in the Interest of W.J.B., a Child ( 2015 )

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