ACCEPTED
01-15-00932-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
12/4/2015 3:46:55 PM
CHRISTOPHER PRINE
CLERK
NO. 01-15-00931-CV
NO. 01-15-00932-CV
NO. 01-15-00933-CV FILED IN
1st COURT OF APPEALS
__________________________________________________________
HOUSTON, TEXAS
12/4/2015 3:46:55 PM
IN THE COURT OF APPEALS CHRISTOPHER A. PRINE
FOR THE FIRST JUDICIAL DISTRICT Clerk
OF TEXAS AT HOUSTON
___________________________________________________________
IN THE MATTER OF A.C., Appellant
___________________________________________________________
A.C., Appellant
v.
THE STATE OF TEXAS,
Appellee
_________________________________________________________
On Appeal from the 315th District Court
Harris County, Texas
Tr. Ct. Cause Nos. 2015-01921J, 2015-02194J & 2015-02097J
_________________________________________________________
APPELLANT’S FIRST UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE BRIEF
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
A.C., appellant, moves the Court to extend the time to file his brief be
extended to Thursday, December 31, 2015 and in support thereof
respectfully shows:
1. This is an accelerated appeal. Appellant’s brief was due on
December 3, 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 were 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, A.C., appellant, prays that this Honorable Court
extend the time to file his brief to December 31, 2015.
Respectfully submitted,
/s/ william m thursland
_____________________
William M. Thursland
TBN: 20016200
440 Louisiana St., Ste. 1130
Houston, TX 77002
Email: wmthursland@hotmail.com
Tel.: (713) 655-0200 x 105;
Fax: (713) 655-9035
Attorney for Appellant A.C.
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 December 4, 2015 a true and correct copy of the
foregoing pleading was served appellee’s counsel, the Harris County District
Attorney’s Office, by fax to (713) 755-5809.
/s/ william m thursland
________________________
William M. Thursland