No.

IN THE SUPREME COURT OF TEXAS

CECILIA CLINKSCALE, Petitioner, V.

LEIROI MICKELE' DANIELS, Respondent

MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR REVIEW

TO THE HONORABLE SUPREME COURT OF TEXAS: ComesNow, Cecilia CHnkscale, Petitioner (hereinafter, "Petitioner"), in the above styled civil action and files this Motion For Extension OfTime To File Petition For Review in compliance with Tex. R. App. P. 10.1,10.5(b), 10.5(b)(3), and 53v7(f). In support of this Motion, Petitioner seeks to show this Court the following: L

Petitioner filed her Motion Rehearing ForEn Banc, Wednesday,July 1,2015.

n.

TheJustices in the Courtof Appeals For The First District Of Texas At Houston denied the said Motion on Tuesday, October 13, 2015. See Exhibit i.

Ill- Tex. R. App. P. 53.7(c) establishes thata Petition For Review is due forty-five (45) days from the later date of the courtof appeals' judgment or its last ruling on a timely filed motion for rehearing or rehearing en banc. Tex. R, App. P. 53.7(a). As such, Petitioner's Petition For R^ads^ue.on^ndS November 27,2015. Tex. R. App. P. 10.5(b)(A). CjrST I COURT OF AP.pfALS1 HOUSTON, TEXAb DEC " 3 ZM5 CHRISTOPHER A. PBINE ICLERK.

IY.

Petitionerseeks additional time to thoroughly examine her trialcourt and appellate court case files. Time is necessary to carefully review, analyze, and to identify the documents material to the preparation of herPetition For Review. Petitioner seeks additional time to research, identify, and to synthesize statutes, laws, caselaws, and legal scholarship which discusses and frames the subject(s) and arguments) in Petitioner's Petition ForReview. Tex. R. App. P. 105(b)(C). Petitioner seeks time to draft her PetitionerFor Review and to consultwith Counsel and like legal professionals adept in the process of preparing a suitablePetition For Review. Tex. R. App. P. 10.5(b)(C).

As well, Petitioner will issue Requests ForFindings OfFactAnd Conclusions OfLaw to both the trial and appellate courts to better gage and to articulate the points on which Petitioner relies for her Petition For-Reviewin the Supreme Court of Texas. Tex. R. App. P. 10.5(b)(C).

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Further, Petitioner seeks time to resolve pending Motions and discrepancies in the Court of Appeals.

VII.

In consideration of the points set forth, Petitioner requests an extension of time of thirty (30) days, to Saturday, December 26, 2015; therefore, Petitioner's Petition For Review would be dueon Monday, December 28,2015. Tex. R. App. P. 10.5(b)(B).

VIII.

Petitioner has not requested an extension of time in this case. Tex.R. App. P. l0.5(b)(D).

IX.

The extension of time requested is not sought for delay, and it is not prejudicial to Respondent Tex. R. App. P. 10.5(b)(D).

CONCLUSION AND PRAYER Wherefore, Petitioner, Cecilia Clinkscale, submits her Motion For Extension OfTime To File Petition For Review, and she respectfully requests relief from this Court in the interestof justice.

With this, Petitioner requests this Court to enter an Ordergranting herMotion, and to grant herany additional reliefthat this Court deems proper, permissible, and just.

Respectfully submitted, Post Office Box 42718, Philadelphia, Pennsylvania 19101 Telephone: (215) 828-4516 Email: [email protected] CERTIFICATE OF CONFERENCE I certify thatI corresponded with Defendant, Mr. Leiroi Mickele' Daniels, Esquire, on Friday, November27, 2015, by wayof electronic communication and facsimile. I havenot yet heard back from Counsel. See Exhibit 2. Tex. R. App. P. 10.3(a)(2).

Dated: CERTIFICATE OF SERVICE Pursuant to Tex. R. App. P. 6.3, 9.5(a)-(e), I, Cecilia Clinkscale, Petitioner, dohereby certify that onthis 27* day ofNovember 2015, a true and correct copy ofthe attached and foregoing Motion ForExtension OfTime To File Petition For Review ms served upon the recipients listed below in the following manner(s): Mr. Blake Hawthorne, Esquire, Clerk, Supreme Court of Texas, West 14*Street, Room 104, Austin, Texas 78731 Service: United States Postal Service, first-class, certified mail.

Mr. Christopher A. Prine, Esquire, Clerk of the Court, Court of Appeals, First District of Texas, Fannin Street, Room 208, Houston, Texas 77002-2066 Service: United States Postal Service first-class mail.

Mr. Leiroi Mickele' Daniels, Esquire, L Mickele' Daniels & Associates, Arena Tower I, Suite 580, 7322 Southwest Freeway, Houston, Texas 77074 Service: United States Postal Service first-class mail.

CEC Petii InPrbpria Persofia EXHIBIT 1

Court of Appeals for the First District of Texas at Houston Order on Motion for En Banc Reconsideration Appellate case name: Cecilia Clinkscale v. Leiroi Mickele Daniels Appellate case number: 01-14-00968-CV Trial court case number: 2012-58724 Trial court: 113th District Court of Harris County Date motion filed: September 23,2015 Party filing motion: Appellant The motion for en banc reconsideration is ordered DENIED.

Judge's signature: /s/ Harvey Brown Acting for the Court* En banc court consists of: Chief Justice Radack and Justices Jennings, Keyes, Higley, Bland, Massengale, Brown, Huddle, and Lloyd.

Date: October 13.2015 Gmail - Position on Motion For Extension Of Time To File Petition For Review... 11/27... Page 1 of 2

C Clinkscale <cclinkscale@gmail,com>

Position on Motion For Extension Of Time To File Petition For Review...

11/27/2015 message C Clinkscale <[email protected]> Fri, Nov 27, 2015 at 5:44 PM To: LEIROI DANIELS <[email protected]> Cc: C Clinkscale <[email protected]> Post Office Box 42718, Philadelphia, Pennsylvania 19101 Phone:(215)828-4516 Email: [email protected] EXHIBIT 2

Friday,November 27, 2015

Mr. Leiroi Mickele' Daniels, Esquire, L. Mickele' Daniels & Associates, IXC, Arena Tower I, Suite 580, 7322 Southwest Freeway, Houston, Texas 77074 Fax: (713) 995-4685 Dear Mr. Daniels:

I am corresponding with you to notify you that I intend to file a Motion For Extension OfTime To File Petition For Review.

I remain open to any consideration that you offer in this matter My contact information is noted atop this letter for your convenience.

Sincerely,

Ms. Cecilia Clinkscale

Petitioner, In Propria Persona

https://mail.google.com/rr^^ 11/27/2015 Gmail - Successful transmission to 17139954685. Re: Position On Motion To Extend Ti... Page 1 of 2

C Clinkscale <[email protected]>

Successful transmission to 17139954685. Re: Position On Motion To Extend Time To File Petition For Review... 11/27/2015 message [email protected] <[email protected]> Fri, Nov 27, 2015 at 5:46 PM To: [email protected] Th* 2 p*sg« tax you sent through MyFaxto 17! 3SQS488Swas successfully g?nsm!!tf>d.

€mwfax' Dear Cecilia, Re: Position On Motion To Extend Time To File Petition For Review... 11/27/2015

The 2 page fax you sent through MyFax to 17139954685 was Try the successfully transmitted at 2015-11-27 23:45:59 (GMT).

The length of transmission was 53 seconds Topis The receiving machine's fax ID: 7139954685

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nttps://mail.google.coni/mail/u/0^ 11/27/2015 Bbst'OfFrce Box 42718, - lhiladelphis,,Pennsjlvfiriia 1^101 EiaaSk: cclinkscale(^rnail.qpm

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Mr.LeiroiMickeler"Daniels, •-;;' ••':" :.;::-:,.„ .-,-;; •',,' Esquire, •: Wiv • L. Mickele'rD"anieis & Associsttes, LLC, Arena To^er^I, • - '- . . -\ ^m'Wk ' .-' :::..' •' .• -:,.•,'• '..:; i -o-: •'", 7322South-west Freeway, " ' V ' Houston,Texas 77074 .•"."•' " '•" "^ •-::. • :^- • /'••: - J; •.""' Fax (71$055-4685 . .,;.;. J , _ .: ,/.. j-::; - ;:.'..v Dear Mr. Danfelis: lam •CGtresponding with you to notity fou-that 1inCead toSifes amotion ForExtettsiffn. '<$fimTfcF2?e ReMo&F'opl&vim,

My^ contact.informaticmis noted••i^p\tfeie'ter"for-^.i^^o^^i!^d'4: Sincerely^

Ms.Gteilk-Clinkscale rp r :v\'. :> £e4tior»er, , 'fevPK>prkcE%JSona •-' VERIFICATION

STATE OF PENNSYLVANIA § § COUNTY OF MONTGOMERY §

BERFORE ME, the undersigned Notary Public, on this daypersonally appeared Cecilia Clinkscale, who, being byme duly sworn on oath, diddepose andsay the following: OATH

"My name is CECILIA CLINKSCALE. I amthe Petitioner in the above-styled case. I have read the foregoing Motion For Extension OfTime To File Petition For Review, and each statementof fact thereinis true and correct. I have personal knowledge of each such fact stated therein." FURTHER, AFFIANT SAYETH NOT.

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L^tfe|r \ jjj C-, ll n fcgg^l-Q ~ ^SUBSCRIBED TO AN0 SWORN BEFORE ME, GpCvU ^ ChAlCs c^lg. on the cr ' day of November 2015, tocertify which witness my hand and official seaL ggmmenwgajttj of Pennsylvania NOTARIAL SEAL [Seal] Paul J McCarthy, Notary Public NOTARY PUBLIC IN AND^DR THE Lower Merlon Township, Montgomery County My Commission Expires September 25,2018 STATE OF PENNSYLVANIA

Print Name

My Commission Expires: No.

IN THE SUPREME COURT OF TEXAS

CECILIA CLINKSCALE, Petitioner,

LEIROI MICKELE' DANIELS, Respondent.

ORDER

On this [ day of 2015, came upon for consideration Motion For Extension OfTime To File Petition For Review, The Court having reviewed saidMotion finds that it should be, and herebyis, .

It is so ORDERED.

Signed this day of . , 20 .

JUDCE