Carolyn Barnes v. the Honorable Burt Carnes

• Court: Court of Appeals of Texas
• Decided: June 17, 2016
• Docket: 03-15-00720-CV
• Status: Published

Opinion

June 17, 2016 NO. 03-15-00720-CV

IN THE THIRD COURT OF APPEALS

AUSTIN, TEXAS

CAROLYN BARNES, ET AL, APPELLANT /received \ V. JUN 172016 ! i vTHiRDCOL.MOf1/."?^.:? .' BURT CARNES, APPELLEE

MOTION TO EXTEND TIME TO FILE APPELLANT'S BRIEF

On Appeal From Cause No. D-l-GN-15-000877 From The 419th Judicial District Court Of Travis County, Texas

TO THE HONORABLE JUDGE OF SAID COURT:

COMES NOW, CAROLYN BARNES, et al, hereinafter referred to as

BARNES, and files this motion to extend time for filing Appellant's Brief,

and in support thereof would show the court as follows:

1, Barnes has ten briefs due because of the nature of the manner in

which this case was handled by the trial court, the complete suspension of

constitutional rights by the licensed attorneys and employees of this State,

and the judicial edicts that are being issued sua sponte without any flue

process by Jeffrey Kyle. 2. It is not humanly possible to produce adequate, effective, or

quality briefs in this manner and the court and licensed attorneys know it. '

Opposing counsel has not agreed to an extension of 90 days for filing

Appellant's Brief. Appellant sent an email seeking an agreement, but

received no response. The Texas Attorney General is a co-defendant in this

case, and despite the clear conflict of interest, continues to advance the

object of this conspiracy and cover-up the complicity and collusion between

the executive, the judicial, and the unconstitutional "quasi-judicial" branches

of the government.

3. Barnes is requesting 90 days to complete and file the eight

briefs due in these appeals, since she has two others due in other pending

cases in addition to the eight due in this case. Barnes will file the briefs as

they are ready, but requires 90 days to file them all. This extension of time

would make the Appellant's briefs due on September 17,2016.

4. This request is being made in good faith and not merely for

delay. Good cause exists to extend the time for filing the Appellant's Briefs

in all the pending appeals arising out of D-l-GN-15-00877 so that they are

due on September 17,2016.

5. Barnes request that the time for filing Appellant's Briefs be

extended to September 17,2016. 6. BARNES prays for such other and further relief to which she

may be entitled, whether at law or in equity.

Respectfully submitted,

$y Carolyn Barnes 419 Indian Trail Leander, Texas 78641 Barnes.legalguidance@gmail.com 512-817-8014

JURAT

COUNTY OF WILLIAMSON

STATE OF TEXAS

Pursuant to Texas Civil Practices and Remedies Code Sec. 132.001, I, Carolyn Barnes, do hereby swear and affirm that the facts stated above are true and correct based on personal knowledge.

I aver that "My name is Carolyn Barnes, by date of birth is January 12, 1957, and my address is 419 Indian Trail, Leander, Texas 78641 in the United States of America. I swear under penalty of perjury that all the facts stated herein are within my personal knowledge and true and correct.

I have read the foregoing Motion for Extension of Time to File the Appellant's Briefs arising from the numerous appeals from D-l-GN-15- 00877 and the facts stated within are true and correct to the best of her knowledge.

SWORN TO BEFORE ME ON THIS 16th day ofJune 2016.

Carolyn CERTIFICATE OF CONFERENCE

Barnes conferred with Texas Attorney General, the co-defendant and

attorney for BURT CARNES, but did not receive a response to the email

seeking an agreement for extension of time for a period of 90 days to file the

Appellant's Briefs due in these appellate cases arising out of Cause No. D-l-

GN-15-00877.

Carolyn Barnes

CERTIFICATE OF SERVICE

By my signature above, I hereby certify that a true and correct copy of

the foregoing document has been served pursuant to Rule 21a of the Texas

Rules of Civil Procedure on all counsel of record on this the 16th day of June

2016. Carolyn Barnes 419 Indian Trail Leander, TX 78641 Barnes.legalguidance@gmail.com (512)817-8014

June 16,2016

Jeffrey D.Kyle, Clerk Third Court of Appeals PO Box 12547 ,/receivedN Austin, Texas 78711 Price Daniel Sr. Building JUN 1 7 2016 209 West 14th Street, Room 101 THIRD COURT OF APPEALS^ Austin, Texas 78701 \ JEFFREY a K-'tE /

RE: Case No. 03-15-700-CV Richard Coons; Case No. 03-15-719-CV Dusty Humes; Case No. 03-15-720-CV Burt Carnes; Case No. 03-15-593-CV Guilford Jones, John Delaney, Elizabeth Cunningham, Marty Griffith; Case No. 03-15-605-CV Kirk Cole, Ken Paxton; Case No. 03-15-630-CV Jeff Rose, Nathan Hecht; Case No. 03-16-125-CV Alan Hickman Schreiber

All arising out of Cause No. D-l-GN-15-000877 Carolyn Barnes, at al v. Texas Attorney General, et al

Dear Sir or Madame:

Enclosed for filing in the above captioned cause, please find seven Motions to Extend Time for Filing Appellee's Briefs in each of the above captioned cases.

If you require anything further from me or if there are any deficiencies or defects in these documents, please advise me immediately. Thank you for your time and attention in this matter. If you have any problems, concerns, or questions, please contact me.

TIME IS OF THE ESSENCE.

truly yours,

Barnes

Enclosures Align top of FedEx Express® sh smart ORIGIN IDsBSMA <512> 817-B014 SHIP DA CAROLYN BARNES ACTUGT' CAD> 69 FedEx carbon-neutral 419 INDIAN TRAIL LEANDER. TX 78641 BILL CR envelope shipping UNITED STATES US T0 JEFFREY D KYLE, CLERK THIRD COURT OF APPEALS 209 WEST 14TH ST ROOM 101, PRICE DANIEL SR B AUSTIN TX 78701 1483-1733 KEF! Mil: POi n?v TUE - T|; 7833 7891 5524 A& ** 385 44AUSA &