Ernest Ray Koonce v. Wells Fargo Bank, N.A., as Trustee Under the Pooling and Servicing Agreement Dated as of April 1, 2005, Asset Backed Pass-Through Certificates, Series 2005-WHQ2 ( 2015 )

ACCEPTED
01-15-00228-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
12/15/2015 1:15:30 AM
CHRISTOPHER PRINE
CLERK
No. 01-15-000228 and 01-15-00440
________________________________________________________________
FILED IN
IN THE FIRST DISTRICT COURT OF APPEALS 1st OFCOURT
TEXASOF APPEALS
HOUSTON, TEXAS
________________________________________________________________
12/15/2015 1:15:30 AM
CHRISTOPHER A. PRINE
Clerk
IN RE ERNEST R. KOONCE, RELATOR
________________________________________________________________
Original Proceeding From the 127th Judicial District Court of
Harris County
Cause No. 2010-64752
__________________________________________________________________
APPELLANT’S MOTION FOR AN EXTENSION OF TIME IN WHICH
TO FILE THE BRIEF
ERNEST R. KOONCE
Pro Se
15938 Fleetwood Oaks Drive
Houston, Texas 77079
Tel: (832) 434-3183
Fax: (832) 328-7171
rayk469@gmail.com
No. 01-15-000228 and 01-15-00440
________________________________________________________________
IN THE FIRST COURT OF APPEALS OF TEXAS
________________________________________________________________
IN RE ERNEST R. KOONCE, RELATOR
________________________________________________________________
Original Proceeding From the 127th Judicial District Court of Harris
County, Texas
Cause No. 2010-64752
__________________________________________________________________
APPELLANT’S MOTION FOR AN EXTENSION OF TIME IN WHICH
TO FILE THE BRIEF
ERNEST R. KOONCE
RELATOR, Pro Se
15938 Fleetwood Oaks Drive
Houston, Texas 77079
Tel: (832) 434-3183
Fax: (832) 328-7171
rayk469@gmail.com
TO THE HONORABLE COURT OF APPEALS OF TEXAS:
Ernest R. Koonce, Relator, and those similarly situation,
respectfully submit this motion for extension of time, and would
show the Court as follows:
IDENTITY OF PARTIES AND THEIR COUNSEL
Relator, Ernest R. Koonce, hereby certifies that the following are the
list of parties and their respective counsel, if any, to the best of his
knowledge and understanding of the rules.
PARTIES COUNSEL
Relator
ERNEST R. KOONCE Pro Se
Respondent
HONORABLE RK SANDILL 127thth Civil District
Court of Harris County, TX
201 Caroline, 10th Floor
Houston, Texas 77002
Court Phone Number:
(713) 368-6161
Chris Daniels 201 Caroline
Harris County District Clerk Houston, Texas 77002
Real Party in Interest:
WELLS FARGO BANK, NA Bradley Chambers
Texas Bar No. 2400186
Valerie Henderson
Texas Bar No. 24078655
Baker, Donelson, Bearman,
Caldwell & Berkowitz, P.C.
1301 McKinney Street
Suite 3700
Houston, Texas 77010
(713) 650-9700 – Telephone
(713) 650-9701 – Facsimile
vhenderson@bakerdonelson.com
TO THE HONORABLE COURT OF APPEALS OF TEXAS:
Ernest Ray Koonce, Relator/Appellant, and those similarly
situated, respectfully submits this motion for extension of time in
which to file his Reply to Response to Writ of Mandamus, and Reply
to Response to Supplemental Writ of Mandamus.
The court ordered WF to provide a response to Koonce’s
Supplemental Writ of Mandamus no later than November 23, 2015,
and ordered Koonce to file his reply within 20 days thereafter. By
Koonce’s calculations, the deadline fell on Sunday, December 13,
2014, and therefore the reply was Due December 14, 2015.
While trying to put together all of the appendix and the
response in one pdf with the tabs as required, I had much difficulty
with the program. Although I diligently tried, I was not able to meet
the deadline due to complication with the program and the very old
computer I have to use. This was not intentional, and out of
Koonce’s control.
Therefore, appellant requests that this court grant him a 1 day
extension from December 14, 2015, due to this unforeseen issue.
PRAYER
For these reasons, Appellant requests that this Court grant
him a 1-day extension of time in which to file is reply brief and reply
to supplemental mandamus, and for such other and further relief
as the court deems just and proper.
Dated: December 15, 2015 Respectfully submitted,
/s/Ernest Ray Koonce
________________________________
Ernest Ray Koonce
CERTIFICATE OF SERVICE
The above and foregoing document was served in accordance
with Rule 21a on this 15th day of December 2015, on all interested
parties in this case.