Case Information

*0 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 7/17/2015 4:00:34 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 01-15-00258-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 7/17/2015 4:00:34 PM CHRISTOPHER PRINE CLERK NO. 01-15-00258-CV IN THE COURT OF APPEALS FOR THE FIRST JUDICIAL DISTRICT OF TEXAS AT HOUSTON IN THE INTEREST OF M.M-Y.P., CHILD S.L.R., Appellant v.

TEXAS DEPARTMENT OF FAMILY AND PROTECTIVE SERVICES,

Appellee On Appeal from the 314th District Court Harris County, Texas Trial Court Cause No. 2014-00702J APPELLANT'S UNOPPOSED MOTION FOR EXTENSION

OF TIME TO FILE REPLY BRIEF TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

S.L.R, appellant, moves the Court to extend the time to file her reply

brief to Monday, July 20, 2015 and in support thereof respectfully shows:

1. In an order dated July 9, 2015, the Court requested that appellant

file a reply brief to address whether her motion for new trial should be

treated as a judicial admission regarding her interest in terminating her

parental rights. Appellant was given until Friday, July 17, 2015 to file her

reply brief.

2. Good cause exists to grant this motion. Within the last ten days

appellant's counsel represented the mother in the trial ofacase involving the

termination ofparental rights in cause no. 2014-00610-CV; styled: In re

J.G., et al, in the 313th District Court and prepared for atrial scheduled for

July 16, 2015 where he represents the respondent charged with the first

degree felony offense of aggravated sexual assault in cause no. 2013-00545-

CV; styled:

In the Matter ofD. W.\ in the 315th District Court. In addition,

on July 16, 2015, he was appointed to as the attorney ad litem for the

children who are placed in foster care in cause no. 2015-04311J; styled: In

re X.H., etal, inthe 315th District Court. He is scheduled to visit the

children on Friday, July 17, 2015.

3. This extension is not sought for the purposes of delay but rather so

that the ends ofjustice may be served.

WHEREFORE, S.L.R., appellant, prays that this motion be granted

and that the time to file her reply brief be extended to Monday, July 20,

2015.

Respectfully submitted, TBN: 20016200 440 Louisiana St., Ste. 1130 Houston, TX 77002 *3 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.

Isi 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 July 17,2015.