ACCEPTED
01-15-00803-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
12/2/2015 4:44:09 PM
CHRISTOPHER PRINE
CLERK
NO. 01-15-00803-CV
__________________________________________________________
FILED IN
1st COURT OF APPEALS
IN THE COURT OF APPEALS HOUSTON, TEXAS
FOR THE FIRST JUDICIAL DISTRICT 12/2/2015 4:44:09 PM
OF TEXAS AT HOUSTON CHRISTOPHER A. PRINE
Clerk
___________________________________________________________
IN THE INTEREST OF A.L.F., D.P.F-A., E.E.F., B.E.H., Jr., and R.F.B.,
CHILDREN
________________________________________________________
B.J.B., Appellant
v.
TEXAS DEPARTMENT OF FAMILY AND PROTECTIVE SERVICES,
Appellee
_________________________________________________________
On Appeal from the 310th District Court
Harris County, Texas
Trial Court Cause No. 2014-01773J
_____________________________________________________________
APPELLANT'S FIRST UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE BRIEF
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
B.J.B., appellant, moves the Court to extend the time to file his brief
to Monday, January 4, 2016 and in support thereof respectfully shows:
1. This is an accelerated appeal. Appellant’s brief is due on
December 2, 2015.
2. Good cause exists to grant this motion. Within the last four and a
half weeks, counsel prepared and filed appellant’s brief in the following
accelerated appeals: No. 14-15-00799-CV; styled: In re J.D.A.; no. 14-15-
00601-CV; styled: In re N.S. and, no. 14-15-00864-CV; styled: In re B.M.S.
Counsel is currently finishing the appellant’s briefs in no. 14-15-00882-CV;
styled: In re K.I.B.C. due on December 5, 2015 and no. 14-15-00904-CV;
styled: In re B.J.C., et al. due on December 14, 2015.
3. In addition, this week trials are scheduled for two parental
termination cases where counsel represents the mother in a case numbered
2014-04419J; styled: In the Interest of R.A., Child in the 313th District Court
and a father in a case numbered 2014-00645J; styled: In the Interest of R.P.,
et al., Children in the 315th District Court.
4. Finally, in the last thirty days counsel has appeared in
approximately 28 district and county court non-trial setting.
5. This extension is not sought for the purposes of delay but rather so
that the ends of justice may be served.
WHEREFORE, B.J.B, appellant, prays that this motion be granted
and that the time to file her brief be extended to Monday, January 4, 2015.
Respectfully submitted,
/s/ 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, B.J.B
CERTIFICATE OF CONFERENCE
Pursuant to TRAP 10.1(a)(5), I certify that appellee’s counsel, R.J.
Hazeltine-Shedd, is unopposed to this motion.
/s/ william m thursland
______________________
William M. Thursland
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the foregoing pleading was
served on R.J. Hazeltine-Shedd, appellee counsel, Donald Crane, counsel for
appellant father and Juli Crow, counsel for appellant mother, by electronic
delivery on December 2, 2015.
/s/ william m thursland
________________________
William M. Thursland