Case Information
*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 4/20/2015 10:52:09 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00195-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 4/20/2015 10:52:09 PM CHRISTOPHER PRINE CLERK
NO. 01-15-00195-CV IN THE COURT OF APPEALS FOR THE FIRST JUDICIAL DISTRICT
OF TEXAS AT HOUSTON N.G., Appellant
v.
Texas Department of Family and Protective Services, Appellee On Appeal from the 308 th Judicial District Court of Harris County, Texas
Trial Court Cause No. 2008-32527 MOTION FOR EXTENSION OF TIME TO FILE BRIEF
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
COMES NOW, N.G., Appellant, and files this her Motion for Extension of Time to
File Brief and respectfully shows the Court as follows:
1. This is an accelerated appeal. Appellant’s brief was due on April 20, 2015.
2. Counsel is requesting an extension of time to file Appellant’s brief to May 20,
2015. Opposing counsel with the Harris County Attorney’s Office is
unopposed to this motion.
3. Good cause exists to grant this extension. Counsel has moved both her office
and her residence and has been ill. Further, a visiting court reporter took the
testimony in this case and this has made it more difficult to quickly get a copy
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of the record from her. Counsel has also had court appearances and other trial
court matters, and appellate matters during this period. Most importantly, the
case involves special issues which has required additional communication
with Appellant.
4. For all of the above reasons, Counsel requests an extension to confer with her
client, and to adequately research and draft her brief.
WHEREFORE, Appellant prays that the Court grant an extension of time to
file her brief on May 20, 2015.
Respectfully Submitted,
/S/ Lana Shadwick
Lana Shadwick
State Bar No. 00784951
12620 FM 1960 Rd. West
Ste. A4-102
Houston, Texas 77065
Phone: 713-392-8222
Lana@LanaShadwick.com
Attorney for Appellant
CERTIFICATE OF SERVICE
I hearby certify that a true and correct copy of the foregoing has been
forwarded by electronic mail on this the 20 th day of April, 2015 to:
Sandra D. Hachem
/S/ Lana Shadwick
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