Douglas W. Kirk v. Plano Independent School District Nancy Humphrey, Individually and in Her Official Capacity as President of the Board of Trustees of the Plano Independent School District Anika Vaughan, Individually and in Her Official Capacity as Teacher for Plano ( 2015 )

03-15-00211-CV June 8, 2015 NO. 013-15-00211-CV IN THE THIRD COURT OF APPEALS COMAL COUNTY, TEXAS APPELLANT Douglas W. Kirk APPELLEE Piano Independent School District, et al JM 08 2015 • MOTION TO EXTEND TIME FOR FILING RECORD Douglas W. Kirk, Appellant, makes this Motion To Extend Time for filing the Appellant's Brief on the Merits in this cause. 1. This Appeal arises out of a proceeding in the District Court for the 22nd Judicial District, Comal County, entitled: C2014-0085C, Douglas W. Kirk v. Piano Independent School District; Nancy Humphrey, Individually and in her Official Capacity as President of the Board of Trustees of the Piano Independent School District; Anika Vaughan, Individually and in her Official Capacity as Teacher for Piano, and numbered. 2. The time limit for filing Appellant's Brief on the Merits goes to June 11, 2015. 3. The brief is due on or before June 11,2015. However Appellant Douglas W. Kirk (pro se) requests an extension to file this brief for the following reasons: - 1- a. Appellant has a long standing tradition (29.5 years) of operating a family retail fireworks business which is legally open June 24 - July 4, 10 am to midnight, but requires three weeks prior to opening and one week after closing for ordering and receiving stock, preparing two retail locations (cleaning, cutting grass, setting up signs, lights, flags) and conducting break-down procedures including inventory, destocking and removal of lights, flags and signs. This is an extremely productive time which contributes to the Texas economy and State and local Sales Tax. b. Appellant is also employed fulltime as the editor and publisher of two weekly community newspapers. c. Appellant is apro se litigant and as they say, has a fool for an attorney. d. Appellant is diligently attempting to prepare a cogent brief. 4. There have been no previous requests for extension of time. 5. Appellant requests that: a. The clerk of this court give notice of this motion to appellee. b. The court grant appellant's motion. c. This court extend the time for filing the Appellant's Brief on the Merits until August 11, 2015 (60 Days). 6. Appellant contacted Appellee's Attorney Stephen R. Marsh and on June 2, 2015, Mr. Marsh wrote: "I have no objection to your request for an extension." -2- Respectfully Submitted, By ``V*yjZ^ US. llZL Douglas Kirk, pro se Appellant 1850 Old Sattler Road Canyon Lake, Texas 78132 Telephone: (830)237-7313 CERTIFICATE OF SERVICE I certify that a true and correct copy of the foregoing pleading or document has been served on all attorneys of record and any parties who are not represented by an attorney on June 3, 2015. Counsel: Stephen R. Marsh Texas State Bar No. 13019700 David Klosterboer & Associates 1301 East Collins Boulevard Suite 490 Richardson, TX 75081 Telephone: (214) 570-6292 Via U.S. Mail, Certified Return Receipt Requested, No. ^Pl2* 26Zo000*- ljp