in the Matter of A.F.

Opinion

ACCEPTED 14-15-00709-CV FOURTEENTH COURT OF APPEALS HOUSTON, TEXAS 12/7/2015 1:43:57 PM CHRISTOPHER PRINE CLERK

NO. 1 4-15-00709-CV __________________________________________________________ FILED IN 14th COURT OF APPEALS IN THE COURT OF APPEALS HOUSTON, TEXAS FOR THE FOURTEENTH JUDICIAL DISTRICT 12/7/2015 1:43:57 PM OF TEXAS AT HOUSTON CHRISTOPHER A. PRINE Clerk ___________________________________________________________

IN THE MATTER OF A.F., Appellant ___________________________________________________________

A.F., Appellant

v.

THE STATE OF TEXAS, Appellee _________________________________________________________

On Appeal from the 314th District Court Harris County, Texas Trial Court Cause No. 2014-03135J _________________________________________________________

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

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

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

and in support thereof respectfully shows:

1. Appellant’s brief was due on December 2, 2015. He requests that

its due date be extended to Monday, January 4, 2016.

2. Good cause exists to grant this motion. Within the last five weeks

counsel prepared and filed appellant briefs 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 preparing the appellant’s briefs in accelerated appeals no. 14-15-

00882-CV; styled: In re K.I.B.C. due December 7, 2015 and no. 14-15-

00904-CV; styled: In re B.J.C., et al. due on December 14, 2015.

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

termination cases where counsel represented the mother in a case numbered

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

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

R.P., et al., Children in the 315th District Court. Finally, counsel appeared in

approximately 25 non-trial setting.

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

that the ends of justice may be served.

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

extend the time to file his brief to Monday, January 4, 2016.

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.F.

CERTIFICATE OF CONFERENCE

Pursuant to TRAP 10.1(a)(5), I certify that Appellee’s counsel, ADA Eric Cougler, is unopposed to this motion.

/s/ william m thursland ______________________ William M. Thursland

CERTIFICATE OF SERVICE

I certify that on December 7, 2015 a true and correct copy of the foregoing pleading was served appellee’s counsel, Eric Cougler, Assistant Harris County District Attorney, by fax to (713) 755-5809.

/s/ william m thursland ________________________ William M. Thursland