in the Interest of W.J.B. & J.B., Children

Opinion

ACCEPTED

14-15-00186-CV

FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS

7/27/2015 10:45:43 PM

CHRISTOPHER PRINE

CLERK

CAUSE NO. 14-15-00186-CV

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FILED IN

14th COURT OF APPEALS

HOUSTON, TEXAS

IN THE COURT OF APPEALS 7/27/2015 10:45:43 PM FOR THE FOURTEENTH DISTRICT OF TEXAS CHRISTOPHER A. PRINE Clerk

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IN THE INTEREST OF W.J.B. & J.B.

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From the 311th Judicial District Court of Harris County, Texas Cause No. 2009-23300

MOTION FOR EXTENSION TO FILE NOTICE OF APPEAL 1. This is an accelerated appeal in a parental termination case. 2. On July 16, 2015, this Court notified appellate counsel that a notice of appeal had been filed within a time period in which a motion for extension needed to be filed. Accordingly, the undersigned appellate counsel files the motion for extension of time in which to file a notice of appeal. 3. Counsel asks this Honorable Court to grant a motion for extension of time to file a notice of appeal because of the serious issues involved in this case and because a motion for extension of time is necessarily implied when the perfecting instrument is filed within 15 days of its due date. Verburgt v. Dorner, 959 S.W.2d 615, 617 (Tex. 1997). Moreover, appellant parent has a reasonable explanation to support the late filing.

4. The filing of the notice of appeal within this timeframe was due to trial counsel’s understanding of the time period in which to file a notice of appeal, and communication with appellate counsel with regard to the filing of a notice of appeal. 5. Appellate counsel asks that this Honorable Court grant this motion.

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 27th day of July, 2015 by electronic mail.

/s/ Lana Shadwick