in the Interest of D. L. D., Jr., L. L.S., J. J. S., H. N. S., Children v. Department of Family and Protective Services
This text of in the Interest of D. L. D., Jr., L. L.S., J. J. S., H. N. S., Children v. Department of Family and Protective Services (in the Interest of D. L. D., Jr., L. L.S., J. J. S., H. N. S., Children v. Department of Family and Protective Services) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.
Opinion
ACCEPTED 01-15-00160-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 4/27/2015 12:00:00 AM CHRISTOPHER PRINE CLERK
N0. 01-15-00160-CV
FILED IN IN THE COURT OF APPEALS 1st COURT OF APPEALS HOUSTON, TEXAS 4/27/2015 12:00:00 AM FOR THE FIRST DISTRICT CHRISTOPHER A. PRINE Clerk OF TEXAS AT HOUSTON
IN THE INTEREST OF D.L.D., JR., L.L.S., J.J.S., H.N.S., CHILDREN
J.T.D., AKA J.T.S., APPELLANT
VS.
DEPARTMENT OF FAMILY & PROTECTIVE SERVICES, APPELLEE
ON APPEAL FROM THE 313TH DISTRICT COURT OF HARRIS COUNTY, TEXAS TRIAL COURT CAUSE NO. 2013-05778J
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, J.T.D., aka J.T.S.,
Page 1 of 6 respondent 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
February 3, 2015, styled: Cause No. 2013-05778J; In the Interest of
D.L.D., JR., L.L.S., J.J.S., H.N.S., 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).
Page 2 of 6 III.
This is an accelerated appeal. Appellant’s brief is due April 27,
2015.
The Clerk’s Record and the Reporter’s Record are in need of
supplementation.
The undersigned is requesting an extension of time up to and
including June 11, 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.
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. 14-15—00352-CV; styled: In the Interest
of S.S.B. and R.D., III, Children, as well as the appellant’s brief in Cause
No. 01-15-00256-CV; styled: In the Interest of M.B.M., and J.J.M.,
Children.
Additionally, appellate counsel will be making several
appearances in the district and probate courts of Harris County, Texas
over the next several weeks.
Finally, this motion to extend time is filed in conformity with
Tex. R. App. P. 10.5.
Page 3 of 6 WHEREFORE, PREMISES CONSIDERED, J.T.D., aka J.T.S.,
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 June 11, 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 J.T.D., aka J.T.S.
Page 4 of 6 CERTIFICATE OF CONFERENCE
This motion is unopposed.
/s/ Donald M. Crane Donald M. Crane
CERTIFICATE OF SERVICE
I hereby certify that on April 26, 2015, that 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 to Sandra Hachem, Sr. Assistant Harris County Attorney, counsel for DFPS by electronically delivery through prodoc e-Filing, on Susan Ryan Soliz, attorney ad litem, through e-Filing, on Theodore F. Trigg through e-Filing, on John S. Maisel through e-Filing, and James Mark Cooper through e-Filing.
Sandra D. Hachem, Senior Assistant County Attorney Attorney for Appellee, Department of Family and Protective Services 1019 Congress Avenue, 15th Floor Houston, Texas 77002-1700 Sandra.Hachem@cao.hctx.net (713) 437-4700 fax
Page 5 of 6 Susan Ryan Solis 2800 East Broadway, Suite C-518 Pearland, Texas 77581 (281) 317-9908 fax
Theodore F. Trigg P.O. Box 10009 Houston, Texas 77206 (713) 956-7666 fax
John S. Maisel 917 Franklin Street, Suite 100 Houston, Texas 77002 (713) 228-4800 fax
James Mark Cooper 300 Fannin Street, Suite 220 Houston, Texas 77002-2030 (713) 4554-7710 fax
Rachel L. Gamez, CSR Texas CSR 9222 Deputy Court Reporter 313th District Court 1200 Congress, 5th Floor Houston, Texas 77002 (000) 000-0000 fax
Page 6 of 6
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