ACCEPTED
05-14-01569-CV
FIFTH COURT OF APPEALS
DALLAS, TEXAS
3/5/2015 4:18:42 PM
LISA MATZ
CLERK
No. 05-14-01569-CV
FILED IN
IN THE 5th COURT OF APPEALS
DALLAS, TEXAS
3/5/2015 4:18:42 PM
FIFTH COURT OF APPEALS LISA MATZ
Clerk
DALLAS, TEXAS
_______________________________________________________________________
IN THE INTEREST OF J.W.C., A CHILD
________________________________________________________________________
On Appeal from the 301st District Court
Of Dallas County, Texas
Cause No. DF-13-17254-T
_____________________________________________________________________________
APPELLANT’S MOTION FOR ADDITIONAL
TIME TO FILE APPELLANT’S BRIEF and
MOTION TO ACCEPT FILED BRIEF
______________________________________________________________________________
TO THE HONORABLE JUSTICES OF SAID COURT:
COMES NOW APPELLANTS, James Cook and Shaunice Cook, who
through their attorney of record, Jim G. Cobb, request additional time to file
Appellant’s Brief and request the Court to accept Appellant’s brief that has been
tendered to the Court.
In support thereof would show:
1. Said Appellant’s brief was due to be filed by February 19, 2015.
2. Attorney for Appellant’s had a death in his family on February 18,
2015 with a rapidly scheduled funeral in Tyler, Texas on February 20,
2015 which he attended. On Monday, February 23, 2015, Appellant
attorney’s law office was closed due to bad weather (ice storm) and was
also closed for part of the day on Tuesday, February 24, 2015 due to
residual ice on the roads.
3. Appellant’s brief was filed on Thursday, February 26, 2015 making it
one week late.
4. Attorney for Appellants, Jim G. Cobb, and Appellants request the
Court to grant an extension of time to file said brief and request the
Court to accept the brief that was tendered to the Court on February 26,
2015.
PRAYER
WHEREFORE, Appellant’s, James Cook and Shaunice Cook, request an
extension of time to file brief and request the Court to accept the brief that has
tendered to the Court.
Respectfully submitted,
Jim G. Cobb
Appellant’s Motion for Additional Time – page 3
LAW OFFICE OF JIM G. COBB
701 Commerce
Suite 200
Dallas, TX 75202
Tel: 214-752-0229
Facsimile: 214-752-5257
Email: adijimboy@aol.com
/S/ Jim G. Cobb____________
By: Jim G. Cobb
SBN: 04443500
ATTORNEY FOR JAMES COOK, APPELLANT
ATTORNEY FOR SHAUNICE COOK, APPELLANT
CERTIFICATE OF CONFERENCE
I hereby certify that I attempted to confer with the counsel for the other
parties regarding whether they opposed the relief requested in this motion by email
on Thursday, March 5, 2015. I also certify that earlier I spoke with Sylvia
Cantu, Assistant District Attorney, and she had no objections. Glyne Worrell
has not responded as of the date of the filed on this motion.
/S/ Jim G. Cobb____________
By: Jim G. Cobb
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the above was served on Counsel for
the Appellee and the Guardian ad Litem in accordance with 9.5 of the Texas Rules
of Appellant Procedure in the manner indicated below on March 5, 2015.
Appellant’s Motion for Additional Time – page 3
VIA FACSIMILE 214-653-6615
AND EMAIL: Sylvia.cantu@dallascounty.org
Assistant District Attorney
SYLVIA A. CANTU
133 N. Riverfront Blvd. #19
Dallas, TX 75207
TEL: 214-698-2285
FAX: 214-653-6615
VIA FACSIMILE 214-540-4945
AND EMAIL: gworrell@theworrelllawfirm.com
Guardian ad Litem/Attorney ad Litem for the child
GLYNE D. WORRELL
4144 N. Central, Suite 230
Dallas, Texas 75204
TEL: 314-540-5950
FAX: 214-540-4945
/S/ Jim G. Cobb____________
By: Jim G. Cobb
Appellant’s Motion for Additional Time – page 3