2015, to all parties and counsel of record as shown below:
Respectfully submitted,
/s/ Jean-Michel Guerin
JEAN-MICHEL GUERIN
Appellant, Pro Se
P.O. Box # 340437
Fort Sam Houston, TX 78234
Tel: (803) 673-2401
Fax: (210) 549-2071
E-mail: jm.t.guerin@gmail.com
Real Party in Interest:
Tina (Leone) Guerin, via email to tina.guerin@gmail.com and last known
address at 5500 Encino Oak Way, Killeen, Texas 76542, USPS certified mail
(tracking # 9502 8000 2076 5257 0001 78).