in the Matter of A.F.

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