ACCEPTED
01-15-00571-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
8/19/2015 9:39:24 PM
CHRISTOPHER PRINE
CLERK
N0. 01-15-00571-CV
FILED IN
IN THE COURT OF APPEALS 1st COURT OF APPEALS
HOUSTON, TEXAS
8/19/2015 9:39:24 PM
FOR THE FIRST DISTRICT CHRISTOPHER A. PRINE
Clerk
OF TEXAS AT HOUSTON
IN THE INTEREST OF
A.G. AND F.G., CHILDREN
S.F., APPELLANT
VS.
DEPARTMENT OF FAMILY & PROTECTIVE
SERVICES, APPELLEE
ON APPEAL FROM
THE 313TH DISTRICT COURT OF
HARRIS COUNTY, TEXAS
TRIAL COURT CAUSE NO. 2013-06904J
NOTICE OF APPEARANCE OF APPELLATE COUNSEL AND
APPELLANT’S UNOPPOSED MOTION FOR FIRST
EXTENSION OF TIME TO FILE APPELLANT’S BRIEF
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
COMES NOW DONALD M. CRANE (“appellate counsel”),
appointed attorney ad litem on appeal for Appellant, S.F., respondent
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mother, and hereby files this notice of appearance of appellate counsel
and unopposed motion for first extension of time to file appellant’s
brief, and in support thereof would respectfully show as follows:
I.
Appellant’s parental rights were terminated by a Decree for
Termination signed by the Honorable Glenn H. Devlin, Presiding
Judge, 313th District Court of Harris County, Texas, and entered
June , 2015, Cause No. 2013-06904J, styled “In the Interest
of A.G. and F.G., Children; In the District Court of Harris County, 313th
Judicial District.”
II.
Appellant is presumed indigent and may proceed without
advance payment of costs as provided by Tex. R. App. P. 20.1(a)(3).
See Attached.
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III.
This is an accelerated appeal. Appellant’s brief is due August 24,
2015.
The undersigned is requesting an extension of time up to and
including September 24, 2015, to prepare and file appellant’s brief
citing the undersigned’s desire for additional time to review the record
(and any supplementation) in this appeal.
Appellate counsel was not the attorney of record in the
underlying cause.
Further, appellate counsel would show that good cause exists to
grant the requested extension of time as he also is preparing the
appellant’s brief in Cause No. 01-15-00589-CV; styled: In the Interest
of T.J.C.. II, Child, said brief being due September 3, 2015, absent
request for a first extension. He also is preparing the appellant’s brief
in Cause No. 14-15-00601-CV; styled: In the Interest of N.S., Child,
said brief on first extension and being due September 8, 2015.
Additionally, appellate counsel will be making several
appearances in the district and probate courts of Harris County, Texas
over the next several weeks as well as an appearance in the County
Court at Law, Austin County, Texas on August 25, 2015.
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Finally, this motion to extend time is filed in conformity with
Tex. R. App. P. 10.5.
WHEREFORE, PREMISES CONSIDERED, S.F., Appellant,
prays that the Court take notice that Donald M. Crane has been
appointed her appellate counsel and, further, grant her unopposed
motion for first extension of time to file appellant’s brief up to and
including September 24, 2015, as set forth above. Appellant prays for
general relief.
Respectfully submitted,
/s/ Donald M. Crane
Donald M. Crane
810 South Mason Road, Suite
350
Katy, Texas 77450
Telephone (281) 392-6611
Facsimile (281) 392-5383
State Bar No. 05005900
donmcrane@gmail.com
ATTORNEY AD LITEM ON
APPEAL FOR
APPELLANT S.F.
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CERTIFICATE OF CONFERENCE
This motion is unopposed.
/s/ Donald M. Crane
Donald M. Crane
CERTIFICATE OF SERVICE
I hereby certify that on this 19th day of August, 2015, a true and
correct copy of the foregoing Notice of Appearance of Appellate
Counsel and Unopposed Motion for First Extension of Time to File
Appellant’s Brief was served in accordance with the TRAP.
1. Sandra D. Hachem
Senior Assistant County Attorney
1019 Congress Avenue, 15th Floor
Houston, Texas 77002-1700
(713) 437-4700 fax
/s/ Donald M. Crane
Donald M. Crane
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