ACCEPTED
14-15-00709-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
9/18/2015 4:43:33 PM
CHRISTOPHER PRINE
CLERK
NO. 14-15-00709-CV
FILED IN
14th COURT OF APPEALS
IN THE COURT OF APPEALS HOUSTON, TEXAS
FOR THE FOURTEENTH JUDICIAL DISTRICT
9/18/2015 4:43:33 PM
OF TEXAS AT HOUSTON CHRISTOPHER A. PRINE
Clerk
IN THE MATTER OF A.F., Appellant
A.F., Appellant
v.
THE STATE OF TEXAS,
Appellee
On Appeal from the 314th District Court
Harris County, Texas
Trial Court Cause No. 2014-03135J
APPELLANTS UNOPPOSED MOTION FOR EXTENSION OF TIME
TO FILE NOTICE OF APPEAL PURSUANT TO TRAP 26.3
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
A.F., appellant, moves the Court to extend the time to file his notice
of appeal pursuant to TRAP 26.3 and in support thereofrespectfully shows:
1. The final judgment was signed on May 6, 2015 and appellant's
notice of appeal was due on August 4, 2015. It was filed on August 19,
2015.
2. Appellant failed to timely file his notice of appeal due to the
following facts and circumstances:
a. Appellant's counsel was out of the country from July 24, 2015
through August 11, 2015. In the week priorto leaving, he represented the
child at trial in a parental termination case styled: In re: B.C. and numbered
2014-04220J; in the 315th District Court of Harris County, Texas. He also
prepared and filed the appellant's reply briefin an accelerated appeal
numbered 01-15-00258-CV and styled: In re M.M.Y-P., Child.
b. The week after returning counsel prepared and filed on August
17, 2015 the appellant's original brief in appeal no. 01-15-00525-CV; styled:
In re: J.M. He also represented a juvenile respondent adjudicated for the
felony offense of aggravated assault on a family member in a contested
disposition hearing held on August 13, 2015 in no. 2014-02392J; styled: In
the Matter ofD.M.; in the 315th District Court ofHarris County, Texas.
Finally, during that week counsel also appeared in approximately ten district
and county court non-trial setting.
3. Counsel's failure to timely file the notice of appeal was not due to
conscious indifference or neglect but rather was inadvertent due to his
summer vacation and workload. This extension is sought so that the ends of
justice may be served.
WHEREFORE, A.F., appellant, prays that pursuant to TRAP 26.3,
this Honorable Court extend the time to file his notice of appeal to August
19,2015.
Respectfully submitted,
Isi william m thursland
William M. Thursland
TBN: 20016200
440 Louisiana St., Ste. 1130
Houston, TX 77002
Email: wmthursland@hotmail.com
Tel: (713) 655-0200x105;
Fax:(713)655-9035
Attorney for Appellant A.F.
CERTIFICATE OF CONFERENCE
Pursuant to TRAP 10.1(a)(5), I certify that Appellee's counsel, Alan
Curry, is unopposed to this motion.
/s/ william m thursland
William M. Thursland
CERTIFICATE OF SERVICE
I certify that on September 18, 2015 a true and correct copy ofthe
foregoing pleading was served on Alan Curry by fax to (713) 755-5809.
/s/ william m thursland
William M. Thursland