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14-14-00947-CV 

IN THE FOURTEENTH COURT OF APPEALS, 

HARRIS COUNTY TEXAS 

 

MARIANN BACHARACH, Appellant 

V. 

JOHN DOE, Appellee 

Appeal from County Court at Law Number Two, Harris County, Texas 

 

APPELLEE’S RESPONSE TO APPELLANT’S MOTION TO CONTESTING 

ABILITY TO PAY COSTS 

 

Eric Dick 

Texas Bar No. 24064316 

4325 Tulsa 

Houston, Texas 77092 

Tel. (832)207-2007 

Fax (713)893-6931 

ACCEPTED

14-14-00947CV

FOURTEENTH COURT OF APPEALS

HOUSTON, TEXAS

2/11/2015 4:10:33 PM

CHRISTOPHER PRINE

CLERK
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TO THE HONORABLE FOURTEENTH COURT OF APPEALS: 

COMES NOW, Appellee, John Doe, and advises this Court that the 

Appellate, Mariann Bacharach, again is being less than candid with the court and 

again has left out income information from her affidavits and from her current 

court filings. Appellant is gaming the trial Court and the Appellate Court as a 

result of her previous professional litigant experience. Please note the attached 

Motion that she has filed in the 13th Court of Appeals that was filed on today’s 

date, February 11, 2015. Attached see Appellant’s motion as Exhibit 1. She is now 

claiming to earn approximately $1,100.00 while working at a law office. Please 

note that she has been working in this office since January 13, 2015 and has failed 

to advise the Court of any of those resources. She has known this all along and has 

mislead the trial Court and the Appellate Court by failing to disclose employment 

and income resources. She has conveniently now changed her position that she 

can afford appellate costs. 

Respectfully submitted, 

By: /s/Eric Dick 

Eric Dick 

Texas Bar No. 24064316 

4325 Tulsa 

Houston, Texas 77092 

Tel. (832)207-2007 

Fax (713)893-6931 

eric@dicklawfirm.com 
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CERTIFICATE OF SERVICE

I certify that on February 11, 2015, a true and correct copy of Appellee’s 

Response to Appellant’s Motion Contesting Ability to Pay Costs was served to each 

person listed below by the method indicated. 

/s/Eric Dick 

Eric Dick 

Mariann Bacharach 

PO Box 8217 

Houston, TX 77288 

CMR No.: 7014 0510 0000 2483 9451 
13-14-000693-CV

IN THE FOURTEENTH COURT OF APPEALS

HARRIS COUNTY, TEXAS

MARIANN BACHARACH,

Appellant,

V.

EUFEMIA GARCIA,

Appellee.

APPELLANT’S MOTION FOR EXTENSION

OF TIME TO PAY COURT COSTS AND FURTHER REVIEW 

Mariann Bacharach

P.O. Box 8217 

Houston Texas 77288

Pro se 

832-352-5926

bacharachmariann@gmail.com
TO THE HONORABLE THIRTEENTH COURT OF APPEALS:

Appellant Mariann Bacharach files this Motion for Extension of Time to pay court 

costs and respectfully shows Appellant is appealing from a appealable order signed by 

the 389th District Court of Hidalgo County Texas on October 22, 2014 in the case styled 

Eufemia Garcia v. Mariann Bacharach, cause no. C-5535-14-H. The deadline to pay fees for 

the Appeal was February 9

th 2015. 

This extension of time is necessary because Appellant Mariann Bacharach has 

been unemployed and without self-employment income since Spring of 2014 and has 

only recently been able to secure some type of temporary part time employment. The 

Appellant Mariann Bacharach had filed a Affidavit of Indigency, a supporting Affidavit 

of Indigency, an Affidavit explaining self-employment income and supporting documents

with the trial court and a contest had been sustained. Appellant Mariann Bacharach is 

resident of Harris County Texas did not have the funds to travel to a distant local, 

Hidalgo County Texas, for a hearing regarding indigency on short notice. Her affidavits, 

supporting documents and previous statements regarding inability to even hire a lawyer

were not considered by the court. Appellant Mariann Bacharach had informed the court 

repeatedly in her pleadings and in a previous hearing that she cannot afford an attorney 

and cannot afford to travel while defending herself in two similar causes of action, let 

alone pay for all costs related to this lawsuit and appeal while being dogpiled.

The Appellant Mariann Bacharach’s financial situation has changed since the 

filing of her first affidavit with the court in December of 2014 and she requests the 
Honorable Thirteenth Court of Appeals review her current income to determine ability to 

pay costs. Mariann Bacharach has been employed by the law office of Trent Gaither

temporarily part time since 01/13/2015 and can currently pay partial costs associated with 

this appeal and two other appeals currently pending with fees due in the Fourteenth Court 

of Appeals.

The Appellant Mariann Bacharach expects to be paid for this work on 2/13/2015 

and anticipates having in between $900.00 to $1,100 for this work. The Appellant 

Mariann Bacharach does not currently have any supporting documents regarding this 

income since she has yet to be paid but will submit to the court by 02/16/2015 proof of 

this income and other supporting documents. Appellant Mariann Bacharach apologizes 

for making this request without supporting documents however these documents are not 

yet available. The Appellant Mariann Bacharach relies on the following rule for this 

extension and review to be granted pursuant to TEX. R. APP. P. Rule 20.1 (I) (20) (k) 

Partial Payment of Costs.

If the party can pay or give security for some of the costs, the court must order 

the party, in writing, to pay or give security, or both, to the extent of the party's ability. 

The court will allocate the payment among the officials to whom payment is due.

This extension of time to pay costs and for further review of ability to pay costs is 

not sought for the purposes of delay, but so that justice may be done.
All facts recited in this motion are within the personal knowledge of the pro se 

Appellant Mariann Bacharach signing this motion, therefore no verification is necessary 

under Rule of Appellate Procedure 10.2.

PRAYER FOR RELIEF

For these reasons, Appellant Mariann Bacharach respectfully requests that the 

Court grant this motion and extend the deadline to pay court costs until February 23, 

2015 or until partial costs can be determined by the court. Appellant respectfully further

requests the Honorable Thirteenth Court of Appeals allow the Appellant Mariann 

Bacharach to pay partial costs of this Appeal to be determined by the court and all other 

relief to which Appellant may be justly entitled.

Respectfully submitted,

______/s/ mariann bacharach/____

 P.O. Box 8217

 Houston Texas 77288

 832-352-5926

 bacharachmariann@gmail.com

Appellant

 mariann bacharach
The above signed is unable to notify opposing counsel other than via certified mail 

or eFile as opposing counsel refuses to communicate via email, fax or telephone with 

Mariann Bacharach. Counsel for the Appellee will more than likely oppose this motion

CERTIFICATE OF CONFERENCE

I certify that I conferred with counsel for Appellee regarding this motion via eFile. 

Appellee may be opposed to this motion.

/s/ mariann bacharach/

CERTIFICATE OF SERVICE

I certify that on 12/28/2014 I mailed a copy of this motion to the following 

counsel by First Class U.S. Mail or eFile notification.

Chris Carmona

P. O. Box 90014

Houston Texas 77290

chris@carmonalawoffice.com

Counsel for Appellee

/s/ mariann bacharach/