Bausch and Lomb_Opposition_2_RamirezWritofCert_2017-03-14

More documents

Recommendations

Info

Case: 12-14679 Date Filed: 01/02/2013 Page: 3 of 8 12. This having occurred, I felt comfortable that the record excerpts would be forwarded to this appellate court for me. 13. I have never done this type of appeal before and I speak English fluently, but as my second language. I am not mentally challenged and I also have a few years of college. Yet I feel I was misled by the clerks representations to me, although not intentionally. 14. Furthermore, I was accompanied by an individual named Donny Rhode on the day that I went to the clerk's window and the misunderstanding occurred and was furthered. 15. Mr. Rhode witnessed the conversation, and claims to recall it in a similar manner and I have included his sworn affidavit indicating that his recollections are similar to mine. 16. It was due to this misunderstanding and mis-communication, and no other reason, that I failed to include the record excerpts as required. 17. Since 2007, I have been on substantial medications that sometimes cause drowsiness and dizziness and, to some degree, a loss of memory. I cannot say with any certainty that this condition may have contributed to my mis-perception of the rule that I am now found to have violated. 18. Due to these circumstances and because the dismissal of my appeal will produce a very harsh result, and because my initial brief 36
P A Case: 12-14679 Date Filed: 01/02/2013 Page: 4 of 8 demonstrates a meritorious ground for appeal, I am asking that this court reinstate my appeal 19. I have made the correction to the record excerpts and have included them simultaneously with this filing as required by the Rules that I have based this motion upon. CONCLUSION WHEREFORE, the appellant, Carlos Ramirez, pro se respectfully requests that this Court find that these circumstances in their totality be considered "extraordinary" and reinstate this appeal. CARLOS RAMIREZ, Pro Se 1514 N. Florida Avenue Tampa, Fl 33602 (813) 474 2038 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a copy of this Appellant's Motion To Reinstate has been provided to the following individuals by deposit in the U.S. Mail with proper postage affixed this 31st day of December 2012. Amanda E. Ballard, Esq. and Kevin Douglas Zwetsch, Esq. Ogletree Deakins, PC Suite 3600 100 N. Tampa Street 37
Page 1 and 2: Ogletree Deakins Karen M. Morinelli
Page 3 and 4: QUESTIONS PRESENTED I. D o Federal
Page 5 and 6: QUESTIONS PRESENTEDi TABLE OF CONTE
Page 7 and 8: Federal Rule of Appellate Procedure
Page 9 and 10: JURISDICTION Ramirez's Petition for
Page 11 and 12: STATUTORY PROVISIONS AND RULES INVO
Page 13 and 14: After remand, the district court ag
Page 15 and 16: and to "find that the circumstances
Page 17 and 18: On November 21, 2016, Ramirez sough
Page 19 and 20: filing by either party hence, the a
Page 21 and 22: 2587, 542 U.S. 367, 381 (2004) (cit
Page 23 and 24: F.3d 1337, 1341 n.2 (11th Cir. 2011
Page 25 and 26: Simply calling a document a motion
Page 27 and 28: motion to set aside the dismissal a
Page 29 and 30: (Petition, p. 11). Nevertheless, th
Page 31 and 32: CONCLUSION AND RELIEF SOUGHT For al
Page 33 and 34: NO. 16-7880 IN THE SUPREME COURT OF
Page 35 and 36: Dated March 13, 2017. Respectfully
Page 37 and 38: Case: 12-14679 Date Filed: 12/17/20
Page 39: R.A. 4 Case: 12-14679 Date Filed: 0
Page 43 and 44: PA R Case: 12-14679 Date Filed: 01/
Page 45 and 46: D A 1 A Case: 12-14679 Date Filed:
Page 53 and 54: Qase: 15-11914 IDAte [CASE: 15-1191
Page 55 and 56: 'RES UNITED STATES 1 POSTAL SERVICF
Page 57 and 58: The order of the United States Cour
Page 59 and 60: A No IN THE SUPREME COURT OF THE UN
Page 61 and 62: 1) A ')4 Rule 31-2. Briefs and Appe
Page 63 and 64: 0 A 1 4 Rule 42-2. Dismissal in a C
Page 65 and 66: U.S.C. Title 28- JUDICIARY AND JUDI
Page 87: Tampa, FL 33602 Telephone: (813) 28

Bausch and Lomb_Opposition_2_RamirezWritofCert_2017-03-14

Create successful ePaper yourself

Delete template?

Save as template?