Case Information
*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 4/21/2015 12:43:10 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00258-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 4/21/2015 12:43:10 PM CHRISTOPHER PRINE CLERK NO. 01-15-00258-CV
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IN THE COURT OF APPEALS
FOR THE FIRST JUDICIAL DISTRICT
OF TEXAS AT HOUSTON
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IN THE INTEREST OF M.M-Y.P., CHILD
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S.L.R., Appellant v.
TEXAS DEPARTMENT OF FAMILY AND PROTECTIVE SERVICES,
Appellee
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On Appeal from the 314 th District Court
Harris County, Texas Trial Court Cause No. 2014-00702J
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APPELLANT'S FIRST UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE BRIEF
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
S.L.R, appellant, moves the Court to extend the time to file her brief
to Monday, May 18, 2015 and in support thereof respectfully shows:
1. This is an accelerated appeal and appellant's brief is due on April
21, 2015. The decree terminating her parental rights was signed on February
24, 2015.
2. Good cause exists to grant this motion. Within the last twenty days
appellant’s counsel prepared and filed original briefs in the following
accelerated appeals: No. 14-14-1030-CV; styled: In re A.L.H .; and no. 14-
15-00094-CV; styled: In re I.M.G. Counsel is also finishing appellant’s
original brief in another accelerated appeal numbered 14-15-00205-CV;
styled: In re: L.E.R , which is due tomorrow.
3. In addition, within the same time period, counsel prepared for and
tried five cases involving the termination of parental rights and appeared in
approximately 25 non-trial setting.
4. This extension is not sought for the purposes of delay but rather so
that the ends of justice may be served.
WHEREFORE, S.L.R., appellant, prays that this motion be granted
and that the time to file her brief be extended to Monday, May 18, 2015.
Respectfully submitted, ___________________________ TBN: 20016200 440 Louisiana St., Ste. 1130 Houston, TX 77002 Email: wmthursland@hotmail.com (713) 655-0200 x 105; Fax: (713) 655-9035 Attorney for Appellant, S.L.R.
CERTIFICATE OF CONFERENCE
Pursuant to TRAP 10.1(a)(5), I certify that appellee’s counsel, Sandra
D. Hachem, is unopposed to this motion.
/s/ william m thursland ______________________ William M. Thursland
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the foregoing pleading was
served on Sandra D. Hachem by electronic delivery or by fax to: (713) 437-
4700 on April 21, 2015.
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