ACCEPTED
01-15-00613-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
8/17/2015 7:10:10 PM
CHRISTOPHER PRINE
CLERK
N0. 01-15-00613-CV
FILED IN
IN THE COURT OF APPEALS 1st COURT OF APPEALS
HOUSTON, TEXAS
8/17/2015 7:10:10 PM
FOR THE FIRST DISTRICT CHRISTOPHER A. PRINE
Clerk
OF TEXAS AT HOUSTON
IN THE INTEREST OF
M.C.M., AKA B.G.M., CHILD
M.M., APPELLANT
VS.
DEPARTMENT OF FAMILY & PROTECTIVE
SERVICES, APPELLEE
ON APPEAL FROM
THE 314TH DISTRICT COURT OF
HARRIS COUNTY, TEXAS
TRIAL COURT CAUSE NO. 2014-03160J
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, M.M., 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 John F. Phillips, Presiding
Judge, 314th District Court of Harris County, Texas, and entered June
30, 2015, Cause No. 2014-03160J, styled “In the Interest of M.C.M.,
aka B.G.M., Child; In the District Court of Harris County, 314th
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).
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III.
This is an accelerated appeal. Appellant’s brief is due August 17,
2015.
The undersigned is requesting an extension of time up to and
including September 16, 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. 01-15-00571-CV; styled: In the Interest
of A.G. and F.G., Children, said brief being due August 24, 2015, absent
request for a first extension.
Additionally, appellate counsel will be making several
appearances in the district and probate courts of Harris County, Texas
over the next several weeks.
Finally, this motion to extend time is filed in conformity with
Tex. R. App. P. 10.5.
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WHEREFORE, PREMISES CONSIDERED, M.M., 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 16, 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 M.M.
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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 17th 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. Marc A. Ritter
Assistant County Attorney
1019 Congress Avenue, 15th Floor
Houston, Texas 77002-1700
(713) 437-4700 fax
2. Daryl Longworth
1385 FM 359, Suite 308
Richmond, Texas 77406
(832) 363-1230 fax
3. John R. Millard
1 Sugar Creek Center Boulevard, Suite 925
Sugar Land, Texas 77478
(888) 501-6580 fax
4. Kevin H. George
440 Louisiana Street, Suite 1130
Houston, Texas 77002
(000) 000-0000 fax
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5. Julia Rangel, CSR
Texas CSR 6412
Official Court Reporter
314th District Court
1200 Congress, 5th Floor
Houston, Texas 77002
(000) 000-0000 fax
/s/ Donald M. Crane
Donald M. Crane
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in the Interest of M. C. M. AKA, Baby Girl M.
Combined Opinion