ACCEPTED
14-14-00984-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
1/23/2015 11:07:21 AM
CHRISTOPHER PRINE
CLERK
No. 14-14-00984-CV
FILED IN
14th COURT OF APPEALS
IN THE COURT OF APPEALS HOUSTON, TEXAS
FOR THE FOURTEENTH JUDICIAL DISTRICT
1/23/2015 11:07:21 AM
OF TEXAS AT HOUSTON CHRISTOPHER A. PRINE
Clerk
IN THE INTEREST OF R.N.Y., Child
L.T.L.Y., Appellant
v.
TEXAS DEPARTMENT OF FAMILY AND PROTECTIVE SERVICES,
Appellee
OnAppeal from the 314th District Court
Harris County, Texas
Trial Court Cause No. 2013-06634J
APPELLANT'S FIRST UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE TARDY BRIEF
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
L.T.L.Y., appellant, files her first unopposed motion for extension of
time to file her tardy brief to February 20, 2015 and in support thereof
respectfully shows:
1. This is an accelerated appeal and appellant's brief was due on
January 19, 2015. The decree terminating appellant's parental rights was
signed on January 5, 2015.
2. Good cause exists to grant this motion. Appellant was found to be
indigent and counsel was appointed to represent her in the trial court
proceedings. The undersigned attorney was appointed to represent her on
appeal on January 8, 2015.
3. On January 22, 2015 counsel spoke with Rene, an assistant clerk of
the Court of Appeals, and learned for the first time that appellant filed a
premature pro se notice of appeal on December 11, 2014.
Contemporaneously with the filing of this motion counsel is filing an
amended notice of appeal with the order appointing appellate counsel
attached.
4. This extension is not sought for the purposes of delay but rather so
that the ends ofjustice may be served.
WHEREFORE, L.T.L.Y., appellant, prays that this motion be granted
and that the time to file her brief be extended to Friday, February 20, 2015.
Respectfully submitted,
Isi william m thursland
William M. Thursland
TBN: 20016200
440 Louisiana St., Ste. 1130
Houston, TX 77002
Email: wmthursland@hotmail.com
(713) 655-0200 x 105; Fax: (713) 655-9035
Attorney for Appellant, L.T.L.Y.
CERTIFICATE OF CONFERENCE
Pursuant to TRAP 10.1(a)(5), I certify that appellee's counsel, Sandra
D. Hachem, is unopposed to this motion.
Isi william m thursland
William M. Thursland
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the foregoing pleading was
served on Sandra D. Hachem by electronic delivery or by fax to: (713) 437-
4700 on January 23, 2015.
Isi william m thursland
William M. Thursland
WILLIAM M. THURSLAND
Attorney At Law
440 Louisiana St., Ste. 1130
Houston, TX 77002
Tel: (713) 655-0200 x 105 Fax: (713) 655-9035
January 23, 2015
Ms. Phyllis Washington, Deputy Clerk
Civil Post-Judgment
201 Caroline, Ste. 250
Houston, TX 77002
Re: No. 2013-06634J; In the Interest ofR.N.Y., 314th District
Clerk; COA no.: 14-14-00984-CV
Dear Ms. Washington:
Please find enclosed the Amended Notice of Appeal with the
attached Order Appointing Appellate Counsel and Confirming that
Respondent is Indigent in the referenced case. Pursuant to TRAP 34.5(b)
& (c), I request that you supplement the clerk's record by filing both the
notice and order with the Court of Appeals.
Thanks you for your attention & co-operation in this matter.
Sincerely,
/s/ william m thursland
William M. Thursland
WMT:aa
Encl.
cc: Sandra D. Hachem
Clerk, 14th Ct. of Appeals