in the Interest of M.M.-Y.P.

Opinion

ACCEPTED 01-15-00258-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 4/21/2015 12:43:10 PM CHRISTOPHER PRINE CLERK

NO. 01-15-00258-CV

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FILED IN 1st COURT OF APPEALS IN THE COURT OF APPEALS HOUSTON, TEXAS FOR THE FIRST JUDICIAL DISTRICT 4/21/2015 12:43:10 PM OF TEXAS AT HOUSTON CHRISTOPHER A. PRINE Clerk

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IN THE INTEREST OF M.M-Y.P., CHILD

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S.L.R., Appellant

v.

TEXAS DEPARTMENT OF FAMILY AND PROTECTIVE SERVICES, Appellee

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On Appeal from the 314th District Court Harris County, Texas Trial Court Cause No. 2014-00702J

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APPELLANT'S FIRST UNOPPOSED MOTION FOR EXTENSION OF TIME TO FILE BRIEF

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

S.L.R, appellant, moves the Court to extend the time to file her brief to Monday, May 18, 2015 and in support thereof respectfully shows:

1. This is an accelerated appeal and appellant's brief is due on April 21, 2015. The decree terminating her parental rights was signed on February 24, 2015.

2. Good cause exists to grant this motion. Within the last twenty days

appellant’s counsel prepared and filed original briefs in the following

accelerated appeals: No. 14-14-1030-CV; styled: In re A.L.H.; and no. 14-

15-00094-CV; styled: In re I.M.G. Counsel is also finishing appellant’s

original brief in another accelerated appeal numbered 14-15-00205-CV;

styled: In re: L.E.R, which is due tomorrow.

3. In addition, within the same time period, counsel prepared for and tried five cases involving the termination of parental rights and appeared in approximately 25 non-trial setting.

4. This extension is not sought for the purposes of delay but rather so that the ends of justice may be served.

WHEREFORE, S.L.R., appellant, prays that this motion be granted and that the time to file her brief be extended to Monday, May 18, 2015.

Respectfully submitted, /s/ william m thursland

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William M. Thursland TBN: 20016200 440 Louisiana St., Ste. 1130 Houston, TX 77002 Email: wmthursland@hotmail.com (713) 655-0200 x 105; Fax: (713) 655-9035

Attorney for Appellant, S.L.R.

CERTIFICATE OF CONFERENCE

Pursuant to TRAP 10.1(a)(5), I certify that appellee’s counsel, Sandra

D. Hachem, is unopposed to this motion.

/s/ william m thursland

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William M. Thursland

CERTIFICATE OF SERVICE

I certify that a true and correct copy of the foregoing pleading was

served on Sandra D. Hachem by electronic delivery or by fax to: (713) 437-

4700 on April 21, 2015.

/s/ william m thursland

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William M. Thursland