in the Interest of X.F.H., Z.T.A.A. and J.D.K., Children

Opinion

ACCEPTED 14-15-00492-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 7/14/2015 12:00:24 PM CHRISTOPHER PRINE CLERK

NO. 14-15-00492-CV

IN THE COURT OF APPEALS FILED IN 14th COURT OF APPEALS HOUSTON, TEXAS FOR THE FOURTEENTH JUDICIAL DISTRICT OF TEXAS AT HOUSTON 7/14/2015 12:00:24 PM CHRISTOPHER A. PRINE Clerk IN THE INTEREST OFX.F.H., Z.T.A.A. AND J.D.K.

F.J.K.H., APPELLANT

TEXAS DEPARTMENT OF FAMILY AND PROTECTIVE SERVICES, APPELLEE

ON APPEAL FROM THE 315TH DISTRICT COURT OF HARRIS COUNTY, TEXAS

TRIAL COURT CAUSE NO. 2012-05963 J

MOTION FOR EXTENSION OF TIME TO FILE APPELLANT’S BRIEF

COMES NOW, W. Leslie Shireman, Appellate Counsel and Attorney for

Appellant, F.J.K.H., and files this his Motion for Extension of Time to File

Appellant’s Brief and in support thereof would respectfully show the Court the

following:

I. MOTION FOR EXTENSION OF TIME

Appellant’s Brief was due on July 13, 2015. Appellant’s Counsel requires an

additional period of time to prepare Appellant’s Brief and requests this Court to grant

2015.07.14 M TN EX T TIM E 1ST.w pd an extension of time of one week for him to file the Brief. In support of this Motion,

Appellant’s Counsel would show that he has not previously been able to adequately

prepare the Brief in this cause. Extensive roof repairs are in progress at Appellant’s

office building since July 7, resulting in serious disruptions (including but not limited

to loss of air conditioning) to the practice of Appellant’s Counsel.

In addition, this appeal involves a total of four children (the trial in this matter

involved two separate cases tried together, both of which are on appeal; the

companion cause number is 14-05-00489-CV) and a record of over 700 pages,

resulting in additional time being spent to adequately brief each case.

This is the first extension requested by Appellant’s Counsel. Two previous

extensions requested by the court reporter were granted for a total of 14 days.

Appellant’s Counsel requests that the Court extend the due date for Appellant’s Brief

to be filed to Monday, July 20, 2015.

II. PRAYER

WHEREFORE PREMISES CONSIDERED, Appellant prays that this Court

grant this Motion for Extension of Time to File Appellant’s Brief.

Appellant prays for general relief.

Respectfully submitted, CONNOLLY & SHIREMAN, LLP

/s/W. Leslie Shireman

2015.07.14 M TN EX T TIM E 1ST.w pd 2 W. Leslie Shireman State Bar No. 24047791 2930 Revere Street, Suite 300 Houston, Texas 77098 Telephone (713) 520-5757 Facsimile (713) 520-6644 wbc@conlawfirm.com

ATTORNEY FOR APPELLANT

CERTIFICATE OF CONFERENCE

As required by Texas Rule of Appellate Procedure 10.1(a)(5), I certify that I have conferred, or made a reasonable attempt to confer, with all other parties — which are listed below — about the merits of this Motion with the following results:

Sandra Hachem, Attorney for TDFPS:

G opposes motion X does not oppose motion G agrees with motion G would not say whether motion is opposed G did not return my message regarding the motion

/s/W. Leslie Shireman W. Leslie Shireman

CERTIFICATE OF SERVICE

I certify that a true and correct copy of the foregoingMotion for Extension of Time to File Appellant’s Brief was forwarded to:

Sandra Hachem, Assistant County Attorney, 1019 Congress, 17th Floor, Houston, Texas 77002 – via electronic filing manager at Sandra.Hachem@cao.hctx.net;

on this the 14th day of July, 2015.

2015.07.14 M TN EX T TIM E 1ST.w pd 3