in the Interest of D.L.T., D.L., D.L., T.L., D.W. AKA D.T.W., D.W., Children v. Department of Family and Protective Services

Opinion

ACCEPTED 01-15-00845-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 11/23/2015 4:53:09 PM CHRISTOPHER PRINE CLERK

N0. 01-15-00845-CV

FILED IN IN THE COURT OF APPEALS 1st COURT OF APPEALS HOUSTON, TEXAS 11/23/2015 4:53:09 PM FOR THE FIRST DISTRICT CHRISTOPHER A. PRINE Clerk OF TEXAS AT HOUSTON

IN THE INTEREST OF D.L.T., D.L., D.L., T.L., D.W. aka D.T.W., D.W., CHILDREN

P.L.W., APPELLANT

VS.

DEPARTMENT OF FAMILY & PROTECTIVE SERVICES, APPELLEE

ON APPEAL FROM THE 314TH DISTRICT COURT OF HARRIS COUNTY, TEXAS TRIAL COURT CAUSE NO. 2014-03436J

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, P.L.W.,

Page 1 of 6 respondent mother, and hereby files this 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 John F. Phillips, Presiding

Judge, 314th District Court of Harris County, Texas, and entered

September 21, 2015, Cause No. 2014-03436J, styled “In the Interest of

D.L.T., D.L., D.L., T.L., D.W. aka D.T.W., Children; In the District

Court of Harris County, 314th 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 November

23, 2015.

The undersigned is requesting an extension of time up to and

including December 29, 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 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. 01-15-00886-CV; styled: In the Interest of B.J., Jr., B.J.,

D.L., D.L., Children, said brief being due November 30, 2015, absent

request for a first extension. Further, Appellate counsel also is

preparing the appellant’s brief in Cause No. 01-15-00862-CV, styled:

In the Interest of T.T.T., T.D.T., Jr., T.T., K.W., K.T., Children, said

brief being due December 2, 2015, absent request for a first extension,

as well as the appellant’s brief in Cause No. 01-15-00885-CV, styled:

In the Interest of J.A.O., Child, said brief also being due December 2,

2015, absent request for a first extension.

Additionally, appellate counsel will be making several

appearances in the district courts of Harris County, Texas and a single

Page 3 of 6 appearance Monday, November 14 2015, in County Court Number

Two, Brazoria County, Texas, on a probate matter.

Finally, this motion to extend time is filed in conformity with Tex.

R. App. P. 10.5.

WHEREFORE, PREMISES CONSIDERED, P.L.W., Appellant,

prays that the Court grant her unopposed motion for first extension of

time to file appellant’s brief up to and including December 29, 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 P.L.W.

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 this 23rd day of November, 2015, a true and correct copy of the foregoing Appellant’s Unopposed Motion for First Extension of Time to File Appellant’s Brief was served in accordance with the TRAP.

1. Dan-Phi V. Nguyen Assistant County Attorney 1019 Congress Avenue, 15th Floor Houston, Texas 77002-1700 (713) 437-4700 fax

2. Juliane (Juli) Crow P.O. Box 10152 Houston, Texas 77206 (713) 422-2389 fax

3. Gary Polland 2211 Norfolk, Suite 920 Houston, Texas 77098 (713) 622-6334 fax

Page 5 of 6 4. John R. Millard 1 Sugar Creek Center Boulevard, Suite 925 Sugar Land, Texas 77478 1-888-501-6580 fax

5. Douglas Ray York 3355 West Alabama Street, Suite 100 Houston, Texas 77098-1863 (713) 586-5585 fax

6. JB Lee Bobbitt 1533 West Alabama Street, Suite 100 Houston, Texas 77006 (281) 476-7816 fax

7. Michael Francis Craig 1533 West Alabama Street, Suite 100 Houston, Texas 77006 (713) 526-3787 fax

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