ACCEPTED
04-15-00095-CV
FOURTH COURT OF APPEALS
SAN ANTONIO, TEXAS
4/22/2015 9:07:02 PM
KEITH HOTTLE
CLERK
IN THE COURT OF APPEALS
FOURTH COURT OF APPEALS DISTRICT OF TEXAS
FILED IN
4th COURT OF APPEALS
SAN ANTONIO, TEXAS
IN THE INTEREST OF 04/22/2015 9:07:02 PM
KEITH E. HOTTLE
N.B., ET. AL. NO. 04-15-00095-CV Clerk
MINOR CHILD
APPELLANT’S FIRST MOTION TO EXTEND TIME TO FILE
APPELLANT’S BRIEF
TO THE HONORABLE COURT OF APPEALS:
COMES NOW the Appellant, Michael Blevins, and pursuant to TRAP 10.5(b),
respectfully moves the Court to extend the time for filing the Brief of Appellant which
is currently due on April 22, 2015, for twenty (20) days, until May 12, 2015. In
support of said motion, Appellant would show the Court as follows:
I.
This is an appeal in a parental rights termination case. The trial court, Hon.
Charles Montemayor presiding, terminated Appellant’s parental rights on February 9,
2015, in Cause No. 2014 PA 00469, In the Interest of N.B., minor child, docketed into
the 73rd Judicial District Court of Bexar County, Texas. The Order of Termination
was signed on February 9, 2015.
II.
The basis for undersigned counsel’s request(s) is as follows: The basis for
undersigned counsel’s request(s) is as follows: Undersigned counsel had numerous
court settings to appear for last week, including multiple trial settings. The extension
of time is necessary to provide effective assistance of counsel. Said extension is not
sought for purposes of delay. Undersigned counsel assures the court no further
extensions will be requested.
III.
Pursuant to TEX. R. APP. P. 38.6(d), Appellant requests a twenty (20) day
extension to file his brief, until May 12, 2015.
IV.
WHEREFORE, PREMISES CONSIDERED, Appellant prays for an
extension of time for filing the brief of Appellant until May 12, 2015.
Respectfully submitted,
__/s/ James B. Peplinski____
James B. Peplinski
Attorney at Law
15751 Knollbranch
San Antonio, Texas 78247
Phone (210) 416-1129
Fax (210) 829-5432
Email: JPeplinski@satx.rr.com
Bar No. 24010294
Attorney for Appellant,
Michael Blevins
CERTIFICATE OF CONFERENCE
Undersigned counsel does not believe any of the opposing parties are opposed
to the granting of this motion.
___/s/ James B. Peplinski___
James B. Peplinski
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the above and foregoing motion
has been served on all parties in accordance with the Texas Rules of Civil Procedure
on the date it was filed.
___/s/ James B. Peplinski____
James B. Peplinski