Inez Manigault v. Jane Thorn-Henderson

1
UNITED STATES COURT OF APPEALS
FOR THE
Twelfth Court of Appeals

Inez Manigault
Twelfth Court of Appeals Case No: 12-14-00156-CV

Appellant FILED IN COURT OF APPEALS
12th Court of Appeals District
vs. Trial C
C122852

Jane Thorn-Henderson
TEXAS
Appellee CATHY S. LUSK, C\

APPELLANT'S MOTION FOR EXTENSION OF TIME TO FILE INITIAL
BRIEF

The Appellant, Inez. Manigault, moves this court to

extend the time for filing the Initial Brief, and as grounds

therefore, states:

1. Recently received the Reporter's Record. Due to
confusion to quoted cost. The initial date of extension date
granted by the court to pay for the Reporter's Record was
obeyed on February 27, 2015, $697.50, was paid. However, a
different amount of $80.00 dollars was added to the amount

2. The issues in this case are complex and involve
Constitutionality of out of-state statue unfamiliar to the
pro se litigant

3. Additional time is necessary to prepare a Brief7.

4. The undersigned, requests additional time in which
to file the Initial Brief, so that the Initial Brief shall
be due on or before May 30, 2015.

5. There will be no prejudice to Appellee in granting
this request for extension of time to file the Initial
Brief. Appellee was contacted on March 26, 2015.

6. This Motion is made in good faith, and not merely
i
for purpose of delay.

Appellant contacted opposing attorney. Please find
enclosed e-mail from opposing attorney.. No further, contact
or information received from attorney.

I HEREBY CERTIFFY, that a true and correct copy of the

foregoing has been furnished via U. S. Mail to Esquire,

lult (Pro
P. (3. Box 81922
Atlanta, Georgia 303
678) 547-3914

Cc: Adam B. Allen
White Shaver, PC
205 West Locust Street
Tyler, Texas 75702
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. *7/20J5 Gmail- briefextension

Inez Manigault

brief extension
2 messages

Inez Manigault Fri, Mar 27, 2015 at 8:34 PM
To: AAIfen@whiteshaverfaw.com
Dear Attorney Allen:

f am writing to ask your position on another extension to file the original brief. As you are aware. Ms. Parks,
recently filed the recorder's record with the Courts. The amount requested in February was paid. A different
amount was quoted, after this amount was paid.

I would need some time to review the record, and prepare my brief. The request would ask the court, to extend
through May 15, 2015.

Thank you,

s/s Inez Manigault

Adam Allen Fri, Mar 27, 20i5 at 9:14 PM
To: Inez Manigault
Ms. Manigault,

I'll need to confer with my client before I agree to another extension. I recognize your situation, and the same
will be communicated, but I cannot agree to anotherextension without prior authorization.
Thank you,

Adam Allen

Sent from my iPad
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