in the Interest of M.S., a Child

• Court: Court of Appeals of Texas
• Decided: June 30, 2015
• Docket: 01-15-00451-CV
• Status: Published

Opinion

ACCEPTED 01-15-00451-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 6/30/2015 6:08:22 PM CHRISTOPHER PRINE CLERK

N0. 01-15-00451-CV

FILED IN IN THE COURT OF APPEALS 1st COURT OF APPEALS HOUSTON, TEXAS 6/30/2015 6:08:22 PM FOR THE FIRST DISTRICT CHRISTOPHER A. PRINE Clerk OF TEXAS AT HOUSTON

IN THE INTEREST OF M.S., CHILD

D.L.B., APPELLANT

VS.

DEPARTMENT OF FAMILY & PROTECTIVE SERVICES, APPELLEE

ON APPEAL FROM THE 314TH DISTRICT COURT OF HARRIS COUNTY, TEXAS TRIAL COURT CAUSE NO. 2014-02671J

NOTICE OF APPEARANCE OF APPELLATE COUNSEL AND APPELLANT’S UNOPPOSED MOTION FOR FIRST EXTENSION OF TIME TO FILE APPELLANT’S BRIEF

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

COMES NOW DONALD M. CRANE (“appellate counsel”),

appointed attorney ad litem on appeal for Appellant, D.L.B.,

Page 1 of 6 respondent mother, and hereby files this notice of appearance of

appellate counsel and unopposed motion for first extension of time to

file appellant’s brief, and in support thereof would respectfully show as

follows:

I.

Appellant’s parental rights were terminated by a Decree for

Termination signed by the Honorable John Phillips, Presiding Judge,

314th District Court of Harris County, Texas, and entered April 27, 2015,

styled: Cause No. 2014-02671J; In the Interest of M.S., Child; In the

District Court of Harris County, 314th Judicial District.

II.

Appellant is presumed indigent and may proceed without

advance payment of costs as provided by Tex. R. App. P. 20.1(a)(3).

Page 2 of 6 III.

This is an accelerated appeal. Appellant’s brief is due July 1,

2015.

The undersigned is requesting an extension of time up to and

including July 21, 2015, to prepare and file appellant’s brief citing the

undersigned’s desire for additional time to review the record (and any

supplementation) in this appeal.

Further, appellate counsel would show that good cause exists to

grant the requested extension of time as he also is preparing the

appellant’s brief in Cause No. 01-15-00469-CV; styled: In the Interest

of T.J.C. and J.A.Y., Children, said being due July 9, 2015, absent

request for extension.

Additionally, appellate counsel will be making several

appearances in the district and probate courts of Harris County, Texas

over the next several weeks.

Finally, this motion to extend time is filed in conformity with

Tex. R. App. P. 10.5.

Page 3 of 6 WHEREFORE, PREMISES CONSIDERED, D.L.B., Appellant,

prays that the Court take notice that Donald M. Crane has been

appointed her appellate counsel and, further, grant her unopposed

motion for first extension of time to file appellant’s brief up to and

including July 21, 2015, as set forth above. Appellant prays for general

relief.

Respectfully submitted,

/s/ Donald M. Crane Donald M. Crane 810 South Mason Road, Suite 350 Katy, Texas 77450 Telephone (281) 392-6611 Facsimile (281) 392-5383 State Bar No. 05005900

donmcrane@gmail.com

ATTORNEY AD LITEM ON APPEAL FOR APPELLANT D.L.B.

Page 4 of 6 CERTIFICATE OF CONFERENCE

This motion is unopposed.

/s/ Donald M. Crane Donald M. Crane

Page 5 of 6 CERTIFICATE OF SERVICE

I hereby certify that on this 30th day of June, 2015, a true and correct copy of the foregoing Notice of Appearance of Appellate Counsel and Unopposed Motion for First Extension of Time to File Appellant’s Brief was served in accordance with the TRAP.

1. Dan-Phi V. Nguyen Assistant County Attorney 1019 Congress Avenue, 15th Floor Houston, Texas 77002-1700 (713) 437-4700 fax

2. Michael Francis Craig 1533 West Alabama Street, Suite 100 Houston, Texas 77006 (713) 526-3787 fax

3. John R. Millard 1 Sugar Creek Center Boulevard, Suite 925 Sugar Land, Texas 77478 (888) 501-6580 fax

4. JB Lee Bobbitt 405 Main Street, Suite 620 Houston, Texas 77002 (281) 476-7816 fax

5. Julia Rangel, CSR Texas CSR 6412 Official Court Reporter 314th District Court 1200 Congress, 5th Floor Houston, Texas 77002 (000) 000-0000 fax

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