in the Interest of M.I.B., a Minor
This text of in the Interest of M.I.B., a Minor (in the Interest of M.I.B., a Minor) 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 05-15-01044-CV FIFTH COURT OF APPEALS DALLAS, TEXAS 11/13/2015 5:34:25 PM LISA MATZ CLERK
No. 05-15-01041-CV No. 05-15-01042-CV FILED IN 5th COURT OF APPEALS No. 05-15-01043-CV DALLAS, TEXAS 11/13/2015 5:34:25 PM No. 05-15-01044-CV LISA MATZ Clerk
IN THE FIFTH COURT OF APPEALS DALLAS, TEXAS _______________________________________________________________________
IN THE INTEREST OF M.W. AND Z.W., CHILDREN IN THE INTEREST OF J.Q.W., A CHILD IN THE INTEREST OF J.W., A CHILD IN THE INTEREST OF M.B., A CHILD ________________________________________________________________________
On Appeal from the 302ND District Court Of Dallas County, Texas Cause No. DF-10-13224-U Cause No. DF-13-18933-U Cause No. DF-14-10757-U Cause No. DF-13-18931-U
_____________________________________________________________________________
APPELLANT’S MOTION FOR ADDITIONAL TIME TO FILE APPELLANT’S BRIEF and MOTION TO ACCEPT FILED BRIEF ______________________________________________________________________________
TO THE HONORABLE JUSTICES OF SAID COURT:
COMES NOW APPELLANT, Crystal Bowens, who through her attorney of record, Stephanie L. Pond, requests additional time to file Appellant’s Brief and
requests 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 November 12, 2015.
2. Since the second extension was granted, attorney for Appellant has
had to prepare for and appear at four CPS hearings, three trial settings,
two home visits to visit children, and one child support hearing.
3. Appellant’s attorney did not have time to adequately prepare the brief
in this case.
4. Appellant’s brief was filed today, November 13, 2015, making it one
day late.
5. Attorney for Appellant, Stephanie L. Pond, and Appellant 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 November 13,
2015.
PRAYER
WHEREFORE, Appellant, Crystal Bowens, requests an extension of
time to file brief and requests the Court to accept the brief that has been tendered
Appellant’s Motion for Additional Time – page 3 to the Court.
Respectfully submitted,
Stephanie L. Pond 701 Commerce Suite 200 Dallas, TX 75202 Tel: 214-752-0229 Facsimile: 214-752-5257 Email: stephaniepond@yahoo.com
/s/ Stephanie L. Pond By: Stephanie L. Pond SBN: 24079817 ATTORNEY FOR CRYSTAL BOWENS, APPELLANT
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the above was served on Counsel for the Appellees and the Guardian ad Litem in accordance with 9.5 of the Texas Rules of Appellant Procedure in the manner indicated below on November 13, 2015. VIA EMAIL: Sandre.Moncriffe@dallascounty.org Assistant District Attorney SANDRE MONCRIFFE
VIA EMAIL: gworrell@theworrelllawfirm.com Guardian ad Litem/Attorney ad Litem for the children GLYNE WORRELL
VIA EMAIL: Charles.Vaughn@dallascounty.org Attorney for Appellant CHARLES VAUGHN
/s/ Stephanie L. Pond____ By: Stephanie L. Pond
Appellant’s Motion for Additional Time – page 3
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