Daryl Barnes

March 16 th ,2015

ECF

Re: Daryl Barnes et.al.,

V Kevin Fulton and National Housing Development Corporation

Civil Action No. 01- 15 -00060

I am counsel pro se in the afore mentioned cause of action styled and captioned. Appellants Daryl Barnes and Demeatrice Goff hereby moves the Court, pursuant to Rule 10.5 (b) of the T.R.A.P.

, Texas Rules of Appellate Procedure , for an extension of time of thirty days in which to file their Brief. The Brief currently is due , March 19 th , 2015. This is the appellant’s first request for an extension of time. If the Court grants this request, the Brief will be due on Wednesday, April 19 th 2015. The Record in this case is very long.. The transcripts have not been filed because of non payment. the petitioners are pro se and unable to pay for the transcripts and need time to gather the funds.

There are numerous exhibits, indeed the record on appeals itself is an exhibit. Appellate counsel wish to ensure the Court is as fully briefed as possible Acquisition of the Record in this case has necessitated more time than counsel anticipated. The Petitioners has not established their status as being indigent we only found out thru the rejection of a legal document we attempted to file on March 14 th 2015. Although we did receive a request from the honorable court that we establish indigence, petitioners thought that by forwarding the Affidavit Of Indigence already filed and established in the 129 th district court Harris County, TX After speaking with the clerk of court we now understand what we must do to remedy the situation.. The Appellants also would like the court to make rulings on a motion that the petitioners attempted to file on March 14 th 2015, which cannot be filed until status of indigency has been established. ACCEPTED
01-15-00060-CV
FIRST COURT OF APPEALS HOUSTON, TEXAS
3/16/2015 3:50:24 PM
CHRISTOPHER PRINE

CLERKThe petitioners are cognizant that the Court disfavors extensions of time and rarely

grants those greater than fourteen days. But given the voluminous Record and the importance of briefing of the highest quality to at least the petitioner’s liberty and

the Court’s decision

- making process, the appellant requests thirty days to make certain that the issues on appeal are fully briefed and presented well to the Court.

Accordingly, this Court should extend the time in which to file the Brief of the Appellant until April 19 th 2015.

Wherefore, Appellant s Daryl Barnes and Demeatrice Goff respectfully requests an extension of time of thirty days in which to file his Brief. Respectfully sub mitted,

March16th

, 2015

Daryl Barnes /s/ Daryl Barnes

Demeatrice Goff /s/ Demeatrice Goff

7741 James Franklin
Houston, Tx 77088

Email: dbarnes.humble@gmail.com Email: dgoff.humble@gmail.com Phone (832)988

- 0403

Respectfully Submitted

Cc all attorneys of record

Daryl Barnes /s/ Daryl Barnes

dbarnes.humble

832

- 988

- 0403Certificate of Service

As required by Texas Rule of Appellate Procedure 6.3 and 9.5(b), (d), (e), I certify that I have served this document on all other parties which are listed below

on March 16 th 2015 as follows:

defendant [ Kevin Fulton ]

Attorne y for Defendant Kevin Fulton Valex Duke Amos

By fax email ECF

Defendant National Housing Development Corporation

General Counsel Phillip Lee

9421 Haven Avenue Rancho Cucamonga, CA 91730 Phone: (909) 483

- 2444 Fax: (909) 483

- 2448 By Email Fax and ECF