ACCEPTED
05-15-01044-CV
FIFTH COURT OF APPEALS
DALLAS, TEXAS
11/13/2015 5:34:25 PM
LISA MATZ
CLERK
No. 05-15-01041-CV
No. 05-15-01042-CV FILED IN
5th COURT OF APPEALS
No. 05-15-01043-CV DALLAS, TEXAS
11/13/2015 5:34:25 PM
No. 05-15-01044-CV LISA MATZ
Clerk
IN THE
FIFTH COURT OF APPEALS
DALLAS, TEXAS
_______________________________________________________________________
IN THE INTEREST OF M.W. AND Z.W., CHILDREN
IN THE INTEREST OF J.Q.W., A CHILD
IN THE INTEREST OF J.W., A CHILD
IN THE INTEREST OF M.B., A CHILD
________________________________________________________________________
On Appeal from the 302ND District Court
Of Dallas County, Texas
Cause No. DF-10-13224-U
Cause No. DF-13-18933-U
Cause No. DF-14-10757-U
Cause No. DF-13-18931-U
_____________________________________________________________________________
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 APPELLANT, Crystal Bowens, who through her attorney of
record, Stephanie L. Pond, requests additional time to file Appellant’s Brief and
requests 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 November 12, 2015.
2. Since the second extension was granted, attorney for Appellant has
had to prepare for and appear at four CPS hearings, three trial settings,
two home visits to visit children, and one child support hearing.
3. Appellant’s attorney did not have time to adequately prepare the brief
in this case.
4. Appellant’s brief was filed today, November 13, 2015, making it one
day late.
5. Attorney for Appellant, Stephanie L. Pond, and Appellant 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 November 13,
2015.
PRAYER
WHEREFORE, Appellant, Crystal Bowens, requests an extension of
time to file brief and requests the Court to accept the brief that has been tendered
Appellant’s Motion for Additional Time – page 3
to the Court.
Respectfully submitted,
Stephanie L. Pond
701 Commerce
Suite 200
Dallas, TX 75202
Tel: 214-752-0229
Facsimile: 214-752-5257
Email: stephaniepond@yahoo.com
/s/ Stephanie L. Pond
By: Stephanie L. Pond
SBN: 24079817
ATTORNEY FOR CRYSTAL BOWENS, APPELLANT
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the above was served on Counsel for
the Appellees and the Guardian ad Litem in accordance with 9.5 of the Texas
Rules of Appellant Procedure in the manner indicated below on November 13,
2015.
VIA EMAIL: Sandre.Moncriffe@dallascounty.org
Assistant District Attorney
SANDRE MONCRIFFE
VIA EMAIL: gworrell@theworrelllawfirm.com
Guardian ad Litem/Attorney ad Litem for the children
GLYNE WORRELL
VIA EMAIL: Charles.Vaughn@dallascounty.org
Attorney for Appellant
CHARLES VAUGHN
/s/ Stephanie L. Pond____
By: Stephanie L. Pond
Appellant’s Motion for Additional Time – page 3