COURT OF APPEALS FOR THE 

### FIRST DISTRICT OFTEXAS ATHOUSTQNou^ofappeals HOUSTON, TEXAS NOV 13 2015

CASE # 01-13-00362-CV CHRISTJBPHEJR/c-P^INE CLERK?

PHILLIP MANDERSCHEH), PLAINTIFF/APPELLANT,

v.
LAZ PARKING OF TEXAS LLC, and BOOT MAN, INC. D/B/A PREMIER PARKING ENFORCEMENT,
DEFENDANT/APPELLEE.

MOTION TO ENLARGE TIME WITHIN WHICH APPELLANT'S MOTION FOR REHEARING THE COURT'S OPINION OF 15 OCTOBER 2015 MAY BE TIMELY COMPLETED AND FILED Phillip Manderscheid, Appellant pro

se 315 Heidrich Street Houston, Texas 77018 Res: 832-848-1934 Cell: 832-423-0951

Page 1of SevenPages request for enlargement of time within which to complete and-mw Appellant's Motion for Rehearing ofthis Court's Opinion of 15 October 15.II. MOTION TO ENLARGE TIME WITHIN WHICH APPELLANTMAY TIMELY COMPLETE AND FILE APPELLANT'S MOTION FOR REHEARING OF THIS COURT'S OPINION OF 15 OCTOBER 15. 6. This Motion To Enlarge Time to make timely filing ofAppellant's Motion 

### for Rehearing of the Court's OPINION of 15 October 15 is timely made pursuant to theTexas Rules ofAppellate Procedure (TRAP) generally, and 

### in particular pursuant to TRAP, Rule 49 said motion being in compliance with TRAP, Rule 10.5(b) 

### 7. Pursuant to TRAP, Rule 49.1, amotion forrehearing may be filed within 15 days after the court ofappeals' judgment or order is rendered. 

### 8. Further, pursuant to TRAP, Rule 49.8, a court of appeals may extend the 

### time for filing a motion for rehearing or enbanc reconsideration if a party files a motion complying with Rule 10.5(b) no later than 15 days after the last date for filing the motion. 9. Further, pursuant to TRAP, Rule 10.5(b), Appellanthere makes this his first 

### request for enlargement oftime to file his Motion for Rearing of this Court 

### Opinion of 15 October 15 Motion for Rehearing. Appellant has not 

### previously made any request norhas Appellant been denied any previous request for enlargementto file Appellant's Motion forRehearing. 10. The Court's Opinion in this case was rendered and filed on 15 October 15 

### and the last day on which aMotion toEnlarge may timely be filed pursuant toTRAP is 15 November 15 thus rendering this presentmotion toenlarge as being timely. 

### 11. Appellants are here requesting an enlargement for a reasonable time of 

### fifteen (30) days from Sunday, 15 November 15, to and including Tuesday, 15 December 15.

Page 3 of SevenPages12. The court's Opinion was rendered and filed on 15 October 15 after many months and the Opinion consisted of29 pages text. In appellant's view, the opinion requires significant research in order to properly address the multiple issues rising from the Opinion for purposes of a Motion for Rehearing. It is impossible for this Appellant to properly complete this task within the present due date of 15 November 15 under the rules without an enlargement of time. Due Process requires that Appellant request of this court an enlargement of time in order to meet the Appellant's burden respecting his Motion for Rehearing. 13. Appellant is here proceeding pro se without the assistance ofcounsel for this 

### appeal andis,accordingly, having toindividually research, write andprepare the Motion for Rehearing for filing with this court without aid and assistance 

### of professional and experienced counsel while not being personally experienced and/or trained in the task at hand. This has and will continue to require a greater and more complex work load than is possible to be completed within the present due date of 15 November 15. 14. Further, Appellant has experienced added complications for this task of 

### researching, writing andtimely filing of his Reply Briefsince theAppellee has raised fundamental jurisdictional issues challenging this court's jurisdiction overthis appeal. 

### 15. Appellant is seeking to address multiple errors which are perceived by Appellant as being inconsistent with the ends ofjustice and due process of law. Those complex issues together with the scope and number ofthose 

### issues make it impossible forappellant to timely complete the taskwithout
an appropriate enlargement oftime from this court.

Page 4 of Seven Pages16. Each and all of the foregoing make absolutely necessary this Appellants request for an extended thirty (30) enlargement of time given the circumstances rising from this appeal. 17. Accordingly, Appellant request of this court an enlargement time in the reasonable amount of thirty (30) days be GRANTED within which Appellant may complete and timely file his Motion for Rehearing ofthis 

### court's Opinion of 15 October 15 which request seeks to enlarge the filing 

### due date from Sunday, 15 November 15 to and including Tuesday, 15 December 15. in. NO ONE WILL BE INJURED BY THIS COURT'S GRANTING A THIRTY

DAYENLARGEMENT OF TIME WITHIN WHICH APPELLANTMAY

TIMELY FILE HIS MOTION FOR REHEARING OF THIS COURT'S OPINION OF 15 OCTOBER 15. 

### 18. Should this court grant Appellant's requests for thirty (30) day enlargement oftime inthis case, noone will beunjustly delayed orinjured. Alternatively, the enlargement of time will permit and afford to the Appellant a due 

### process sufficient to complete his Motion for Rehearing of the Opinion of this court dated 15 October 15. 

### 19. This request forenlargement oftime is notbeing made for anypurpose of 

### delay butrather for sufficient and reasonable added time topermitAppellant adequate time to complete preparation and timely filing ofhis Motion for Rehearing ofthe Court's Opinion of 15 October 15. 

### WHEREFORE PREMISES CONSIDERED, Appellant requests relieffrom this

court as follows:

Page 5 of SevenPages1. That this court GRANT Appellant's requests for a thirty (30) day enlargement oftime within which Appellant Motion for Rehearing ofthe Court's Opinion of 15 October 15 may be completed and timely filed with the clerk ofthis court, and 2. That the court GRANT the Appellant's request for an Enlargement oftime of thirty (30) days enlargement from Sunday, 15 November 15 to and including Tuesday, 15 December 15, and 3. That this court GRANT to Appellant added and other reliefthat to the court isjust at law and/or in equity, and 4. Appellants requestjustice. Respectfully submitted,



### AXXAfffiUtfMi 

### ^Phillip Mand^rsohefdVAppellantpro se iS Heidrich Street Houston, Texas 77018 Res: 832-848-1934 Cell: 832-423-0951

Page 6 of SevenPagesCERTIFICATE OF SERVICE I hereby certify that a true and correct copy ofthe foregoing Motion to the 

### court ofAppeals has on this the /j) day of November, 2015 been forwarded to the counsel for Appellee at his address ofrecord as is filed in the records ofthis appeal.

Page 7 of Seven Pages