ACCEPTED
05-14-00662-CV 05-14-00662-CV
FIFTH COURT OF APPEALS
DALLAS, TEXAS
9/3/2015 2:43:11 PM
No. 15-
LISA MATZ
CLERK
__________________________________
FILED IN
IN THE 5th COURT OF APPEALS
SUPREME COURT OF TEXAS DALLAS, TEXAS
9/3/2015 2:43:11 PM
_________________________________
LISA MATZ
Clerk
IN THE INTEREST OF M.I.M., A CHILD
The Office of the Attorney General of Texas,
Petitioner,
V.
Brent Duane Blackmore,
Respondent.
On Petition for Review from the
Fifth Court of Appeals, Dallas, Texas
Cause No. 05-14-00662-CV
MOTION FOR EXTENSION
OF TIME TO FILE
PETITION FOR REVIEW
TO THE HONORABLE SUPREME COURT OF TEXAS:
Petitioner, the Office of the Attorney General of Texas, respectfully files this motion
for an extension of time to file a petition for review.
A. The deadline for the Attorney General’s petition for review is September 8, 2015.
B. The Attorney General requests an extension of 30 days to file the petition for review,
so that it will be due on October 8, 2015.
C. The following facts justify an extension:
The undesigned Assistant Attorney General has been assigned to this matter as lead
counsel since its inception in the appellate courts for the first appeal in 2010. The
undersigned Assistant Attorney General has been out of the office due to personal illness and
unable to complete the petition. The undersigned Assistant Attorney General’s knowledge
of this case makes it essential that she personally prepare the petition for review. This
extension is not sought for delay, but rather to give the petitioner’s preferred attorney
sufficient time to complete the petition.
D. No extensions have been granted for the filing of a petition for review in this case.
II.
Certificate of Conference
The undersigned counsel has conferred with Lilia Morales, interested party and she
is not opposed to this motion. The undersigned counsel attempted to confer with Brent
Blackmore via telephone on September 2, 2015. A voice message was left stating the
purpose of the call and asking for a return call or message. To date, Mr. Blackmore has not
responded.
III.
Prayer for Relief
For these reasons, the Office of the Attorney General requests that the Court grant a
30-day extension to file a petition for review in this case, so that it will be due on October
8, 2015.
Respectfully submitted,
KEN PAXTON
ATTORNEY GENERAL OF TEXAS
CHARLES ROY
FIRST ASSISTANT ATTORNEY GENERAL
MARA FRIESEN
DEPUTY ATTORNEY GENERAL FOR
CHILD SUPPORT
TITLE IV-D DIRECTOR
/s/ Rande K. Herrell
RANDE K. HERRELL
State Bar No. 09529400
MANAGING ATTORNEY
APPELLATE LITIGATION SECTION
CHILD SUPPORT DIVISION
JOHN B. WORLEY
Assistant Attorney General
State Bar No. 22001480
DETERREAN GAMBLE
Assistant Attorney General
State Bar No. 24062194
Child Support Division
Appellate Litigation Section
Mail Code 038-1
P.O. Box 12017, Capitol Sta.
Austin, Texas 78711-2017
Phone: (512) 406-2306
Fax: (512) 460-6612
E-Mail: rande.herrell@texasattorneygeneral.gov
ATTORNEYS FOR PETITIONER, THE
OFFICE OF THE ATTORNEY GENERAL OF
TEXAS
CERTIFICATE OF SERVICE
I certify that a copy of this motion is being served in the manner indicated on the
parties or their counsel listed below on September 3, 2015.
/s/ Rande K. Herrell
Rande K. Herrell
Assistant Attorney General
Brent Duaine Blackmore
801 Ingleside Dr.
Plano, Texas 75075
brentblackmore@aol.com
Respondent, pro se
Lilia Noemi Morales
Guatemala
lily07302003@yahoo.com
Interested Party