Jean-Michel Guerin v. Tina Renee Leone

Opinion

ACCEPTED

03-15-00324-CV

6982811

THIRD COURT OF APPEALS

AUSTIN, TEXAS

9/17/2015 5:53:05 PM

JEFFREY D. KYLE

CLERK

NO. 03-15-00324-CV

IN THE MATTER OF § IN THE COURT OFFILED APPEALS

IN

3rd COURT OF APPEALS

AUSTIN, TEXAS

THE MARRIAGE OF § 9/17/2015 5:53:05 PM JEFFREY D. KYLE

§ Clerk

JEAN-MICHEL GUERIN § THIRD DISTRICT AND § TINA GUERIN § OF TEXAS

APPELLANT’S MOTION TO

EXTEND TIME TO FILE APPELLANT’S BRIEF NOW Comes Appellant, JEAN-MICHEL GUERIN, and pursuant to Texas Rule of Appellate Procedure 38.6 (d), requests that the Court grant additional time in which to file Appellant’s Brief as related to an order issued on February 27, 2015, in Cause No. 263,324-E, Jean-Michel Guerin v. Tina Guerin, in the 426 th Judicial District, Bell County, Texas.

1. The deadline to file the Appellant’s Brief is September 16, 2015.

2. Appellant requests an additional 45 days to file Appellant’s Brief, extending the time until October 30, 2015.

3. Appellant has never sought or received a prior extension to file the Appellant’s Brief.

4. Appellant needs additional time to file the Appellant’s Brief because he has been unable to adequately prepare and research a brief for this case due to:

a. His waiting for the additional findings of fact and conclusions of law that he timely requested from the Trial Court on July 26, 2015.

b. His military duty requirements, as the chief of strategy and policy for his command, where he is responsible for developing and publishing his command’s theater campaign plan for fiscal year’s 2017 – 2021, no later than October 1, 2015.

c. His other pleading(s) in this case; specifically a Writ for Mandamus filed concurrently with this motion.

5. For these reasons, Appellant asks the Court to grant an extension of time to file Appellant’s Brief until October 30, 2015.

6. This extension of time is sought so that justice may be done and not for purposes of delay.

Respectfully submitted,

/s/ Jean-Michel Guerin

JEAN-MICHEL GUERIN

Appellant, Pro Se

CERTIFICATE OF CONFERENCE I certify that I have attempted to confer with Tina Leone (formerly known as Tina Guerin) once by email and once by USPS on September 14, 2015, but she has not responded to my attempts.

/s/ Jean-Michel Guerin

JEAN-MICHEL GUERIN

Appellant, Pro Se

CERTIFICATE OF SERVICE

I hereby certify that a true copy of the foregoing was delivered on September 14, 2015, to all parties and counsel of record as shown below:

Respectfully submitted,

/s/ Jean-Michel Guerin

JEAN-MICHEL GUERIN

Appellant, Pro Se

P.O. Box # 340437

Fort Sam Houston, TX 78234 Tel: (803) 673-2401

Fax: (210) 549-2071

E-mail: jm.t.guerin@gmail.com

Real Party in Interest: Tina (Leone) Guerin, via email to tina.guerin@gmail.com and last known address at 5500 Encino Oak Way, Killeen, Texas 76542, USPS certified mail (tracking # 9502 8000 2076 5257 0001 78).