Case Information

*0 FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS 5/11/2015 5:45:42 PM CHRISTOPHER A. PRINE Clerk *1 ACCEPTED 14-15-00370-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 5/11/2015 5:45:42 PM CHRISTOPHER PRINE CLERK N O . 14-15-00370-CV In the Court of Appeals for the 14 th Judicial District Houston, Texas In re C ONNIE V ASQUEZ H ARRISON , Relator Original Proceeding Arising from the 311 th Judicial District Harris County, Texas Trial Court Cause No. 2006-68864 R EAL P ARTY I N I NTEREST C LIFFORD L AYNE H ARRISON ’ S

F IRST M OTION TO E XTEND T IME TO F ILE R ESPONSE T O T HE H ONORABLE J USTICES OF THE F OURTEENTH OURT OF

A PPEALS :

Real Party in Interest, C LIFFORD L AYNE H ARRISON , (“Mr. Harrison”)

requests a thirty (30) day extension of time to file his response to C ONNIE V ASQUEZ ARRISON ’ , Petition for Writ of Habeas Corpus. In support of this motion, Mr.

Harrison shows as follows: *2 On or about April 28, 2015, C ONNIE V ASQUEZ ARRISON (“Relator”),

filed her Petition for Writ of Habeas Corpus before this Honorable Court.

The petition relates to several orders issued by the trial court in the

underlying suit. Following a hearing on October 24, 2014, the Honorable Alicia K.

Franklin, Presiding Judge of the 311 th Judicial District Court of Harris

County, Texas, signed an order holding Relator in contempt of court and

committing her to the Harris County Jail. It was ordered that Relator be

placed on community supervision and her commitment be conditionally

suspended. On December 18, 2014, the Honorable Alicia K. Franklin, Presiding

Judge of the 311 th Judicial District Court of Harris County, Texas, signed

an order revoking Relator’s suspension of commitment and committed

Relator to the Harris County Jail. Relator was subsequently released from

the Harris County Jail on January 5, 2015. On April 10, 2015, the Honorable Judge Charley Prine, as the sitting,

assigned Judge of the 311th District Court, entered an order revoking

Relator’s suspension of commitment, thereby committing Relator to the

Harris County Jail, again.

5. On or about April 28, 2015, Relator filed her Petition for Writ of Habeas

Corpus before this Honorable Court. Contemporaneously with her

Petition for Writ of Habeas Corpus, Relator filed a Motion for Emergency

Interim Relief.

6. On April 29, 2015 this Court issued a writ of habeas corpus, returnable on

May 26, 2015 (pending final determination of the relief requested in

Relator’s petition). On the same day, this Court also denied (as moot),

Relator’s Motion for Emergency Interim Relief. This Court has requested a response to Relator’s Petition for Writ of

Habeas Corpus be filed on or before May 12, 2015. Real Party in Interest, Clifford Harrison, respectfully requests an

extension of time of thirty (30) days to file his response pursuant to Rule

10.5 and Rule 38.6 of the Texas Rules of Appellate Procedure. There are still numerous unresolved post-judgment matters relating to the

underlying case pending before the trial court. As a result, Real Party in

Interest, Clifford Harrison, has been required to commit an exceptional

amount of time attending to the resolution of those matters. In addition to the perpetual nature of the ongoing trial court proceedings,

Relator has been unrelenting in seeking various forms of appellate relief

before this Court. Aside from Relator’s Petition for Writ of Habeas

Corpus currently before this Court, since the beginning of the year,

Relator has filed two (2) Petitions for Writ of Mandamus with this Court.

Significant time was expended responding to Relator’s second Petition for

Writ of Mandamus, the response having been filed just last week.

11. Much of Counsel’s recent time has been devoted to the resolution of

matters related to this case. An extension is being requested so that

Counsel may appropriately attend to other pending client matters in her

caseload while also preparing a response to Relator’s Petition for Writ of

Habeas Corpus that best presents Mr. Harrison’s position. Pursuant to the writ issued by this Court, Relator has been released from

commitment at the Harris County Jail. Therefore, an extension of time to

respond to Relator’s petition would not unduly harm or disadvantage

Relator in any way. Real Party in Interest respectfully requests additional time to prepare his

response to Relator’s Petition for Writ of Habeas Corpus. Real Party in Interest, Clifford Harrison has not been granted any previous

extensions to the deadline to respond to the Petition for Writ of Habeas

Corpus. This motion is not made to delay, but to present Mr. Harrison’s position

effectively and in compliance with the Rules of Appellate Procedure.

P RAYER W HEREFORE , P REMISES ONSIDERED , Real Party in Interest, Clifford

Harrison, respectfully requests that the Court grant a thirty (30) day extension of

time for Real Party in Interest to file a response to Relator’s Petition for Writ of

Habeas Corpus.

Respectfully Submitted, ARAH IRSCH J OYCE , A TTORNEY AT L AW /s/ Sarah Hirsch Joyce Sarah Hirsch Joyce State Bar No. 24092522 3355 W. Alabama St., Suite 825 (713) 529-3982 (855) 624-7224 Facsimile SarahHirschJoyce@gmail.com Appellate Counsel for Clifford Layne Harrison, Real Party in Interest *6 C ERTIFICATE OF C ONFERENCE I hereby certify that Real Party in Interest’s counsel has conferred with Terry

Hart, counsel for Relator, and he is opposed to this request for extension.

_/s/ Sarah Hirsch Joyce Sarah Hirsch Joyce ERTIFICATE OF ERVICE I certify that a true copy was served on all parties and/or counsel of record in

accordance with Texas Rules of Appellate Procedure 6.3 and 9.5(b), (d) and (e) on

May 11, 2015 as follows:

T ERRY L. ART

State Bar No. 09150750

4265 San Felipe, Suite 1100 Houston, TX 77027

Tel: (713) 968-9818

Fax: (713) 968-9817

Email: thart@terryhartlaw.com

/s/ Sarah Hirsch Joyce Sarah Hirsch Joyce