in the Interest of D.L.T., D.L., D.L., T.L., D.W. AKA D.T.W., D.W., Children v. Department of Family and Protective Services ( 2015 )

ACCEPTED
01-15-00845-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
11/23/2015 4:53:09 PM
CHRISTOPHER PRINE
CLERK
N0. 01-15-00845-CV
FILED IN
IN THE COURT OF APPEALS 1st COURT OF APPEALS
HOUSTON, TEXAS
11/23/2015 4:53:09 PM
FOR THE FIRST DISTRICT CHRISTOPHER A. PRINE
Clerk
OF TEXAS AT HOUSTON
IN THE INTEREST OF
D.L.T., D.L., D.L., T.L., D.W. aka D.T.W., D.W., CHILDREN
P.L.W., APPELLANT
VS.
DEPARTMENT OF FAMILY & PROTECTIVE
SERVICES, APPELLEE
ON APPEAL FROM
THE 314TH DISTRICT COURT OF
HARRIS COUNTY, TEXAS
TRIAL COURT CAUSE NO. 2014-03436J
APPELLANT’S UNOPPOSED MOTION FOR FIRST
EXTENSION OF TIME TO FILE APPELLANT’S BRIEF
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
COMES NOW DONALD M. CRANE (“appellate counsel”),
appointed attorney ad litem on appeal for Appellant, P.L.W.,
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respondent mother, and hereby files this unopposed motion for first
extension of time to file appellant’s brief, and in support thereof would
respectfully show as follows:
I.
Appellant’s parental rights were terminated by a Decree for
Termination signed by the Honorable John F. Phillips, Presiding
Judge, 314th District Court of Harris County, Texas, and entered
September 21, 2015, Cause No. 2014-03436J, styled “In the Interest of
D.L.T., D.L., D.L., T.L., D.W. aka D.T.W., Children; In the District
Court of Harris County, 314th Judicial District.”
II.
Appellant is presumed indigent and may proceed without
advance payment of costs as provided by Tex. R. App. P. 20.1(a)(3).
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III.
This is an accelerated appeal. Appellant’s brief is due November
23, 2015.
The undersigned is requesting an extension of time up to and
including December 29, 2015, to prepare and file appellant’s brief citing
the undersigned’s desire for additional time to review the record (and
any supplementation) in this appeal.
Appellate counsel would show that good cause exists to grant the
requested extension of time as he also is preparing the appellant’s brief
in Cause No. 01-15-00886-CV; styled: In the Interest of B.J., Jr., B.J.,
D.L., D.L., Children, said brief being due November 30, 2015, absent
request for a first extension. Further, Appellate counsel also is
preparing the appellant’s brief in Cause No. 01-15-00862-CV, styled:
In the Interest of T.T.T., T.D.T., Jr., T.T., K.W., K.T., Children, said
brief being due December 2, 2015, absent request for a first extension,
as well as the appellant’s brief in Cause No. 01-15-00885-CV, styled:
In the Interest of J.A.O., Child, said brief also being due December 2,
2015, absent request for a first extension.
Additionally, appellate counsel will be making several
appearances in the district courts of Harris County, Texas and a single
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appearance Monday, November 14 2015, in County Court Number
Two, Brazoria County, Texas, on a probate matter.
Finally, this motion to extend time is filed in conformity with Tex.
R. App. P. 10.5.
WHEREFORE, PREMISES CONSIDERED, P.L.W., Appellant,
prays that the Court grant her unopposed motion for first extension of
time to file appellant’s brief up to and including December 29, 2015, as
set forth above. Appellant prays for general relief.
Respectfully submitted,
/s/ Donald M. Crane
Donald M. Crane
810 South Mason Road, Suite
350
Katy, Texas 77450
Telephone (281) 392-6611
Facsimile (281) 392-5383
State Bar No. 05005900
donmcrane@gmail.com
ATTORNEY AD LITEM ON
APPEAL FOR
APPELLANT P.L.W.
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CERTIFICATE OF CONFERENCE
This motion is unopposed.
/s/ Donald M. Crane
Donald M. Crane
CERTIFICATE OF SERVICE
I hereby certify that on this 23rd day of November, 2015, a true
and correct copy of the foregoing Appellant’s Unopposed Motion for
First Extension of Time to File Appellant’s Brief was served in
accordance with the TRAP.
1. Dan-Phi V. Nguyen
Assistant County Attorney
1019 Congress Avenue, 15th Floor
Houston, Texas 77002-1700
(713) 437-4700 fax
2. Juliane (Juli) Crow
P.O. Box 10152
Houston, Texas 77206
(713) 422-2389 fax
3. Gary Polland
2211 Norfolk, Suite 920
Houston, Texas 77098
(713) 622-6334 fax
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4. John R. Millard
1 Sugar Creek Center Boulevard, Suite 925
Sugar Land, Texas 77478
1-888-501-6580 fax
5. Douglas Ray York
3355 West Alabama Street, Suite 100
Houston, Texas 77098-1863
(713) 586-5585 fax
6. JB Lee Bobbitt
1533 West Alabama Street, Suite 100
Houston, Texas 77006
(281) 476-7816 fax
7. Michael Francis Craig
1533 West Alabama Street, Suite 100
Houston, Texas 77006
(713) 526-3787 fax
/s/ Donald M. Crane
Donald M. Crane
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