in the Interest of A.H.G., a Child

Opinion

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

FILED IN IN THE COURT OF APPEALS FOR THE FIRST JUDICIAL DISTRICT 1st COURT OF APPEALS OF TEXAS AT HOUSTON HOUSTON, TEXAS 4/20/2015 10:52:09 PM CHRISTOPHER A. PRINE Clerk

N.G., Appellant

v.

Texas Department of Family and Protective Services, Appellee

On Appeal from the 308th 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

1 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 20th day of April, 2015 to:

Sandra D. Hachem /S/ Lana Shadwick