in the Interest Of: M.I.M.

Opinion

ACCEPTED 05-14-00662-CV 05-14-00662-CV FIFTH COURT OF APPEALS DALLAS, TEXAS 9/3/2015 2:43:11 PM

No. 15- LISA MATZ CLERK

__________________________________ FILED IN IN THE 5th COURT OF APPEALS SUPREME COURT OF TEXAS DALLAS, TEXAS 9/3/2015 2:43:11 PM _________________________________ LISA MATZ Clerk IN THE INTEREST OF M.I.M., A CHILD The Office of the Attorney General of Texas, Petitioner,

V.

Brent Duane Blackmore, Respondent.

On Petition for Review from the Fifth Court of Appeals, Dallas, Texas Cause No. 05-14-00662-CV

MOTION FOR EXTENSION OF TIME TO FILE PETITION FOR REVIEW

TO THE HONORABLE SUPREME COURT OF TEXAS:

Petitioner, the Office of the Attorney General of Texas, respectfully files this motion

for an extension of time to file a petition for review.

A. The deadline for the Attorney General’s petition for review is September 8, 2015.

B. The Attorney General requests an extension of 30 days to file the petition for review,

so that it will be due on October 8, 2015.

C. The following facts justify an extension:

The undesigned Assistant Attorney General has been assigned to this matter as lead

counsel since its inception in the appellate courts for the first appeal in 2010. The undersigned Assistant Attorney General has been out of the office due to personal illness and

unable to complete the petition. The undersigned Assistant Attorney General’s knowledge

of this case makes it essential that she personally prepare the petition for review. This

extension is not sought for delay, but rather to give the petitioner’s preferred attorney

sufficient time to complete the petition.

D. No extensions have been granted for the filing of a petition for review in this case.

II.

Certificate of Conference

The undersigned counsel has conferred with Lilia Morales, interested party and she

is not opposed to this motion. The undersigned counsel attempted to confer with Brent

Blackmore via telephone on September 2, 2015. A voice message was left stating the

purpose of the call and asking for a return call or message. To date, Mr. Blackmore has not

responded.

III.

Prayer for Relief

For these reasons, the Office of the Attorney General requests that the Court grant a

30-day extension to file a petition for review in this case, so that it will be due on October

8, 2015.

Respectfully submitted,

KEN PAXTON ATTORNEY GENERAL OF TEXAS

CHARLES ROY FIRST ASSISTANT ATTORNEY GENERAL

MARA FRIESEN DEPUTY ATTORNEY GENERAL FOR CHILD SUPPORT TITLE IV-D DIRECTOR /s/ Rande K. Herrell RANDE K. HERRELL State Bar No. 09529400 MANAGING ATTORNEY APPELLATE LITIGATION SECTION CHILD SUPPORT DIVISION

JOHN B. WORLEY Assistant Attorney General State Bar No. 22001480

DETERREAN GAMBLE Assistant Attorney General State Bar No. 24062194

Child Support Division Appellate Litigation Section Mail Code 038-1 P.O. Box 12017, Capitol Sta. Austin, Texas 78711-2017 Phone: (512) 406-2306 Fax: (512) 460-6612 E-Mail: rande.herrell@texasattorneygeneral.gov

ATTORNEYS FOR PETITIONER, THE OFFICE OF THE ATTORNEY GENERAL OF TEXAS CERTIFICATE OF SERVICE

I certify that a copy of this motion is being served in the manner indicated on the

parties or their counsel listed below on September 3, 2015.

/s/ Rande K. Herrell Rande K. Herrell Assistant Attorney General

Brent Duaine Blackmore 801 Ingleside Dr. Plano, Texas 75075 brentblackmore@aol.com

Respondent, pro se

Lilia Noemi Morales Guatemala lily07302003@yahoo.com

Interested Party