Aleksander Borisov v. Kerry Lea Keels, Chief Clerk, Harris County Justice Court Precinct 5, Place 1

Court of Appeals of Texas·Decided October 12, 2015·No. 01-15-00522-CV·Published

Opinion

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700220SB39 .H,„,Miij1i„,|M„|j,n„\„h\u>ii|i,,j.i,|,|nli!ni|m,j FILED IN 1ST COURTOF APPEALS HOUSTON, TEXAS

OCT 12 2015 Case Number CHRISTOPHER^i^RINE 01-14-01019-CR CLERK.

Hung Le, Appellant § COURT OF APPEALS § Ist DISTRICT State of Texas, Appellee § HOUSTON, TEXAS

Pro se Motion for Extension of Time to File Response to Anders Brief

To the Honorable Justices of said Court:

Appellant's appointed counsel file a brief in the above styled and numbered

cause pursuant to Anders v. California, 386 U.S. 738 (1967).

Appellant filed a pro se request for access to the clerk's record and reporter's

record in preparation for use in preparing his pro se response to counsel's brief and

included a motion for extension of time to respond to counsel's Anders brief.

This Honorable Court granted said extension which is set to expire on

November 2, 2015.

Appellant is in the transit to another Unit in safekeeping area and currently

confined in the Life Division of the Texas Department of Justice Center in

Huntsville Unit, and has suffered yet another epileptic seizure, caused scalp

laceration and became hospitalized at Huntsville Memorial Hospital on 9/29/2015

and was ordered by Doctor Windham to remove staples within 7 days (please see

attached hospital's report) during his period of extension and appeal response

filing. As a result, Appellant has become confused, disoriented, and has shown Due to Appellant's financial hardship to hire a private counsel, non-

accessible permission for any assistance due to past 50 day safety confinement,

now in transit to a new unit, recurring seizures, and incompetency mental

condition, Appellant now respectfully requests the Court grant him another

Appellate Public Defender Bob Wicoff to substitute Public Defendant Crowley's

withdrawal and additional sixty (60) days from the granting of the motion to retain

another Appellate Public Defender or find an outside assistance and allow time for

that professional to help Appellant prepare and file a timely pro se response to

counsel's brief and a writ of Habeas Corpus as advised by Appellate Public

Defender Crowley.

Respectfully submitted,

M^X*^, (ii , Uy^ Ll'.S.PjA""" Hung Le, Pro se Appellant Unit,TDCJ# 0nUl2$ , Texas

CERTIFICATE OF SERVICE

The undersigned hereby certifies that on this the day of ,

2015, a true and correct copy of the foregoing Motion for Extension of Time to

File Response to Counsel's Anders Brief was served by U.S. mail on the :

Harris County District Attorney's Office 1200 Franklin, Suite 600 Houston, Texas 77002

Pro se Appellant GENERAL POWER OF ATTORNEY STATE OF TEXAS KNOW ALL MEN BY THESE PRESENTS:

COUNTY OF /VhA^r-SQQ

THAT I, /-/l/a//| ^_L=£L •of the County of AtvkrSon and State of Texas do hereby constitute and appoint MAI LAN T. LE of Jefferson Parish, Louisiana to be my duly and lawfully appointed attorney in fact granting unto said attorney in fact the full power and authority to do and perform any and all acts and/or things necessary or requisite to be done in furtherance of my interests, whether said acts involve any type of medical or legal matters, financial, real or personal property, granting unto my attorney in fact a Universal power of attorney permitting said attorney in fact to act as fully and for all intents and purposes as I might do if I were personally present. I further authorize and empower said attorney in fact to being suit, to recover monies, to recover property or convey personal or real property and to execute receipts, releases and/or any other documents as may be necessary under the circumstances. Said attorney in fact is empowered to use their sole discretion in handling matters relating to my interests. This universal power of attorney will supersede my disability to the fullest extent possible for the laws of the State of Texas.

Witness my hand ih^ [£J_ day of (jLci^U/^— ,20 /~

Acknowledgement

STATE OF TEXAS

COUNTY OF &Y^£££&y BEFORE ME, the undersigned authority, on this day personally appeared \lZULY\G\ LJ2— , known to me to be the person whose name is subscribed tVthe foregoing document and acknowledged to me that (s)he executed the same for the purposes and consideration therein expressed. GJ\(EN under my hand ancLseaLof office this the /ot*\ day of " " "^ .20/5 KISHANSTOTTS NOTARY PUBLIC STATE OFTEXAS

. ubicinandfor ,_ \5 Uffife/ N®Sj^ comm.expires 8-28-2016 te of Texas w-CcsS--^^^^^^r:n„ ^^^"NIOTARv ,,;,TMODT 80ND ray c j- «•

Date: 09/29/15 Account No: H00001033625 Huntsville Unit No: M000202557 Patient: L£,HUNG 1966229 MEMORIAL HOSPITAL Location: ER Physician: WINDHAM,WILLIAM A

Patient Visit"Information You were seen today for:

Seizure Scalp laceration Phenytoin overdose

Staff

Your caregivers today were:

Physician: WINDHAM,WILLIAM A Nurse: TOG

Activity Restrictions or Additional instructions cTAPi ^ OUT IU 7 "DAYS THE PATIENT'S PnENYTQIN SHOULD BE TAKEN OUT OF THE CELL AnS d'Ip^SEDVo^IM AT DOSING TIMES. HE SHOULD BE OBSERVED TAKING THE PHENYTOIN TO MAKE SURE HE HAS TAKEN IT.

Follow-up

Please contact the following to make an appointment for follow-up care: TDGJ,PRIMARY CARE DOC Note: Your health care plan may require a referral from your primary care provider prior to making an appointment.

Discharge Form

The exam and treatment which you have received has been on an EMERGENCY BASIS ONLY It is not inttneded to substitute or replace complete medical care. It is advised that you follow the recommendations below: 1. If complications arise, call your doctor inVnediateiy. Ifthe doctor cannot be reached return to the Emergency Department at once, 2. Have your prescriptions filled and follow the directions on the label. 3. The x-ray report by the Emergency Physician is NOT a final report. A Page 2 of 2

Date: 09/29/15

Huntsville Account No: H00001033625 Unit No: M000202557 Patient: LE,HUNG 1966229 Memorial Hospital Location: ER Physician: WINDHAM,WILUAM A

radiologist will interpret your x-rays and confirm the diagnosis of the Emergency Physician. OCT is * Case Number CHRISTOPHER A- 01-14-01019-CR clebk.

Hung Le, Appellant § COURT OF APPEALS § Ist DISTRICT State of Texas, Appellee § HOUSTON, TEXAS

Pro se Motion for Extension of Time to File Response to Anders Brief

Appellant's appointed counsel file a brief in the above styled and numbered

Appellant filed a pro se request for access to the clerk's record and reporter's

record in preparation for use in preparing his pro se response to counsel's brief and

included a motion for extension of time to respond to counsel's Anders brief.

This Honorable Court granted said extension which is set to expire on

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Aleksander Borisov v. Kerry Lea Keels, Chief Clerk, Harris County Justice Court Precinct 5, Place 1, (Tex. Ct. App. 2015).

Aleksander Borisov v. Kerry Lea Keels, Chief Clerk, Harris County Justice Court Precinct 5, Place 1 (Aleksander Borisov v. Kerry Lea Keels, Chief Clerk, Harris County Justice Court Precinct 5, Place 1) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Anders v. California
386 U.S. 738 (Supreme Court, 1967)