in the Interest of W.J.B., a Child

Opinion

ACCEPTED 01-15-00802-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 12/2/2015 4:21:39 PM CHRISTOPHER PRINE CLERK

NO. 01-15-00802-CV _____________________________________________________________ FILED IN 1st COURT OF APPEALS IN THE COURT OF APPEALS HOUSTON, TEXAS FOR THE FIRST JUDICIAL DISTRICT 12/2/2015 4:21:39 PM OF TEXAS AT HOUSTON CHRISTOPHER A. PRINE Clerk _____________________________________________________________

IN THE INTEREST OF W.J.B, A CHILD ___________________________________________________________

T.B.F., Appellant

v.

TEXAS DEPARTMENT OF FAMILY AND PROTECTIVE SERVICES, Appellee _________________________________________________________

On Appeal from the 310th District Court Harris County, Texas Trial Court Cause No. 2014-18450 _________________________________________________________

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

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

T.B.F., appellant, moves the Court to extend the time to file her brief

to January 4, 2016 and in support thereof respectfully shows:

1. This is an accelerated appeal. The deadline for the brief in this

case is December 2, 2015.

2. Counsel finished the brief in this case but then realized that the

final decree dated October 6, 2015 was not included in the court record filed with the Court, even though this Court specifically ordered in November that

the record be supplemented.

3. Upon realizing the absence of the decree, Counsel immediately

took measures to ensure that the record is supplemented properly as

previously ordered by this Court.

3. Due to the absence of a material court record, good cause exists to

grant this motion.

4. This extension is not sought for the purposes of delay but rather so

that the ends of justice may be served.

WHEREFORE, T.B.F., appellant, prays that this motion be granted

and that the time to file her brief be extended to January 2, 2016.

Respectfully submitted,

s/ Juliane Crow ___________________________ Juliane Crow TBN: 24000652 PO Box 10152 Houston, Texas 77206 (281) 382-1395; Fax: (713) 422-2389 Email: jpcrow@yahoo.com

Attorney for Appellant, T.B.F. CERTIFICATE OF CONFERENCE

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

J. Hazeltine-Shedd, is unopposed to this motion.

/s/ juliane crow ______________________ Juliane P. Crow

CERTIFICATE OF SERVICE

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

served on Robert J. Hazeltine-Shedd, appellee counsel, and William M.

Thursland, counsel for appellant B.E.B., by electronic delivery on

December 2, 2015.

/s/ juliane corw ________________________ Juliane P. Crow