in Re Shayna (Deboise) Herring ( 2015 )


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  •                                                                                                              ACCEPTED
    01-14-00989-CV
    FIRST COURT OF APPEALS
    HOUSTON, TEXAS
    1/9/2015 11:30:41 AM
    CHRISTOPHER PRINE
    CLERK
    CASE NO: 01-14-00989-CV
    IN THEFIRST COURT OF APPEALS
    FILED IN
    1st COURT OF APPEALS
    AT HOUSTON                             HOUSTON, TEXAS
    1/9/2015 11:30:41 AM
    CHRISTOPHER A. PRINE
    Clerk
    IN RE SHAYNA (DEBOISE) HERRING
    Relator
    From the 247th District Court
    Harris County, Texas
    REAL PARTY IN INTEREST UNOPPOSED MOTION FOR EXTENSION OF TIME TO
    FILE BRIEF IN RESPONSE TO PETITION FOR WRIT OF HABEAS CORPUS
    TO THE HONORABLE JUSTICES OF THE FIRST COURT OF APPEALS:
    Real Party in Interest’s Counsel respectfully requests that the Court grant this Motion for
    Extension of Time established by Rule 10.5 and Rule 38.6 of the Texas Rules of Appellate
    Procedure.
    I.
    Real Party in Interest’s deadline for filing their Reply is January 31, 2015. Real Party in
    Interest respectfully requests an extension of time to file their brief for an additional thirty (30)
    days pursuant to Rule 10.5 and Rule 38.6 of the Texas Rules of Appellate Procedure.
    II.
    Real Party in Interests received the Notice of Reply on or around December 29, 2014.
    Further, Relator has not been taken into the custody of the Harris County Sheriff’s Department
    and is not currently incarcerated. Therefore, the urgency to have this matter heard by Relator is
    somewhat diminished as she is not incarcerated. Real Party in Interest requests this Court to
    extend the reply deadline. This request is unopposed.
    III.
    There has been no extensions granted to extend the time to file Real Party in Interest’s
    Reply.
    IV.
    Pursuant to Texas Rules of Appellate Procedure 10.1(a)(5) Real Party in Interest’s
    counsel contacted Relator’s counsel and Relator’s counsel was not opposed to this motion.
    V. CONCLUSION
    For the reasons stated above, Real Party in Interest respectfully requests that this Motion
    for Extension of Time be granted so that Real Party in Interest has an adequate opportunity to
    respond to the Writ of Habeas Corpus.
    Respectfully Submitted,
    THE LAW OFFICE OF TERISA TAYLOR, P.C.
    917 Franklin Street, Suite 510
    Houston, Texas 77002
    Tel: (713) 224-9900
    Fax: (713) 224-9903
    By:______________________________________
    TERISA TAYLOR
    SBN: 24000240
    GRACE M. CRUMP
    SBN: 24083482
    Attorneys for CASTON LEE DEBOISE
    CERTIFICATE OF CONFERENCE
    As required by the Texas Rules of Appellate Procedure 10.1(a)(5), I certify that on January 9,
    2015, I have conferred, or made a reasonable attempt to confer, with all other parties – which are
    listed below – about the merits of this motion and George Dana does not oppose this Motion.
    ____________________________________
    TERISA TAYLOR
    GRACE M. CRUMP
    CERTIFICATE OF SERVICE
    Pursuant to Texas Rules of Appellate Procedure 9.5(d), (e), this is to certify that a copy of this
    motion was served on Shayna (DeBoise) Herring, by and through her attorney of record, George
    Dana on January 9, 2015, by faxing a copy to George Dana at (281) 484-9687 and by efiling in
    the 247th Judicial District Court, Harris County, Texas.
    ____________________________________
    TERISA TAYLOR
    GRACE M. CRUMP
    

Document Info

Docket Number: 01-14-00989-CV

Filed Date: 1/9/2015

Precedential Status: Precedential

Modified Date: 9/28/2016