Jean-Michel Guerin v. Tina Renee Leone ( 2015 )

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.