in the Interest of K.M.-J. AKA K.M-J and D.A.R.-J. v. Department of Family and Protective Services ( 2015 )

ACCEPTED
01-15-00253-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
7/2/2015 12:12:02 PM
CHRISTOPHER PRINE
CLERK
No. 01-15-00253-CV
______________________________________ FILED IN
1st COURT OF APPEALS
HOUSTON, TEXAS
IN THE COURT OF APPEALS FOR THE 7/2/2015 12:12:02 PM
FIRST JUDICIAL DISTRICT OF TEXAS AT HOUSTONCHRISTOPHER A. PRINE
__________________________________ Clerk
In the Interest of K.M-J aka K.M.J. and D.A.R.
__________________________________
H.J. [mother], Appellant
v.
Department of Family & Protective Services, Appellee
_______________________________________
On appeal from the 314th Judicial District
of Harris County, Texas; No. 2012-06289J
____________________________________
UNOPPOSED MOTION FOR EXTENSION OF TIME
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
Department of Family & Protective Services [hereinafter “Department”],
Appellee, files this motion for extension of time as follows:
1. Background: The above referenced appeal is from a judgment that
terminated parental rights on a suit filed by the Department, and is subject to
acceleration under Sections 109.002 and 263.405 of the Family Code. Tex. Fam.
Code Ann. §109.002 and §263.405 (West 2008). Pursuant to extensions granted
by this court, Appellant’s Brief was filed on June 2, 2015. Applying the applicable
accelerated deadline, Appellee’s Brief became due June 22, 2015.
2. First Extension: This is the Department’s first request for an
extension of time in this case.
3. Request for Extension of Time Due to Personal Issues, and
Heavy Work Demands in Other Accelerated Matters: The undersigned attorney
was unable to meet the due date for filing Appellee’s Brief in this case, because the
undersigned attorney needed to take a substantial amount of time off from work to
assist a brother who suffered medical conditions that required several
hospitalizations in May and June. Unfortunately, medical interventions were
unsuccessful and the undersigned attorney’s brother passed away June 10, 2015.
Moreover, since the death of the undersigned attorney’s brother, the undersigned
attorney has been suffering from her own medical issues and was advised by her
doctor to not work June 30, 2015 to July 6, 2015 while she undergoes treatment.
In addition to these personal matters, since the filing of Appellant’s Brief in
this case the undersigned attorney has had other competing accelerated matters that
have prevented the completion of the responsive brief in this matter including (1)
the preparation of an Appellee’s Brief in In re M.M.Y.P, No. 01-15-00258-CV; and
(2) an Appellee’s Brief in In re D.L.D., Jr., L.L.S., J.J.S., H.N.S., No. 01-15-00160-
CV. These issues together delayed the undersigned attorney’s ability to timely file
Appellee’s Brief in this case.
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WHEREFORE, PREMISES CONSIDERED, the Department requests that
this court allow the undersigned attorney to file the Department’s Appellee’s brief
in this matter on or before twenty days after the due date, or by July 13, 2015, and
for such other and further relief to which it may be entitled in law or in equity.
Respectfully submitted,
VINCE RYAN
HARRIS COUNTY ATTORNEY
/s/ Sandra D. Hachem
Sandra D. Hachem
Sr. Assistant County Attorney
State Bar #08667060
1019 Congress, 17th Floor
Houston, Texas 77002
Phone: 713/274-5293
Fax: 713/437-4700
Email: sandra.hachem@cao.hctx.net
Attorney for Appellee,
Department of Family &
Protective Services
CERTIFICATE OF CONFERENCE
This is to certify that reasonable efforts were made to confer with all parties
regarding the merits of this motion. The attorney for the appellant does not oppose
this motion.
/s/ Sandra D. Hachem
Sandra D. Hachem
CERTIFICATE OF SERVICE
I hereby certify that on this the 2nd day of July 2015 a true and correct copy
of this motion for extension of time was sent to all parties to this appeal by sending
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a copy by electronic transmission to the Appellant care of her attorney of record
William Thursland at his email address of wmthursland@hotmail.com.
/s/ Sandra D. Hachem
Sandra D. Hachem
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