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