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

ACCEPTED 03-14-00737-CV 7601536 THIRD COURT OF APPEALS AUSTIN, TEXAS 10/29/2015 2:33:02 PM JEFFREY D. KYLE CLERK No. 03-14-00737-cv _____________________________________ FILED IN IN THE THIRD COURT OF APPEALS 3rd COURT OF APPEALS AUSTIN, TEXAS AUSTIN, TEXAS 10/29/2015 2:33:02 PM _____________________________________ JEFFREY D. KYLE Clerk CHASE CARMEN HUNTER, APPELLANT/PLAINTIFF v. DAVID MATTAX IN HIS OFFICIAL CAPACITY AS COMMISSIONER OF INSURANCE, AND THE TEXAS DEPARTMENT OF INSURANCE, APPELLEES/DEFENDANTS APPELLANT’S MOTION TO FILE A SUPPLEMENT TO APPELLANT’S BRIEF 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 TO: THE JUSTICES OF THIS COURT On October 14, 2015, Hunter was first able to access the underlying court’s record due to a new, free technology offered by the underlying court (“TCTDC” which means “Travis County Texas District Court”). And Hunter discovered that there is 1) no notice of court setting dated in June 2014 or any other time and 2) no dismissal order dated August 25, 2014, or any other time in the underlying record. Hunter’s initial brief was drafted without Hunter having access to the underlying court’s record. As shown in Hunter’s initial brief, which was filed almost ten months ago, the clerk of the underlying court (“TCTDC Clerk”) had been refusing to perform ministerial duties. See ¶ 7 of Appellant’s initial brief and see also p. 16 of initial brief under “certification”. The TCTDC Clerk refused to respond to Hunter’s telephone calls and faxes sent in which Hunter asked for, among other things, an itemization of record activity. See p. 16 of initial brief under “certification”. Paragraphs 10 and 12 of Hunter’s initial brief are not supported by the record in the underlying court. And this is significant to this appeal. There is no document in the underlying record that shows that Hunter’s underlying cause was dismissed. Yet, this appeal seeks reversal of the underlying court’s dismissal, which does not exist. Apparently, the TCTDC Clerk mailed Hunter a document advising Hunter that her cause was dismissed but did not enter that document in the underlying record. Therefore, the TCTDC Clerk only caused Hunter to believe that her underlying cause was dismissed when it was not. Hunter received a document from the TCTDC Clerk that gave Hunter the false impression that her lawsuit was dismissed. See ¶¶ 10, 12, and 13 of Hunter’s initial brief. This is an appeal of the underlying court’s failure to hold a hearing on Hunter’s Motion To Reinstate (“MTR”). But the underlying record shows that the TCTDC Clerk erroneously filed Hunter’s MTR as a “Notice of Appeal” and did not present it to the judge as a motion. The foregoing facts are significant to this appeal. WHEREFORE, Appellant asks that this Court grant Hunter’s Motion To File A Supplement To Appellant’s Brief. 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. __________________ 10/29/2015 Chase Carmen Hunter CERTIFICATION PURSUANT TEX R. APP. P. 10.1(a)(5) I, Chase Carmen Hunter, certify that I did make a reasonable attempt to confer with all other parties about the merits of this motion and whether those parties oppose the motion with no success in receiving a response.” __________________ 10/29/2015 Chase Carmen Hunter CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served upon the parties shown below as indicated: Cynthia A. Morales, Assistant Attorney General By Efile on 10/29/2015 Cynthia.Morales@texasattorneygeneral.gov Facsimile: (512) 477-2348 Velva L. Price Clerk of Travis County Texas District Court By Efile on 10/29/2015 Chase Carmen Hunter