Case Information

*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 4/27/2015 12:00:00 AM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00160-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 4/27/2015 12:00:00 AM CHRISTOPHER PRINE CLERK N0. 01-15-00160-CV IN THE COURT OF APPEALS FOR THE FIRST DISTRICT OF TEXAS AT HOUSTON IN THE INTEREST OF D.L.D., JR., L.L.S., J.J.S., H.N.S., CHILDREN J.T.D., AKA J.T.S., APPELLANT VS.

DEPARTMENT OF FAMILY & PROTECTIVE SERVICES, APPELLEE ON APPEAL FROM THE 313 TH DISTRICT COURT OF HARRIS COUNTY, TEXAS TRIAL COURT CAUSE NO. 2013-05778J NOTICE OF APPEARANCE OF APPELLATE COUNSEL AND

APPELLANT’S UNOPPOSED MOTION FOR FIRST EXTENSION OF TIME TO FILE APPELLANT’S BRIEF TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

COMES NOW DONALD M. CRANE (“appellate counsel”),

appointed attorney ad litem on appeal for Appellant, J.T.D., aka J.T.S.,

respondent mother, and hereby files this notice of appearance of

appellate counsel and unopposed motion for first extension of time to

file appellant’s brief, and in support thereof would respectfully show as

follows:

I.

Appellant’s parental rights were terminated by a Decree for

Termination signed by the Honorable Glenn H. Devlin, Presiding

Judge, 313 th District Court of Harris County, Texas, and entered

February 3, 2015, styled: Cause No. 2013-05778J; In the Interest of

D.L.D., JR., L.L.S., J.J.S., H.N.S., Children; In the District Court of

Harris County, 313 Judicial District.

II.

Appellant is presumed indigent and may proceed without

advance payment of costs as provided by Tex. R. App. P. 20.1(a)(3).

III.

This is an accelerated appeal. Appellant’s brief is due April 27,

2015.

The Clerk’s Record and the Reporter’s Record are in need of

supplementation.

The undersigned is requesting an extension of time up to and

including June 11, 2015, to prepare and file appellant’s brief citing the

undersigned’s desire for additional time to review the record (and any

supplementation) in this appeal.

Further, appellate counsel would show that good cause exists to

grant the requested extension of time as he also is preparing the

appellant’s brief in Cause No. 14-15—00352-CV; styled: In the Interest

of S.S.B. and R.D., III, Children, as well as the appellant’s brief in Cause

No. 01-15-00256-CV; styled: In the Interest of M.B.M., and J.J.M.,

Children.

Additionally, appellate counsel will be making several

appearances in the district and probate courts of Harris County, Texas

over the next several weeks.

Finally, this motion to extend time is filed in conformity with

Tex. R. App. P. 10.5.

WHEREFORE, PREMISES CONSIDERED, J.T.D., aka J.T.S.,

Appellant, prays that the Court take notice that Donald M. Crane has

been appointed her appellate counsel and, further, grant her

unopposed motion for first extension of time to file appellant’s brief up

to and including June 11, 2015, as set forth above. Appellant prays for

general relief.

Respectfully submitted, Donald M. Crane 810 South Mason Road, Suite 350 Katy, Texas 77450 Telephone (281) 392-6611 Facsimile (281) 392-5383 State Bar No. 05005900 donmcrane@gmail.com ATTORNEY AD LITEM ON APPEAL FOR APPELLANT J.T.D., aka J.T.S.

CERTIFICATE OF CONFERENCE This motion is unopposed.

Donald M. Crane CERTIFICATE OF SERVICE I hereby certify that on April 26, 2015, that a true and correct copy of

the foregoing Notice of Appearance of Appellate Counsel and

Unopposed Motion for First Extension of Time to File Appellant’s Brief

was served in accordance with the TRAP to Sandra Hachem, Sr.

Assistant Harris County Attorney, counsel for DFPS by electronically

delivery through prodoc e-Filing, on Susan Ryan Soliz, attorney ad

litem, through e-Filing, on Theodore F. Trigg through e-Filing, on John

S. Maisel through e-Filing, and James Mark Cooper through e-Filing.

Sandra D. Hachem,

Senior Assistant County Attorney

Attorney for Appellee,

Department of Family and Protective Services

1019 Congress Avenue, 15 Floor

Houston, Texas 77002-1700

Sandra.Hachem@cao.hctx.net

(713) 437-4700 fax

Susan Ryan Solis

2800 East Broadway, Suite C-518

Pearland, Texas 77581

(281) 317-9908 fax

Theodore F. Trigg

P.O. Box 10009

Houston, Texas 77206

(713) 956-7666 fax

John S. Maisel

917 Franklin Street, Suite 100

Houston, Texas 77002

(713) 228-4800 fax

James Mark Cooper

300 Fannin Street, Suite 220

Houston, Texas 77002-2030

(713) 4554-7710 fax

Rachel L. Gamez, CSR

Texas CSR 9222

Deputy Court Reporter

313 th District Court

1200 Congress, 5 Floor

Houston, Texas 77002

(000) 000-0000 fax

Donald M. Crane