in the Interest of S. R. H., a Minor Child

Opinion

ACCEPTED 01-15-00714-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 10/26/2015 9:37:54 PM CHRISTOPHER PRINE CLERK

CAUSE NO. 01-15-00714-CV ____________________________________________________________ FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS IN THE COURT OF APPEALS 10/26/2015 9:37:54 PM FOR THE FIRST DISTRICT OF TEXAS CHRISTOPHER A. PRINE _____________________________________________________________ Clerk

IN THE INTEREST OF S.R.H., A CHILD _______________________________________________ ______________

From the 315th Judicial District Court of Harris County, Texas Cause No. 2013-04271J

MOTION FOR EXTENSION TO FILE APPELLANT’S BRIEF

1. This is an accelerated appeal in a parental termination case.

2. Appellant’s brief was due in this case on September 28th because the record was

filed on September 8, 2015.

3. On October 15, 2015, the Clerk notified the undersigned counsel that either a

brief or a motion for extension of time to file the brief had to be filed within ten

days after this notice. The due date would then be October 25 th, but the

undersigned counsel calculates that because October 25th was a Sunday, counsel

had until midnight of October 26th to file her motion for extension. Counsel has

filed a motion for extension pursuant to that calculation.

4. The Court issued an order on October 26th received by the undersigned counsel

at approximately 5:27 p.m. which stated that counsel must file appellant’s brief

by November 3, 2105. 5. Counsel respectfully requests that she be granted an extension until November

23rd. Counsel must have this time in order to communicate with her client and

his trial counsel. Trial counsel has expressed an interest to be involved in the

appeal and the undersigned counsel was out of town on vacation for two weeks

in October. This vacation had been scheduled for approximately four months.

Counsel also has her taxes due on November 2 nd (there is an extension this year

because of the flooding), and she is getting ready for trial, and has other work

obligations.

6. Therefore, counsel respectfully requests that the Court allow her an extension of

time to file appellant’s brief until November 23rd.

Respectfully submitted,

/s/ Lana Shadwick Lana Shadwick State Bar No. 00784951 12535 Kingsride, Ste. 313 Houston, Texas 77024 Telephone: (713) 392-8222 Lana@LanaShadwick.com

CERTIFICATE OF CONFERENCE

Appellant has notified opposing counsel and there is no opposition to this

motion.

/s/ Lana Shadwick CERTIFICATE OF SERVICE

The undersigned hereby certifies that a true and correct copy of the foregoing

instrument was forwarded to Asst. Harris County Attorney Sandra Hachem on the

26th day of October, 2015 by electronic mail.

/s/ Lana Shadwick