in the Interest of R.N.Y., a Child

• Court: Court of Appeals of Texas
• Decided: January 23, 2015
• Docket: 14-14-00984-CV
• Status: Published

Opinion

ACCEPTED 14-14-00984-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 1/23/2015 11:07:21 AM CHRISTOPHER PRINE CLERK

No. 14-14-00984-CV

FILED IN 14th COURT OF APPEALS IN THE COURT OF APPEALS HOUSTON, TEXAS FOR THE FOURTEENTH JUDICIAL DISTRICT 1/23/2015 11:07:21 AM OF TEXAS AT HOUSTON CHRISTOPHER A. PRINE Clerk

IN THE INTEREST OF R.N.Y., Child

L.T.L.Y., Appellant

v.

TEXAS DEPARTMENT OF FAMILY AND PROTECTIVE SERVICES, Appellee

OnAppeal from the 314th District Court Harris County, Texas Trial Court Cause No. 2013-06634J

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

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

L.T.L.Y., appellant, files her first unopposed motion for extension of time to file her tardy brief to February 20, 2015 and in support thereof respectfully shows: 1. This is an accelerated appeal and appellant's brief was due on January 19, 2015. The decree terminating appellant's parental rights was signed on January 5, 2015. 2. Good cause exists to grant this motion. Appellant was found to be

indigent and counsel was appointed to represent her in the trial court

proceedings. The undersigned attorney was appointed to represent her on

appeal on January 8, 2015.

3. On January 22, 2015 counsel spoke with Rene, an assistant clerk of the Court of Appeals, and learned for the first time that appellant filed a premature pro se notice of appeal on December 11, 2014. Contemporaneously with the filing of this motion counsel is filing an amended notice of appeal with the order appointing appellate counsel attached.

4. This extension is not sought for the purposes of delay but rather so that the ends ofjustice may be served. WHEREFORE, L.T.L.Y., appellant, prays that this motion be granted and that the time to file her brief be extended to Friday, February 20, 2015.

Respectfully submitted, Isi william m thursland

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, L.T.L.Y. CERTIFICATE OF CONFERENCE

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

D. Hachem, is unopposed to this motion.

Isi william m thursland

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 January 23, 2015.

William M. Thursland WILLIAM M. THURSLAND Attorney At Law 440 Louisiana St., Ste. 1130 Houston, TX 77002 Tel: (713) 655-0200 x 105 Fax: (713) 655-9035 January 23, 2015

Ms. Phyllis Washington, Deputy Clerk Civil Post-Judgment 201 Caroline, Ste. 250 Houston, TX 77002

Re: No. 2013-06634J; In the Interest ofR.N.Y., 314th District Clerk; COA no.: 14-14-00984-CV

Dear Ms. Washington:

Please find enclosed the Amended Notice of Appeal with the attached Order Appointing Appellate Counsel and Confirming that Respondent is Indigent in the referenced case. Pursuant to TRAP 34.5(b) & (c), I request that you supplement the clerk's record by filing both the notice and order with the Court of Appeals.

Thanks you for your attention & co-operation in this matter.

Sincerely,

/s/ william m thursland

WMT:aa Encl.

cc: Sandra D. Hachem Clerk, 14th Ct. of Appeals