in the Matter of A. C.

Opinion

ACCEPTED 01-15-00932-CV FIRST COURT OF APPEALS HOUSTON, TEXAS 12/4/2015 3:46:55 PM CHRISTOPHER PRINE CLERK

NO. 01-15-00931-CV NO. 01-15-00932-CV NO. 01-15-00933-CV FILED IN 1st COURT OF APPEALS __________________________________________________________ HOUSTON, TEXAS 12/4/2015 3:46:55 PM IN THE COURT OF APPEALS CHRISTOPHER A. PRINE FOR THE FIRST JUDICIAL DISTRICT Clerk

OF TEXAS AT HOUSTON ___________________________________________________________

IN THE MATTER OF A.C., Appellant ___________________________________________________________

A.C., Appellant

v.

THE STATE OF TEXAS, Appellee _________________________________________________________

On Appeal from the 315th District Court Harris County, Texas Tr. Ct. Cause Nos. 2015-01921J, 2015-02194J & 2015-02097J _________________________________________________________

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

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

A.C., appellant, moves the Court to extend the time to file his brief be

extended to Thursday, December 31, 2015 and in support thereof

respectfully shows:

1. This is an accelerated appeal. Appellant’s brief was due on

December 3, 2015. 2. Good cause exists to grant this motion. Within the last four and a

half weeks, counsel prepared and filed appellant’s brief in the following

accelerated appeals: No. 14-15-00799-CV; styled: In re J.D.A.; no. 14-15-

00601-CV; styled: In re N.S. and, no. 14-15-00864-CV; styled: In re B.M.S.

Counsel is currently finishing the appellant’s briefs in no. 14-15-00882-CV;

styled: In re K.I.B.C. due on December 5, 2015 and no. 14-15-00904-CV;

styled: In re B.J.C., et al. due on December 14, 2015.

3. In addition, this week trials were scheduled for two parental

termination cases where counsel represents the mother in a case numbered

2014-04419J; styled: In the Interest of R.A., Child in the 313th District Court

and a father in a case numbered 2014-00645J; styled: In the Interest of R.P.,

et al., Children in the 315th District Court.

4. Finally, in the last thirty days counsel has appeared in

approximately 28 district and county court non-trial setting.

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

that the ends of justice may be served.

WHEREFORE, A.C., appellant, prays that this Honorable Court

extend the time to file his brief to December 31, 2015.

Respectfully submitted, /s/ william m thursland _____________________ William M. Thursland TBN: 20016200 440 Louisiana St., Ste. 1130 Houston, TX 77002 Email: wmthursland@hotmail.com Tel.: (713) 655-0200 x 105; Fax: (713) 655-9035

Attorney for Appellant A.C.

CERTIFICATE OF CONFERENCE

Pursuant to TRAP 10.1(a)(5), I certify that Appellee’s counsel, Alan Curry, is unopposed to this motion. /s/ william m thursland ______________________ William M. Thursland

CERTIFICATE OF SERVICE

I certify that on December 4, 2015 a true and correct copy of the foregoing pleading was served appellee’s counsel, the Harris County District Attorney’s Office, by fax to (713) 755-5809.

/s/ william m thursland ________________________ William M. Thursland