in the Interest of J.W.C., a Child

Opinion

ACCEPTED

05-14-01569-CV

FIFTH COURT OF APPEALS

DALLAS, TEXAS 3/5/2015 4:18:42 PM

LISA MATZ

CLERK

No. 05-14-01569-CV

FILED IN

IN THE 5th COURT OF APPEALS DALLAS, TEXAS

3/5/2015 4:18:42 PM

FIFTH COURT OF APPEALS LISA MATZ Clerk

DALLAS, TEXAS

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IN THE INTEREST OF J.W.C., A CHILD

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On Appeal from the 301st District Court Of Dallas County, Texas Cause No. DF-13-17254-T

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APPELLANT’S MOTION FOR ADDITIONAL TIME TO FILE APPELLANT’S BRIEF and MOTION TO ACCEPT FILED BRIEF

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TO THE HONORABLE JUSTICES OF SAID COURT:

COMES NOW APPELLANTS, James Cook and Shaunice Cook, who

through their attorney of record, Jim G. Cobb, request additional time to file

Appellant’s Brief and request the Court to accept Appellant’s brief that has been

tendered to the Court.

In support thereof would show:

1. Said Appellant’s brief was due to be filed by February 19, 2015.

2. Attorney for Appellant’s had a death in his family on February 18,

2015 with a rapidly scheduled funeral in Tyler, Texas on February 20,

2015 which he attended. On Monday, February 23, 2015, Appellant

attorney’s law office was closed due to bad weather (ice storm) and was

also closed for part of the day on Tuesday, February 24, 2015 due to

residual ice on the roads.

3. Appellant’s brief was filed on Thursday, February 26, 2015 making it

one week late.

4. Attorney for Appellants, Jim G. Cobb, and Appellants request the

Court to grant an extension of time to file said brief and request the

Court to accept the brief that was tendered to the Court on February 26,

2015.

PRAYER

WHEREFORE, Appellant’s, James Cook and Shaunice Cook, request an

extension of time to file brief and request the Court to accept the brief that has

tendered to the Court.

Respectfully submitted,

Jim G. Cobb

LAW OFFICE OF JIM G. COBB 701 Commerce Suite 200 Dallas, TX 75202 Tel: 214-752-0229 Facsimile: 214-752-5257 Email: adijimboy@aol.com

/S/ Jim G. Cobb____________ By: Jim G. Cobb SBN: 04443500

ATTORNEY FOR JAMES COOK, APPELLANT ATTORNEY FOR SHAUNICE COOK, APPELLANT

CERTIFICATE OF CONFERENCE

I hereby certify that I attempted to confer with the counsel for the other parties regarding whether they opposed the relief requested in this motion by email on Thursday, March 5, 2015. I also certify that earlier I spoke with Sylvia Cantu, Assistant District Attorney, and she had no objections. Glyne Worrell has not responded as of the date of the filed on this motion.

/S/ Jim G. Cobb____________ By: Jim G. Cobb

CERTIFICATE OF SERVICE

I certify that a true and correct copy of the above was served on Counsel for the Appellee and the Guardian ad Litem in accordance with 9.5 of the Texas Rules of Appellant Procedure in the manner indicated below on March 5, 2015.

VIA FACSIMILE 214-653-6615 AND EMAIL: Sylvia.cantu@dallascounty.org Assistant District Attorney SYLVIA A. CANTU 133 N. Riverfront Blvd. #19 Dallas, TX 75207 TEL: 214-698-2285 FAX: 214-653-6615

VIA FACSIMILE 214-540-4945 AND EMAIL: gworrell@theworrelllawfirm.com Guardian ad Litem/Attorney ad Litem for the child GLYNE D. WORRELL 4144 N. Central, Suite 230 Dallas, Texas 75204 TEL: 314-540-5950 FAX: 214-540-4945

/S/ Jim G. Cobb____________ By: Jim G. Cobb