in the Interest of M.S., a Child ( 2015 )

ACCEPTED
01-15-00451-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
6/30/2015 6:08:22 PM
CHRISTOPHER PRINE
CLERK
N0. 01-15-00451-CV
FILED IN
IN THE COURT OF APPEALS 1st COURT OF APPEALS
HOUSTON, TEXAS
6/30/2015 6:08:22 PM
FOR THE FIRST DISTRICT CHRISTOPHER A. PRINE
Clerk
OF TEXAS AT HOUSTON
IN THE INTEREST OF
M.S., CHILD
D.L.B., APPELLANT
VS.
DEPARTMENT OF FAMILY & PROTECTIVE
SERVICES, APPELLEE
ON APPEAL FROM
THE 314TH DISTRICT COURT OF
HARRIS COUNTY, TEXAS
TRIAL COURT CAUSE NO. 2014-02671J
NOTICE OF APPEARANCE OF APPELLATE COUNSEL AND
APPELLANT’S UNOPPOSED MOTION FOR FIRST
EXTENSION OF TIME TO FILE APPELLANT’S BRIEF
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
COMES NOW DONALD M. CRANE (“appellate counsel”),
appointed attorney ad litem on appeal for Appellant, D.L.B.,
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respondent mother, and hereby files this notice of appearance of
appellate counsel and unopposed motion for first extension of time to
file appellant’s brief, and in support thereof would respectfully show as
follows:
I.
Appellant’s parental rights were terminated by a Decree for
Termination signed by the Honorable John Phillips, Presiding Judge,
314th District Court of Harris County, Texas, and entered April 27, 2015,
styled: Cause No. 2014-02671J; In the Interest of M.S., Child; In the
District Court of Harris County, 314th Judicial District.
II.
Appellant is presumed indigent and may proceed without
advance payment of costs as provided by Tex. R. App. P. 20.1(a)(3).
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III.
This is an accelerated appeal. Appellant’s brief is due July 1,
2015.
The undersigned is requesting an extension of time up to and
including July 21, 2015, to prepare and file appellant’s brief citing the
undersigned’s desire for additional time to review the record (and any
supplementation) in this appeal.
Further, appellate counsel would show that good cause exists to
grant the requested extension of time as he also is preparing the
appellant’s brief in Cause No. 01-15-00469-CV; styled: In the Interest
of T.J.C. and J.A.Y., Children, said being due July 9, 2015, absent
request for extension.
Additionally, appellate counsel will be making several
appearances in the district and probate courts of Harris County, Texas
over the next several weeks.
Finally, this motion to extend time is filed in conformity with
Tex. R. App. P. 10.5.
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WHEREFORE, PREMISES CONSIDERED, D.L.B., Appellant,
prays that the Court take notice that Donald M. Crane has been
appointed her appellate counsel and, further, grant her unopposed
motion for first extension of time to file appellant’s brief up to and
including July 21, 2015, as set forth above. Appellant prays for general
relief.
Respectfully submitted,
/s/ Donald M. Crane
Donald M. Crane
810 South Mason Road, Suite
350
Katy, Texas 77450
Telephone (281) 392-6611
Facsimile (281) 392-5383
State Bar No. 05005900
donmcrane@gmail.com
ATTORNEY AD LITEM ON
APPEAL FOR
APPELLANT D.L.B.
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CERTIFICATE OF CONFERENCE
This motion is unopposed.
/s/ Donald M. Crane
Donald M. Crane
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CERTIFICATE OF SERVICE
I hereby certify that on this 30th day of June, 2015, a true and
correct copy of the foregoing Notice of Appearance of Appellate
Counsel and Unopposed Motion for First Extension of Time to File
Appellant’s Brief was served in accordance with the TRAP.
1. Dan-Phi V. Nguyen
Assistant County Attorney
1019 Congress Avenue, 15th Floor
Houston, Texas 77002-1700
(713) 437-4700 fax
2. Michael Francis Craig
1533 West Alabama Street, Suite 100
Houston, Texas 77006
(713) 526-3787 fax
3. John R. Millard
1 Sugar Creek Center Boulevard, Suite 925
Sugar Land, Texas 77478
(888) 501-6580 fax
4. JB Lee Bobbitt
405 Main Street, Suite 620
Houston, Texas 77002
(281) 476-7816 fax
5. Julia Rangel, CSR
Texas CSR 6412
Official Court Reporter
314th District Court
1200 Congress, 5th Floor
Houston, Texas 77002
(000) 000-0000 fax
/s/ Donald M. Crane
Donald M. Crane
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