Time: Fri Dec 12 16:21:11 1997
To: brendamc <brendamc@admin.hilconet.com>
From: Paul Andrew Mitchell [address in tool bar]
Subject: Revised Motion
Cc: 
Bcc: 
References: 

The verification was not proper;
I edited it below.


At 03:47 PM 12/12/97 -0800, you wrote:
>Dear Paul,
>
>Following is the contents of the motion to extend time after I made the changes 
>you suggested.  I thought you might want to look at the way I changed the 
>verification and proof of service.  I changed the verification to 28 USC 1746(1) 
>and borrowed part of the wording on the proof of service from your opening brief 
>in Gilbertson.
>
>Do we need to say anything else at this point about the lack of notice of hearing 
>or judgment to Dad, or the hearing being held in the wrong county?


No.  You are merely asking for more
time to research and make these
arguments.  Don't get into the 
merits here;  you have provided
sufficient reason to extend time
to file, and this is normally quite
routinely granted.


>
>--------
>
>Milburn Ray, Vernor, Sui Juris
>c/o general delivery at:
>La Pryor, Texas
>
>In Propria Persona
>
>All Rights Reserved
>without prejudice
>
>
>
>
>
>
>
>TEXAS FOURTH COURT OF APPEALS
>
>
> Zavala County Bank,
>	Plaintiff/Appellee,
>
>v.
>
>Milburn Ray, Vernor et al.,
>	Defendant/Appellant.
> )
>)
>)
>)
>)
>)
>)
>)
> Docket Number
>
>04-97-00709-CV
>
>
>APPELLANT’S MOTION TO EXTEND TIME TO FILE THE BRIEF
> __________________________________)
>
>Appellant, Milburn Ray, Vernor, under the authority of Tex.R.App.P. 74(n), asks 
>the court to extend time to file the brief.
>
>1. The 293rd/365th Judicial District Court of Zavala/Dimmit County signed the 
>default judgment in Zavala County Bank v. Milburn Vernor et al., cause number 
>97-03-09516-CV, on July 22/24, 1997.
> 
>2. Appellant perfected the appeal timely on September 10, 1997.
> 
>3. Appellant’s brief is now due on December 30, 1997.
> 
>4. Appellant requests an additional thirty (30) days to file the brief, that is, 
>an extension of time until January 30, 1998.
> 
>5. In the alternative, Appellant requests an additional fifteen (15) days to file 
>the brief, that is, an extension of time until January 15, 1998.
> 
>6. This is Appellant’s first request for an extension of time to file the brief.
> 
>7. Appellant needs additional time to file the brief because:
>a) The Christmas and New Year’s holiday season impedes the normal course of work;
>b) Appellant has retained new counsel;
>c) Appellant’s new counsel needs additional time to prepare; and
>d) Appellant needs additional time to investigate newly found evidence, which is 
>being investigated and acquired presently.
> 
>8. For these reasons, Appellant asks the court to grant an extension of time to 
>file the brief in this cause to January 30, 1998, or in the alternative to January 
>15, 1998.
>
>
>Respectfully submitted,
>
>
>
>__________________________________
>Milburn Ray, Vernor
>c/o General Delivery
>La Pryor, Texas state
>
>
>
>VERIFICATION
>

[delete starting here]

>
>Texas state		)
>				)	
>Zavala county  	)
>
>Under penalties of perjury pursuant to 28 U.S.C. 1746(1), I, Milburn Ray, Vernor, 
>Christian in the herein attached APPELLANT’S MOTION TO EXTEND TIME TO FILE THE 
>BRIEF, affirm by my bonafide and genuine signature hereon, the facts and 
>allegations therein, and further, affirm said facts and allegations to be true and 
>correct to the best of my information and belief, so help me God.

[stop deletion here]


I, Milburn Ray, Vernor, a Christian, hereby verify, 
under penalty of perjury, under the laws of the
United States of America, without (outside) the
"United States" (federal government), that the
above statement of facts is true and correct,
according to the best of My current information,
knowledge, and belief, so help Me God, pursuant
to 28 U.S.C. 1746(1).  See Supremacy Clause.


Executed on:  [date]

Respectfully submitted,



_____________________________________________
Milburn Ray, Vernor, Sui Juris
Citizen of Texas state
(expressly not a citizen of the United States)

All Rights Reserved without Prejudice


>
>
>
>							
>______________________________
>							Milburn Ray, Vernor
> 
>
>PROOF OF SERVICE
>
>I, Milburn Ray, Vernor,  Sui  Juris,  hereby  certify,  under
>penalty of  perjury, under  the laws  of  the  United  States  of
>America, without the "United States," that I am at least 18 years
>of age,  a Citizen  of one  of the  United States of America, and
>that I personally served the following document(s):
>
>APPELLANT'S MOTION TO EXTEND TIME TO FILE THE BRIEF
>
>by placing true and correct copies of said document(s) in first
>class U.S. Mail, Certified Mail Return Receipt Requested, with 
>postage prepaid and properly addressed to:
>
>
>Fourth Court of Appeals			___________________________
>300 Dolorosa, Suite 3200				
>San Antonio, Texas 78205-3037
>
>Joe M. Davis 					___________________________
>NUNLEY & JOLLEY, L.L.P.			
>194 S. Main Street, Suite 301
>Boerne, Texas 78006
>
>J. Ken Nunley 					___________________________
>NUNLEY & JOLLEY, L.L.P.			
>194 S. Main Street, Suite 301
>Boerne, Texas 78006
>
>
>
>
>Dated:  __________________________________
>
>
>__________________________________________
>Milburn Ray, Vernor, Sui Juris
>Citizen of Texas state
>All Rights Reserved without Prejudice
>_________________________
>
>Soon as you approve these changes I will get Dad to sign it and we will get it 
>sent off in the mail.
>-- 
>Brenda McCurdy 
>(a state Citizen by birth, my only allegience is to the one true God)
>
>Romans 3:29-31  Is he the God of the Jews only? is he not also of the Gentiles? 
>Yes, of the Gentiles also: 30 Seeing it is one God, which shall justify the 
>circumcision by faith, and uncircumcision through faith. 31 Do we then make void 
>the law through faith? God forbid: yea, we establish the law.
>
>Isaiah 53:1-11  Who hath believed our report? and to whom is the arm of the LORD 
>revealed? 2 For he shall grow up before him as a tender plant, and as a root out 
>of a dry ground: he hath no form nor comeliness; and when we shall see him, there 
>is no beauty that we should desire him. 3 He is despised and rejected of men; a 
>man of sorrows, and acquainted with grief: and we hid as it were our faces from 
>him; he was despised, and we esteemed him not. 4 Surely he hath borne our griefs, 
>and carried our sorrows: yet we did esteem him stricken, smitten of God, and 
>afflicted. 5 But he was wounded for our transgressions, he was bruised for our 
>iniquities: the chastisement of our peace was upon him; and with his stripes we 
>are healed. 6 All we like sheep have gone astray; we have turned every one to his 
>own way; and the LORD hath laid on him the iniquity of us all. 7 He was oppressed, 
>and he was afflicted, yet he opened not his mouth: he is brought as a lamb to the 
>slaughter, and as a sheep before her shearers is dumb, so he openeth not his 
>mouth. 8 He was taken from prison and from judgment: and who shall declare his 
>generation? for he was cut off out of the land of the living: for the 
>transgression of my people was he stricken. 9 And he made his grave with the 
>wicked, and with the rich in his death; because he had done no violence, neither 
>was any deceit in his mouth. 10 Yet it pleased the LORD to bruise him; he hath put 
>him to grief: when thou shalt make his soul an offering for sin, he shall see his 
>seed, he shall prolong his days, and the pleasure of the LORD shall prosper in his 
>hand. 11 He shall see of the travail of his soul, and shall be satisfied: by his 
>knowledge shall my righteous servant justify many; for he shall bear their 
>iniquities.
>***********************There is no remission of sins without the shedding of 
>blood.  Yeshua is God's Passover Lamb.**********************
>
>
>
      


Return to Table of Contents for

Supreme Law School:   E-mail