in the Interest of I.M.T., a Child

Opinion

ACCEPTED 14-15-00869-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 12/14/2015 4:04:23 PM CHRISTOPHER PRINE CLERK

No. 14-15-00869-CV

In the Courts of Appeals for the FILED IN Fourteenth District of Texas at Houston, Texas 14th COURT OF APPEALS ________________________________________ HOUSTON, TEXAS 12/14/2015 4:04:23 PM Carlos Torres, Appellant CHRISTOPHER A. PRINE Clerk v.

Department of Family and Protective Services, Appellee

___________________________________________

On appeal from the Harris County District Court, 312th Judicial District Cause No. 2010-45148

______________________________________

MOTION FOR EXTENSION OF TIME TO FILE BRIEF

Carlos Torres, Appellant, would show the Court the following:

1. Counsel has not had sufficient time to prepare the brief on behalf of the Appellant. There

have been multiple trial docket settings and hearings in the past few weeks that have interfered

with counsel’s ability to properly assimilate the multiple court reporters’ records submitted along

with the exhibits. Counsel does not maintain an appellate practice and is a solo practitioner.

For these reasons, Appellant is requesting an extension of time in which to file his brief.

2. Counsel would further show the Court that the counsel for Appellee Sandra Hachem was

notified of this request for an extension of time and has no objection to the request.

3. Appellant prays the Court to grant his Motion for Extension of Time to File Brief.

Appellant is requesting the date of January 15, 2016 on which to file the brief.

1 Respectfully submitted,

By: /s/ Mary Kay Green Mary Kay Green Texas Bar No. 08365580 P. O. . Box 7744 Houston, Texas 77270-7744 Tel. (713) 582-7510 Fax. (713) 861-0617 mkgreenlaw@gmail.com Attorney for Carlos Torres

CERTIFICATE OF SERVICE

I certify that on December 14, 2015, a true and correct copy of Carlos Torres’s Motion of Extension of Time to File Brief was served to counsel or agent for Appellee Sandra D. Hachem by email to sandra.hachem@cao.hctx.net and Laura Arteaga by email to laura@lauraarteaga.com.

/s/ Mary Kay Green Attorney for Carlos Torres