in the Interest of A.L.F., D.P.F-A., E.E.F., B.E.H. Jr., and R.F.B., Children

Opinion

ACCEPTED 01-15-00803-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 12/2/2015 4:44:09 PM CHRISTOPHER PRINE CLERK

NO. 01-15-00803-CV __________________________________________________________ FILED IN 1st COURT OF APPEALS IN THE COURT OF APPEALS HOUSTON, TEXAS FOR THE FIRST JUDICIAL DISTRICT 12/2/2015 4:44:09 PM OF TEXAS AT HOUSTON CHRISTOPHER A. PRINE Clerk ___________________________________________________________

IN THE INTEREST OF A.L.F., D.P.F-A., E.E.F., B.E.H., Jr., and R.F.B., CHILDREN ________________________________________________________

B.J.B., Appellant

v.

TEXAS DEPARTMENT OF FAMILY AND PROTECTIVE SERVICES, Appellee _________________________________________________________

On Appeal from the 310th District Court Harris County, Texas Trial Court Cause No. 2014-01773J _____________________________________________________________

APPELLANT'S FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

B.J.B., appellant, moves the Court to extend the time to file his brief

to Monday, January 4, 2016 and in support thereof respectfully shows:

1. This is an accelerated appeal. Appellant’s brief is due on

December 2, 2015. 2. Good cause exists to grant this motion. Within the last four and a half weeks, counsel prepared and filed appellant’s brief in the following accelerated appeals: No. 14-15-00799-CV; styled: In re J.D.A.; no. 14-15- 00601-CV; styled: In re N.S. and, no. 14-15-00864-CV; styled: In re B.M.S. Counsel is currently finishing the appellant’s briefs in no. 14-15-00882-CV; styled: In re K.I.B.C. due on December 5, 2015 and no. 14-15-00904-CV; styled: In re B.J.C., et al. due on December 14, 2015. 3. In addition, this week trials are scheduled for two parental termination cases where counsel represents the mother in a case numbered 2014-04419J; styled: In the Interest of R.A., Child in the 313th District Court and a father in a case numbered 2014-00645J; styled: In the Interest of R.P., et al., Children in the 315th District Court. 4. Finally, in the last thirty days counsel has appeared in approximately 28 district and county court non-trial setting. 5. This extension is not sought for the purposes of delay but rather so that the ends of justice may be served. WHEREFORE, B.J.B, appellant, prays that this motion be granted and that the time to file her brief be extended to Monday, January 4, 2015.

Respectfully submitted, /s/ william m thursland ___________________________ William M. Thursland TBN: 20016200 440 Louisiana St., Ste. 1130 Houston, TX 77002 Email: wmthursland@hotmail.com (713) 655-0200 x 105; Fax: (713) 655-9035 Attorney for Appellant, B.J.B

CERTIFICATE OF CONFERENCE

Pursuant to TRAP 10.1(a)(5), I certify that appellee’s counsel, R.J.

Hazeltine-Shedd, is unopposed to this motion.

/s/ william m thursland ______________________ William M. Thursland

CERTIFICATE OF SERVICE

I certify that a true and correct copy of the foregoing pleading was

served on R.J. Hazeltine-Shedd, appellee counsel, Donald Crane, counsel for

appellant father and Juli Crow, counsel for appellant mother, by electronic

delivery on December 2, 2015.

/s/ william m thursland ________________________ William M. Thursland