in the Interest of A.G. and F.G., Children

• Court: Court of Appeals of Texas
• Decided: August 19, 2015
• Docket: 01-15-00571-CV
• Status: Published

Opinion

ACCEPTED 01-15-00571-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 8/19/2015 9:39:24 PM CHRISTOPHER PRINE CLERK

N0. 01-15-00571-CV

FILED IN IN THE COURT OF APPEALS 1st COURT OF APPEALS HOUSTON, TEXAS 8/19/2015 9:39:24 PM FOR THE FIRST DISTRICT CHRISTOPHER A. PRINE Clerk OF TEXAS AT HOUSTON

IN THE INTEREST OF A.G. AND F.G., CHILDREN

S.F., APPELLANT

VS.

DEPARTMENT OF FAMILY & PROTECTIVE SERVICES, APPELLEE

ON APPEAL FROM THE 313TH DISTRICT COURT OF HARRIS COUNTY, TEXAS TRIAL COURT CAUSE NO. 2013-06904J

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, S.F., respondent

Page 1 of 5 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, 313th District Court of Harris County, Texas, and entered

June , 2015, Cause No. 2013-06904J, styled “In the Interest

of A.G. and F.G., Children; In the District Court of Harris County, 313th

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).

See Attached.

Page 2 of 5 III.

This is an accelerated appeal. Appellant’s brief is due August 24,

2015.

The undersigned is requesting an extension of time up to and

including September 24, 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.

Appellate counsel was not the attorney of record in the

underlying cause.

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. 01-15-00589-CV; styled: In the Interest

of T.J.C.. II, Child, said brief being due September 3, 2015, absent

request for a first extension. He also is preparing the appellant’s brief

in Cause No. 14-15-00601-CV; styled: In the Interest of N.S., Child,

said brief on first extension and being due September 8, 2015.

Additionally, appellate counsel will be making several

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

over the next several weeks as well as an appearance in the County

Court at Law, Austin County, Texas on August 25, 2015.

Page 3 of 5 Finally, this motion to extend time is filed in conformity with

Tex. R. App. P. 10.5.

WHEREFORE, PREMISES CONSIDERED, S.F., 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 September 24, 2015, as set forth above. Appellant prays for

general relief.

Respectfully submitted,

/s/ Donald M. Crane 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 S.F.

Page 4 of 5 CERTIFICATE OF CONFERENCE

This motion is unopposed.

/s/ Donald M. Crane Donald M. Crane

CERTIFICATE OF SERVICE

I hereby certify that on this 19th day of August, 2015, 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.

1. Sandra D. Hachem Senior Assistant County Attorney 1019 Congress Avenue, 15th Floor Houston, Texas 77002-1700 (713) 437-4700 fax

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