                                                                                 ACCEPTED
                                                                             01-15-00228-CV
                                                                  FIRST COURT OF APPEALS
                                                                          HOUSTON, TEXAS
                                                                       12/15/2015 1:15:30 AM
                                                                       CHRISTOPHER PRINE
                                                                                      CLERK



               No. 01-15-000228 and 01-15-00440
 ________________________________________________________________
                                                         FILED IN
     IN THE FIRST DISTRICT COURT OF APPEALS 1st    OFCOURT
                                                        TEXASOF APPEALS
                                                     HOUSTON, TEXAS
 ________________________________________________________________
                                                  12/15/2015 1:15:30 AM
                                                     CHRISTOPHER A. PRINE
                                                            Clerk
              IN RE ERNEST R. KOONCE, RELATOR

 ________________________________________________________________
   Original Proceeding From the 127th Judicial District Court of
                          Harris County
                      Cause No. 2010-64752
__________________________________________________________________



APPELLANT’S MOTION FOR AN EXTENSION OF TIME IN WHICH
                 TO FILE THE BRIEF

                       ERNEST R. KOONCE
                               Pro Se
                    15938 Fleetwood Oaks Drive
                      Houston, Texas 77079
                        Tel: (832) 434-3183
                       Fax: (832) 328-7171
                       rayk469@gmail.com
               No. 01-15-000228 and 01-15-00440
 ________________________________________________________________
          IN THE FIRST COURT OF APPEALS OF TEXAS
 ________________________________________________________________


              IN RE ERNEST R. KOONCE, RELATOR

 ________________________________________________________________
Original Proceeding From the 127th Judicial District Court of Harris
                          County, Texas
                      Cause No. 2010-64752
__________________________________________________________________



APPELLANT’S MOTION FOR AN EXTENSION OF TIME IN WHICH
                 TO FILE THE BRIEF


                      ERNEST R. KOONCE
                        RELATOR, Pro Se
                   15938 Fleetwood Oaks Drive
                     Houston, Texas 77079
                       Tel: (832) 434-3183
                      Fax: (832) 328-7171
                      rayk469@gmail.com



TO THE HONORABLE COURT OF APPEALS OF TEXAS:

     Ernest R. Koonce, Relator, and those similarly situation,
respectfully submit this motion for extension of time, and would
show the Court as follows:
IDENTITY OF PARTIES AND THEIR COUNSEL

Relator, Ernest R. Koonce, hereby certifies that the following are the
list of parties and their respective counsel, if any, to the best of his
knowledge and understanding of the rules.

PARTIES                                     COUNSEL

Relator
ERNEST R. KOONCE                                  Pro Se


Respondent

HONORABLE RK SANDILL                        127thth Civil District
                                            Court of Harris County, TX
                                            201 Caroline, 10th Floor
                                            Houston, Texas 77002
                                            Court Phone Number:
                                            (713) 368-6161

Chris Daniels                               201 Caroline
Harris County District Clerk                Houston, Texas 77002


Real Party in Interest:

WELLS FARGO BANK, NA                       Bradley Chambers
                                           Texas Bar No. 2400186
                                           Valerie Henderson
                                           Texas Bar No. 24078655
                                           Baker, Donelson, Bearman,
                                           Caldwell & Berkowitz, P.C.
                                           1301 McKinney Street
                                           Suite 3700
                                           Houston, Texas 77010
                                           (713) 650-9700 – Telephone
                                           (713) 650-9701 – Facsimile
                                      vhenderson@bakerdonelson.com
TO THE HONORABLE COURT OF APPEALS OF TEXAS:

     Ernest Ray Koonce, Relator/Appellant, and those similarly

situated, respectfully submits this motion for extension of time in

which to file his Reply to Response to Writ of Mandamus, and Reply

to Response to Supplemental Writ of Mandamus.

     The court ordered WF to provide a response to Koonce’s

Supplemental Writ of Mandamus no later than November 23, 2015,

and ordered Koonce to file his reply within 20 days thereafter. By

Koonce’s calculations, the deadline fell on Sunday, December 13,

2014, and therefore the reply was Due December 14, 2015.

      While trying to put together all of the appendix and the

response in one pdf with the tabs as required, I had much difficulty

with the program. Although I diligently tried, I was not able to meet

the deadline due to complication with the program and the very old

computer I have to use. This was not intentional, and out of

Koonce’s control.

     Therefore, appellant requests that this court grant him a 1 day

extension from December 14, 2015, due to this unforeseen issue.
                               PRAYER

     For these reasons, Appellant requests that this Court grant

him a 1-day extension of time in which to file is reply brief and reply

to supplemental mandamus, and for such other and further relief

as the court deems just and proper.

Dated: December 15, 2015         Respectfully submitted,

                                 /s/Ernest Ray Koonce
                            ________________________________
                            Ernest Ray Koonce




                        CERTIFICATE OF SERVICE



     The above and foregoing document was served in accordance

with Rule 21a on this 15th day of December 2015, on all interested

parties in this case.
