in the Interest of C. D. v. Department of Family and Protective Services

ACCEPTED 01-15-00713-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 10/5/2015 4:49:46 PM CHRISTOPHER PRINE CLERK NO. 01-15-00713-CV ______________________________________ FILED IN 1st COURT OF APPEALS In the Court of Appeals for the HOUSTON, TEXAS First District of Texas at Houston, Texas 10/5/2015 4:49:46 PM CHRISTOPHER A. PRINE ___________________________________________ Clerk IN THE MATTER OF C.D., A CHILD ____________________________________________ On appeal from the 315th District Court of Harris County, Texas, No. 2014-03650J APPELLANT’S FIRST MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF _____________________________________________________________ TO THE HONORABLE COURT OF APPEALS: Octavia Jackson, appellant, files this First Motion for Extension of Time to file Appellant’s Brief and shows the following: 1. Nature of Proceeding This appeal arises out of a proceeding in the District Court for the 315th Judicial District, Harris County, entitled In the Interest of: C.D., A Child and numbered 2014-03650J. 2. Deadline for Filing Appellant’s Brief. The deadline for filing Appellant's Brief was September 24, 2015. 3. Length of Extension Sought. The length of extension sought for filing Appellant's Brief is 12 days. 4. Facts Relied Upon to Explain Need for Extension. Appellant requires additional time to file Appellant’s brief due to counsel’s busy trial court schedule and delayed notice of appointment to this 1 case as Appellate Counsel. As a result counsel has been unable to complete Appellant’s brief in the last 30 days. At the time of the filing of this motion, Counsel for Appellant also filed an Ander’s Brief in this case. 5. Number of Previous Extensions Granted. There have been no previous extensions granted in this case. 6. Prayer WHEREFORE, appellant requests that this Court grant appellant's motion, extending time for filing the Notice of Appeal by 12 days. Respectfully submitted, /s/Stephen M. Pierce STEPHEN M. PIERCE SBN: 24062192 909 Texas, #402 Houston, Texas 77002 (832) 463-0224 FAX (832) 201-9668 Attorney for Appellant CERTIFICATE OF CONFERENCE I, Stephen M. Pierce, hereby certify that on December 4, 2013 I contacted Sandra Hachem of the Harris County Attorney’s Office regarding this Motion to Substitute Counsel and she indicated she was unopposed to the motion. 2 /s/Stephen M. Pierce STEPHEN M. PIERCE CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing motion has been served on all counsel of record, on October 5, 2015. /s/Stephen M. Pierce STEPHEN M. PIERCE 3