in the Interest of T.S.P., a Child

Court of Appeals of Texas·Decided February 12, 2015·No. 04-14-00547-CV·Published

Opinion

ACCEPTED

04-14-00547-CV

FOURTH COURT OF APPEALS

SAN ANTONIO, TEXAS

2/12/2015 3:52:30 PM

KEITH HOTTLE

CLERK

No. 04-14-00547-CV

IN THE

FILED IN

COURT OF APPEALS 4th COURT OF APPEALS FOR THE SAN ANTONIO, TEXAS FOURTH SUPREME JUDICIAL DISTRICT OF TEXAS 02/12/2015 3:52:30 PM

AT SAN ANTONIO, TEXAS KEITH E. HOTTLE Clerk

IN THE INTEREST OF T.S.P., A CHILD

APPELLEE'S MOTION TO EXTEND TIME TO FILE BRIEF

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS, FOURTH DISTRICT OF TEXAS:

COMES NOW, MARSALIE ZINSMEYER, the appellee in the above styled and numbered cause, pursuant to Texas Rules of Appellate Procedure 10.5(b) and 49.8, through her attorney of record, files this motion to extend time to file her Appellee’s brief. In support of this motion the appellee respectfully shows the following: 1. On January 16, 2015, Appellant’s brief was filed in this case. 2. The deadline for filing the Appellee’s brief in this appeal was set for February 16, 2015. 3. The Appellee seeks a fourteen-day extension of time to file her brief, making the due date March 2, 2015.

4. Appellee seeks this extension of time to file her brief because Attorney Shawn H. Smith, has had multiple scheduling conflicts over the past month, including several felony cases which needed to be disposed of through trial or hearings and demanded a large investment of time.

5. No previous extensions of time to file the motion for rehearing in this cause have been

sought or granted.

6. The undersigned counsel does not believe the additional time requested will prejudice or inconvenience the Appellant.

PRAYER

THEREFORE, the Appellee prays that this Court issue an order granting the extension of time to file the Appellee’s Brief in the above case, and grant all such relief as is fair and just.

Respectfully submitted,

LAW OFFICES OF SHAWN H. SMITH, P.C.

Shawn H. Smith

1919 San Pedro

San Antonio, TX 78212

Phone: 512-576-3380

Fax: 866-572-6413

/s/ Shawn H. Smith

Shawn H. Smith

State Bar Number: 24079361 ATTORNEY FOR APPELLEE

CERTIFICATE OF SERVICE

The undersigned does hereby certify that a copy of the above motion was delivered on August 25, 2013 to the State’s Attorney: Susan D. Reed, Criminal District Attorney, Bexar County District Attorney’s Office, 101 W. Nueva St., Suite 370, San Antonio, Texas 78205.

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