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
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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.
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/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
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