in the Interest of D. L. D., Jr., L. L.S., J. J. S., H. N. S., Children v. Department of Family and Protective Services ( 2015 )

ACCEPTED
01-15-00160-CV
FIRST COURT OF APPEALS
HOUSTON, TEXAS
4/27/2015 12:00:00 AM
CHRISTOPHER PRINE
CLERK
N0. 01-15-00160-CV
FILED IN
IN THE COURT OF APPEALS 1st COURT OF APPEALS
HOUSTON, TEXAS
4/27/2015 12:00:00 AM
FOR THE FIRST DISTRICT CHRISTOPHER A. PRINE
Clerk
OF TEXAS AT HOUSTON
IN THE INTEREST OF
D.L.D., JR., L.L.S., J.J.S., H.N.S., CHILDREN
J.T.D., AKA J.T.S., APPELLANT
VS.
DEPARTMENT OF FAMILY & PROTECTIVE
SERVICES, APPELLEE
ON APPEAL FROM
THE 313TH DISTRICT COURT OF
HARRIS COUNTY, TEXAS
TRIAL COURT CAUSE NO. 2013-05778J
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, J.T.D., aka J.T.S.,
Page 1 of 6
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 Glenn H. Devlin, Presiding
Judge, 313th District Court of Harris County, Texas, and entered
February 3, 2015, styled: Cause No. 2013-05778J; In the Interest of
D.L.D., JR., L.L.S., J.J.S., H.N.S., Children; In the District Court of
Harris County, 313th 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).
Page 2 of 6
III.
This is an accelerated appeal. Appellant’s brief is due April 27,
2015.
The Clerk’s Record and the Reporter’s Record are in need of
supplementation.
The undersigned is requesting an extension of time up to and
including June 11, 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. 14-15—00352-CV; styled: In the Interest
of S.S.B. and R.D., III, Children, as well as the appellant’s brief in Cause
No. 01-15-00256-CV; styled: In the Interest of M.B.M., and J.J.M.,
Children.
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.
Page 3 of 6
WHEREFORE, PREMISES CONSIDERED, J.T.D., aka J.T.S.,
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 June 11, 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 J.T.D., aka
J.T.S.
Page 4 of 6
CERTIFICATE OF CONFERENCE
This motion is unopposed.
/s/ Donald M. Crane
Donald M. Crane
CERTIFICATE OF SERVICE
I hereby certify that on April 26, 2015, that 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 to Sandra Hachem, Sr.
Assistant Harris County Attorney, counsel for DFPS by electronically
delivery through prodoc e-Filing, on Susan Ryan Soliz, attorney ad
litem, through e-Filing, on Theodore F. Trigg through e-Filing, on John
S. Maisel through e-Filing, and James Mark Cooper through e-Filing.
Sandra D. Hachem,
Senior Assistant County Attorney
Attorney for Appellee,
Department of Family and Protective Services
1019 Congress Avenue, 15th Floor
Houston, Texas 77002-1700
Sandra.Hachem@cao.hctx.net
(713) 437-4700 fax
Page 5 of 6
Susan Ryan Solis
2800 East Broadway, Suite C-518
Pearland, Texas 77581
(281) 317-9908 fax
Theodore F. Trigg
P.O. Box 10009
Houston, Texas 77206
(713) 956-7666 fax
John S. Maisel
917 Franklin Street, Suite 100
Houston, Texas 77002
(713) 228-4800 fax
James Mark Cooper
300 Fannin Street, Suite 220
Houston, Texas 77002-2030
(713) 4554-7710 fax
Rachel L. Gamez, CSR
Texas CSR 9222
Deputy Court Reporter
313th District Court
1200 Congress, 5th Floor
Houston, Texas 77002
(000) 000-0000 fax
/s/ Donald M. Crane
Donald M. Crane
Page 6 of 6