Jean-Michel Guerin v. Tina Renee Leone

Opinion

ACCEPTED

03-15-00324-CV

7650584

THIRD COURT OF APPEALS

AUSTIN, TEXAS

11/3/2015 6:40:03 AM

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 § 11/3/2015 6:40:03 AM 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 was October 30, 2015.

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

3. Appellant sought and received one prior extension to file the Appellant’s Brief on or about September 16, 2015.

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. The military duty requirements referenced in his last request for additional time to file the Appellant’s Brief experienced unexpected delays and were completed on November 2, 2015.

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

5. For these reasons, Appellant asks the Court to grant an extension of time to file Appellant’s Brief until November 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’s (formerly known as Tina Guerin) attorney of record, Nathan L. Kennedy, Bar No. 24049190, by email on November 1, 2015, who has not responded to my attempt.

/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 November 3, 2015, by electronic service, fax, and email 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

Counsel for Respondent / Real Party in Interest: Nathan L. Kennedy; State Bar No. 24049190; 1607 Nueces Street, Austin, Texas 78701; Telephone: (512) 469-0092; Fax: (512) 469-9102; nkennedy@nathankennedylaw.com.