in the Interest of M.M.-Y.P.

ACCEPTED 01-15-00258-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 7/17/2015 4:00:34 PM CHRISTOPHER PRINE CLERK NO. 01-15-00258-CV FILED IN 1st COURT OF APPEALS IN THE COURT OF APPEALS HOUSTON, TEXAS FOR THE FIRST JUDICIAL DISTRICT 7/17/2015 4:00:34 PM OF TEXAS AT HOUSTON CHRISTOPHER A. PRINE Clerk IN THE INTEREST OF M.M-Y.P., CHILD S.L.R., Appellant v. TEXAS DEPARTMENT OF FAMILY AND PROTECTIVE SERVICES, Appellee On Appeal from the 314th District Court Harris County, Texas Trial Court Cause No. 2014-00702J APPELLANT'S UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE REPLY BRIEF TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS: S.L.R, appellant, moves the Court to extend the time to file her reply brief to Monday, July 20, 2015 and in support thereof respectfully shows: 1. In an order dated July 9, 2015, the Court requested that appellant file a reply brief to address whether her motion for new trial should be treated as a judicial admission regarding her interest in terminating her parental rights. Appellant was given until Friday, July 17, 2015 to file her reply brief. 2. Good cause exists to grant this motion. Within the last ten days appellant's counsel represented the mother in the trial ofacase involving the termination ofparental rights in cause no. 2014-00610-CV; styled: In re J.G., et al, in the 313th District Court and prepared for atrial scheduled for July 16, 2015 where he represents the respondent charged with the first degree felony offense of aggravated sexual assault in cause no. 2013-00545- CV; styled: In the Matter ofD. W.\ in the 315th District Court. In addition, on July 16, 2015, he was appointed to as the attorney ad litem for the children who are placed in foster care in cause no. 2015-04311J; styled: In re X.H., etal, inthe 315th District Court. He is scheduled to visit the children on Friday, July 17, 2015. 3. This extension is not sought for the purposes of delay but rather so that the ends ofjustice may be served. WHEREFORE, S.L.R., appellant, prays that this motion be granted and that the time to file her reply brief be extended to Monday, July 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, S.L.R. 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 July 17,2015. Isi william m thursland William M. Thursland