in the Interest of I. S. v. Department of Family and Protective Services

ACCEPTED 01-15-00136-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 5/22/2015 10:55:52 AM CHRISTOPHER PRINE CLERK No. 01-15-00136-CV In the Courts of Appeals for the First District of Texas at Houston, Texas ___________________________________ FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS In the Interest of I.S. 5/22/2015 10:55:52 AM ----------------------------------- CHRISTOPHER A. PRINE Clerk T.S., Appellant v. DEPARTMENT OF FAMILY & PROTECTIVE SERVICES, Appellee ___________________________________ On appeal from the Harris County District Court 315th Judicial District; No. 2014-00465J ____________________________________  WAIVER OF OPPORTUNITY TO RESPOND TO APPELLANT’S ANDERS BRIEF  TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS: Comes now the Department of Family & Protective Services (hereinafter “Department”), by the undersigned assistant county attorney, and respectfully waives the opportunity to file a brief in response to the Anders brief filed by counsel for Appellant. The Department would respectfully show the Court the following: I. In keeping with the requirements of Anders v. California, 386 U.S. 738, 87 S.Ct. 1396 (1967), which this court held was applicable to parental termination cases, counsel for the appellant has filed a brief containing the conclusion that there is no arguable grounds for appeal and indicates that this appeal is frivolous. The electronic website for this court indicates a letter was sent by this court on April 27, 2015 advising Appellant that an Anders Brief was filed by his attorney and that Appellant could file a response by May 26, 2015. II. Review of the appellant’s brief reveals no question of constitutional dimension or other issue requiring review in the interest of justice. THEREFORE, the DFPS waives the opportunity to file a response to the Anders brief filed by the attorney for appellant and moves the Court to affirm the trial court’s judgment. Respectfully submitted, VINCE RYAN COUNTY ATTORNEY By: /s/ Sandra Hachem Sandra D. Hachem Sr. Assistant County Attorney State Bar #08667060 1019 Congress, 17th Floor Houston, Texas 77002 Phone: 713/274-5293 Fax: 713/437-4700 Email: sandra.hachem@cao.hctx.net Attorney for Appellee, Department of Family & Protective Services CERTIFICATE OF SERVICE I hereby certify that on this the 22nd day of May a true and correct copy of the foregoing document was sent to all parties to this appeal by sending a copy of this document by electronic transmission to Appellant, T.S., by and through her attorney of record, Stephen Pierce, at his email address of spiercelaw@gmail.com and a copy was also sent to the attorney ad litem for the Child, Valeria Brock, at valeria.lee.brock@gmail.com. /s/ Sandra Hachem Sandra D. Hachem