Case Information

*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 3/13/2015 4:18:25 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-14-00680-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 3/13/2015 4:18:25 PM CHRISTOPHER PRINE CLERK Cause No. 01-14-00680-CV Elizabeth Copeland, § In the Court of Appeals

Appellant, §

§ —versus— § First Court of Appeals District

§ Barry Copeland, §

Appellee. § Houston, Texas APPELANT’S MOTION FOR EXTENTION OF TIME TO FILE BRIEF TO THE HONORABLE JUSTICES OF SAID COURT:

NOW COMES Appellant Elizabeth Copeland, and respectfully requests that this Court extend

the deadline to file the Brief of Appellant by three business days, and would respectfully show

the

Court as follows:

A. Factual and Procedural History The case is on appeal from the 311th and 312th Judicial District Courts, Harris County, Texas. The style and number of the case in the trial court was In the Matter of the Marriage of

Barry L. Copeland and Elizabeth Copeland, and in the Interest of […], Minor Children , Harris

County District Court Cause No. 2012-39055. This is an appeal from a Final Decree of Divorce rendered after an arbitration proceeding. The present deadline for Appellant to file her brief in this case is March 11, 2015. Appellant requests a three business day extension of this deadline.

B. Argument and Authorities This Court has the authority to grant a motion to extend the deadline to file a party’s brief under Texas Rule of Appellate Procedure 10.5(b). Appellant seeks an extension of time of three business days—until March 16, 2015—to

file

her brief. Appellant sought additional time to file her brief due to computer issues. Two

significant sections of her brief are unable to be retrieved. Appellant was able to re-create and finish the missing portions. And arranged for a

messenger to pick them up as she had a doctor's appointment out of state and was quickly

leaving. (the court has a letter from the doctor attached to First request for extension

confirming , but the appointment was actually moved to the llth).. Appellant's brief was

picked up by someone purporting to be a messenger from the concierge. Appellant is

baffled(and frustrated). The messenger she hired said he was told it had already been

picked up when he arrived (the concierge confirmed two different people came)

Appellant has part of her brief on her computer, but the recreated portions are on her

friend's computer, who is out of town on Spring Break with her children and until

Sunday. Appellant was in a rush to get out of town did not print out an additional copy

The files are not accessible from my computer. Appellant has been trying to reach her

sister, who has a key, but thinks she may be out of town also. Three extensions have been granted thus far to Appellant’s former attorneys. This is her

third and last request since representing herself.

C. Conclusion and Prayer 11. For the foregoing reasons, Appellant Elizabeth Copeland, respectfully requests that this Court

grant her grant her Motion for Extension of Time to File Brief of Appellant, and extend that

deadline for three business (3) days—until March 16, 2015.

12. Appellant has not spoken with Appellee’s Attorney yet. Appellant believes this Motion is

opposed. And will notify the court immediately if that is incorrect. Certificate of Conference is

being sent via email on March 13, 2015.

Respectfully submitted, *3 /s/Elizabeth Copeland

Elizabeth Copeland 14655 Champion Forest Drive #1803 Houston, Texas 77069 (832) 925-1904—phone (281) 583-0948—fax elizabethpaytekendrick@gmail.com C ERTIFICATE OF C ONFERENCE I hereby certify that on March 13, 2015, I emailed a copy of this motion to Sallee Smyth,

counsel for Appellee Barry L. Copeland, Jr.

/s/Elizabeth Copeland Elizabeth Copeland C ERTIFICATE OF S ERVICE I hereby certify that on March 13, 2015, a true and correct copy of the foregoing was sent via

priority certified mail, return receipt requested, to the following counsel of record:

Sallee Smyth

S ALLEE S. S MYTH , A TTORNEY AT L AW

800 Jackson St Richmond,

TX 77469

smyth.sallee@gmail.com

Counsel for Appellee Barry Copeland

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