Case Information
*0 FILED IN 5th COURT OF APPEALS DALLAS, TEXAS 3/5/2015 4:18:42 PM LISA MATZ Clerk *1 ACCEPTED 05-14-01569-CV FIFTH COURT OF APPEALS DALLAS, TEXAS 3/5/2015 4:18:42 PM LISA MATZ CLERK No. 05-14-01569-CV IN THE FIFTH COURT OF APPEALS DALLAS, TEXAS _______________________________________________________________________
IN THE INTEREST OF J.W.C., A CHILD ________________________________________________________________________
On Appeal from the 301 st District Court Of Dallas County, Texas Cause No. DF-13-17254-T _____________________________________________________________________________
APPELLANT’S MOTION FOR ADDITIONAL
TIME TO FILE APPELLANT’S BRIEF and
MOTION TO ACCEPT FILED BRIEF
______________________________________________________________________________
TO THE HONORABLE JUSTICES OF SAID COURT:
COMES NOW APPELLANTS, James Cook and Shaunice Cook, who
through their attorney of record, Jim G. Cobb, request additional time to file
Appellant’s Brief and request the Court to accept Appellant’s brief that has been
tendered to the Court.
In support thereof would show:
1. Said Appellant’s brief was due to be filed by February 19, 2015.
2. Attorney for Appellant’s had a death in his family on February 18,
2015 with a rapidly scheduled funeral in Tyler, Texas on February 20,
2015 which he attended. On Monday, February 23, 2015, Appellant
attorney’s law office was closed due to bad weather (ice storm) and was
also closed for part of the day on Tuesday, February 24, 2015 due to
residual ice on the roads.
3. Appellant’s brief was filed on Thursday, February 26, 2015 making it
one week late.
4. Attorney for Appellants, Jim G. Cobb, and Appellants request the
Court to grant an extension of time to file said brief and request the
Court to accept the brief that was tendered to the Court on February 26,
2015.
PRAYER
WHEREFORE, Appellant’s, James Cook and Shaunice Cook, request an
extension of time to file brief and request the Court to accept the brief that has
tendered to the Court.
Respectfully submitted, Jim G. Cobb *3 LAW OFFICE OF JIM G. COBB 701 Commerce Suite 200 Dallas, TX 75202 Tel: 214-752-0229 Facsimile: 214-752-5257 Email: adijimboy@aol.com /S/ Jim G. Cobb____________ By: Jim G. Cobb
SBN: 04443500 ATTORNEY FOR JAMES COOK, APPELLANT ATTORNEY FOR SHAUNICE COOK, APPELLANT
CERTIFICATE OF CONFERENCE I hereby certify that I attempted to confer with the counsel for the other
parties regarding whether they opposed the relief requested in this motion by email
on Thursday, March 5, 2015. I also certify that earlier I spoke with Sylvia
Cantu, Assistant District Attorney, and she had no objections. Glyne Worrell
has not responded as of the date of the filed on this motion.
/S/ Jim G. Cobb____________ By: Jim G. Cobb CERTIFICATE OF SERVICE I certify that a true and correct copy of the above was served on Counsel for
the Appellee and the Guardian ad Litem in accordance with 9.5 of the Texas Rules
of Appellant Procedure in the manner indicated below on March 5, 2015.
VIA FACSIMILE 214-653-6615
AND EMAIL: Sylvia.cantu@dallascounty.org Assistant District Attorney
SYLVIA A. CANTU
133 N. Riverfront Blvd. #19
Dallas, TX 75207
TEL: 214-698-2285
FAX: 214-653-6615
VIA FACSIMILE 214-540-4945
AND EMAIL: gworrell@theworrelllawfirm.com Guardian ad Litem/Attorney ad Litem for the child
GLYNE D. WORRELL
4144 N. Central, Suite 230
Dallas, Texas 75204
TEL: 314-540-5950
FAX: 214-540-4945
/S/ Jim G. Cobb____________ By: Jim G. Cobb