RECEIVED
Ah. 2 6 2U21 08-21-00009-CV
EUZa\CETH g.flores,clerk 08-21-00009-CV
|firHTHCOURTQF appeals
IN THE COURT OF APPEALS
^ FILEDIN
COURT Or APPEALS
EIGHTH JUDICIAL DISTRICT
2€2m
EL PASO,TEXAS
EHZABETy r.
CLERKo"- . - '^>r-
IN THE MATTER OF THE FRAUDULENT MARRIAGE OF EDWARD ALLEN
BREEDING,III AND DEBRA ANN BREEDING,AKA: DEBRA HOLLAND
APPEALED FROM THE 266'^ JUDICIAL DISTRICT COURT
OF ERATH COUNTY,TEXAS,TRIAL COURT NO: CV 35815;
AND TRANSFERRED FROM THE ELEVENTH COURT OF
APPEALS, EASTLAND,TEXAS: 11-20-00272-CV
APPELLANT'S FIRST MOTION TO EXTEND TIME TO FILE APPELLANT'S
BRIEF,REQUEST CLARIFICATION,REQUEST COPY OF CLERK AND
REPORTER'S RECORD BY MAIL,AND SEEK PRO-BONO COUNSEL.
Debra Ann Holland - Unrepresented Appellant
Mailing Address:
9036 Cedar Ridge Ct. Cleburne, Texas 76033
Telephone: 772-222-7248
TO THE HONORABLE EIGHTH COURT OF APPEALS: Pursuant to TEX.
R. AFP. P. 10.5 and 38.6(d), the Appellant, Debra Ann Holland aka: Debra Ann
Breeding, files this First Motion to Extend Time to File Appellant's Brief and
lots
APPELLANT'S FIRST MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF, REQUEST CLARIFICATION, REQUEST COPY OF
CLERK AND REPORTER'S RECORD BY MAIL,AND SEEK PRO-BONO COUNSEL REFERRAL FROM COURT.
requests clarification, along with again requesting a copy of the trial Court Clerk
and Reporter's Record, with request of being relayed potential pro-bono counsel
information from the Court. Appellant has not been provided either trial Court
record, after numerous requests as shown in the records of both courts and with the
Erath County District Clerk. She requested the Reporter's Record along with the
Clerk's Record, dated 12.28.20; those were received by them on 12.29.20. It was
followed up on by Appellant on 1.21.2021, after initial confusion regarding those
records was conveyed to her. A copy of what was originally requested was
forwarded to the Erath Court Clerk for the Court Reporter, acknowledged by
Wanda Greer as received on 1.22.2021. Though there were requests in writing,
filed by mail even into March, 2021, as relayed again in attached email provided,
Appellant's not received the records. Appellant knows not the cause for such a
delay in receiving those by mail from the trial Court, District Clerk, or Clerk of
said Court.
INABILITY TO SIGN OUT RECORDS IN PERSON
Appellant cannot travel from the DFW area of Texas to El Paso(20+ hours round-
trip, or otherwise) to sign out hard copies from the Court, as would have been
possible if this case was not transferred from the Eleventh Court of Appeals; thus
Appellant has requested the records be sent to her, and awaited them to no avail.
2 of 5
APPELLANT'S FIRST MOTION TO EXTEND TIME TO FILE APPELLANTS BRIEF, REQUEST CLARIFICATION, REQUEST COPY OF
CLERK AND REPORTER'S RECORD BY MAIL, AND SEEK PRO-BONO COUNSEL REFERRAL FROM COURT.
UNAWARE OF WHEN BRIEF IS DUE
Appellant is also unsure when the brief is currently due. Appellant requests a 90-
day extension of time - after the records reach her -to file the brief. Appellant
needs additional time to familiarize herself with the record and legal issues
pertinent to the record in order to prepare the brief
ADDITIONAL REASONS FOR EXTENSION
Appellant also relies on the following reasons, in addition to the routine matters
that Appellant must attend to in daily life, and the foregoing reasons, to explain the
need for the requested extension: Appellant has been unjustly displaced from her
home, as a result of Appellee's initial 2004/2005 and subsequent August of 2019
frauds which led to all counts of litigation related to this and the other appeals.
Appellant has also been unrepresented in handling another suit relevant to the
subject matter in this suit. That case is a direct result of Appellee in this appeal
operating in fraud and bad faith in the life of Appellant and then in the trial Court,
to file and pursue the trial court case which resulted in this appeal and in Appellant
losing her home; Appellee's exhibited zero willingness to discuss settlement.
3 of 5
APPELLANT'S FIRST MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF, REQUEST CLARIFICATION, REQUEST COPY OF
CLERK AND REPORTER'S RECORD BY MAIL, AND SEEK PRO-BONO COUNSEL REFERRAL FROM COURT.
FIRST EXTENSION FOR TIME ON BRIEF REQUESTED
This is the first request for extension of time to file the brief Appellant seeks this
extension of time to be able to prepare a cogent and succinct brief to aid this Court
in its analysis of the issues presented. This request is not sought for delay but so
that justice may be done.
m
PRO BONO COUNSEL NEEDED
If this Court is aware of any program to which Appellant, who is dually shown to
be indigent in the trial court case and this appeal, could be appointed adequate
pro-bono counsel to prepare the brief she asks the Court to relay such information
so Appellant can pursue such assistance to aid injustice being served. The added
time requested should allow Appellant or such a professional the additional time to
become familiarized with the record and legal issues in the case in order to prepare
Appellant's brief.
CERTIFICATE OF CONFERENCE
I certify that I attempted to confer with counsel for Appellee numerous times about
numerous motions and discovery; he typically does not respond to such attempts.
At one point he responded that he should not be talking to me at all. I disagreed.
4 of 5
APPELLANT'S FIRST MOTION TO EXTEND TIME TO FILE APPELLANTS BRIEF, REQUEST CLARIFICATION, REQUEST COPY OF
CLERK AND REPORTER'S RECORD BY MAIL, AND SEEK PRO-BONO COUNSEL REFERRAL FROM COURT.
He was willing to speak with an attorney I hired in efforts to attempt discussions
on settlement late last year, after she conveyed that per the law he is required to
abide by lawyer ethics, and yet he thereafter refiised to discuss anything with me.
He seemed willing to discuss settlement with her, to have a new annulment --
which should have been pursued and granted, instead of a fraudulent divorce --
now ordered for the litigants, but never responded to me afterwards on the same.
VERIFICATION
All facts recited in this motion are within the personal knowledge of Appellant
signing this motion; therefore no verification is necessary under Rule of Appellate
Procedure 10.2.
PILAYER FOR RELIEF
Appellant asks for the above and all other relief this Court deems just.
Respectfully submitted,
DEBRA ANN HOLLAND
Unrepresented Appellant
Mailing Address: 9036 Cedar Ridge Ct, Clebume, Texas, 76033
Telephone: 772-222-7248
CERTIFICATE OF SERVICE
A^Ilant certifies mailing a copy of this to opposing counsel by First Class U.S.P.S., RRR.
WbRA ANN HOLLAND
5 of 5
APPELLANT'S FIRST MOTION TO EXTEND TIME TO FILE APPELLANTS BRIEF, REQUEST CLARIFICATION, REQUEST COPY OF
CLERK AND REPORTER'S RECORD BY MAIL, AND SEEK PRO-BONO COUNSEL REFERRAL FROM COURT.