ACCEPTED
01-15-00714-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
10/26/2015 9:37:54 PM
CHRISTOPHER PRINE
CLERK
CAUSE NO. 01-15-00714-CV
____________________________________________________________
FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS
IN THE COURT OF APPEALS 10/26/2015 9:37:54 PM
FOR THE FIRST DISTRICT OF TEXAS CHRISTOPHER A. PRINE
_____________________________________________________________
Clerk
IN THE INTEREST OF S.R.H., A CHILD
_______________________________________________ ______________
From the 315th Judicial District Court of Harris County, Texas
Cause No. 2013-04271J
MOTION FOR EXTENSION TO FILE APPELLANT’S BRIEF
1. This is an accelerated appeal in a parental termination case.
2. Appellant’s brief was due in this case on September 28th because the record was
filed on September 8, 2015.
3. On October 15, 2015, the Clerk notified the undersigned counsel that either a
brief or a motion for extension of time to file the brief had to be filed within ten
days after this notice. The due date would then be October 25 th, but the
undersigned counsel calculates that because October 25th was a Sunday, counsel
had until midnight of October 26th to file her motion for extension. Counsel has
filed a motion for extension pursuant to that calculation.
4. The Court issued an order on October 26th received by the undersigned counsel
at approximately 5:27 p.m. which stated that counsel must file appellant’s brief
by November 3, 2105.
5. Counsel respectfully requests that she be granted an extension until November
23rd. Counsel must have this time in order to communicate with her client and
his trial counsel. Trial counsel has expressed an interest to be involved in the
appeal and the undersigned counsel was out of town on vacation for two weeks
in October. This vacation had been scheduled for approximately four months.
Counsel also has her taxes due on November 2 nd (there is an extension this year
because of the flooding), and she is getting ready for trial, and has other work
obligations.
6. Therefore, counsel respectfully requests that the Court allow her an extension of
time to file appellant’s brief until November 23rd.
Respectfully submitted,
/s/ Lana Shadwick
Lana Shadwick
State Bar No. 00784951
12535 Kingsride, Ste. 313
Houston, Texas 77024
Telephone: (713) 392-8222
Lana@LanaShadwick.com
CERTIFICATE OF CONFERENCE
Appellant has notified opposing counsel and there is no opposition to this
motion.
/s/ Lana Shadwick
CERTIFICATE OF SERVICE
The undersigned hereby certifies that a true and correct copy of the foregoing
instrument was forwarded to Asst. Harris County Attorney Sandra Hachem on the
26th day of October, 2015 by electronic mail.
/s/ Lana Shadwick