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

ACCEPTED
14-15-00869-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
12/14/2015 4:04:23 PM
CHRISTOPHER PRINE
CLERK
No. 14-15-00869-CV
In the Courts of Appeals for the
FILED IN
Fourteenth District of Texas at Houston, Texas 14th COURT OF APPEALS
________________________________________ HOUSTON, TEXAS
12/14/2015 4:04:23 PM
Carlos Torres, Appellant CHRISTOPHER A. PRINE
Clerk
v.
Department of Family and Protective Services, Appellee
___________________________________________
On appeal from the Harris County District Court, 312th Judicial District
Cause No. 2010-45148
______________________________________
MOTION FOR EXTENSION OF TIME TO FILE BRIEF
Carlos Torres, Appellant, would show the Court the following:
1. Counsel has not had sufficient time to prepare the brief on behalf of the Appellant. There
have been multiple trial docket settings and hearings in the past few weeks that have interfered
with counsel’s ability to properly assimilate the multiple court reporters’ records submitted along
with the exhibits. Counsel does not maintain an appellate practice and is a solo practitioner.
For these reasons, Appellant is requesting an extension of time in which to file his brief.
2. Counsel would further show the Court that the counsel for Appellee Sandra Hachem was
notified of this request for an extension of time and has no objection to the request.
3. Appellant prays the Court to grant his Motion for Extension of Time to File Brief.
Appellant is requesting the date of January 15, 2016 on which to file the brief.
1
Respectfully submitted,
By: /s/ Mary Kay Green
Mary Kay Green
Texas Bar No. 08365580
P. O. . Box 7744
Houston, Texas 77270-7744
Tel. (713) 582-7510
Fax. (713) 861-0617
mkgreenlaw@gmail.com
Attorney for Carlos Torres
CERTIFICATE OF SERVICE
I certify that on December 14, 2015, a true and correct copy of Carlos Torres’s Motion of
Extension of Time to File Brief was served to counsel or agent for Appellee Sandra D. Hachem
by email to sandra.hachem@cao.hctx.net and Laura Arteaga by email to laura@lauraarteaga.com.
/s/ Mary Kay Green
Attorney for Carlos Torres