in the Matter of A.F. ( 2015 )

ACCEPTED
14-15-00709-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
12/7/2015 1:43:57 PM
CHRISTOPHER PRINE
CLERK
NO. 1 4-15-00709-CV
__________________________________________________________
FILED IN
14th COURT OF APPEALS
IN THE COURT OF APPEALS HOUSTON, TEXAS
FOR THE FOURTEENTH JUDICIAL DISTRICT 12/7/2015 1:43:57 PM
OF TEXAS AT HOUSTON CHRISTOPHER A. PRINE
Clerk
___________________________________________________________
IN THE MATTER OF A.F., Appellant
___________________________________________________________
A.F., Appellant
v.
THE STATE OF TEXAS,
Appellee
_________________________________________________________
On Appeal from the 314th District Court
Harris County, Texas
Trial Court Cause No. 2014-03135J
_________________________________________________________
APPELLANT’S SECOND UNOPPOSED MOTION FOR EXTENSION
OF TIME TO FILE BRIEF
TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:
A.F., appellant, moves the Court to extend the time to file his brief
and in support thereof respectfully shows:
1. Appellant’s brief was due on December 2, 2015. He requests that
its due date be extended to Monday, January 4, 2016.
2. Good cause exists to grant this motion. Within the last five weeks
counsel prepared and filed appellant briefs in the following accelerated
appeals: No. 14-15-00799-CV; styled: In re J.D.A.; no. 14-15-00601-CV;
styled: In re N.S. and, no. 14-15-00864-CV; styled: In re B.M.S. Counsel is
currently preparing the appellant’s briefs in accelerated appeals no. 14-15-
00882-CV; styled: In re K.I.B.C. due December 7, 2015 and no. 14-15-
00904-CV; styled: In re B.J.C., et al. due on December 14, 2015.
3. In addition, last week trials were scheduled for two parental
termination cases where counsel represented the mother in a case numbered
2014-04419J; styled: In the Interest of R.A., Child in the 313th District Court
and the father in a case numbered 2014-00645J; styled: In the Interest of
R.P., et al., Children in the 315th District Court. Finally, counsel appeared in
approximately 25 non-trial setting.
4. This extension is not sought for the purposes of delay but rather so
that the ends of justice may be served.
WHEREFORE, A.F., appellant, prays that this Honorable Court
extend the time to file his brief to Monday, January 4, 2016.
Respectfully submitted,
/s/ william m thursland
___________________________
William M. Thursland
TBN: 20016200
440 Louisiana St., Ste. 1130
Houston, TX 77002
Email: wmthursland@hotmail.com
Tel.: (713) 655-0200 x 105;
Fax: (713) 655-9035
Attorney for Appellant A.F.
CERTIFICATE OF CONFERENCE
Pursuant to TRAP 10.1(a)(5), I certify that Appellee’s counsel, ADA
Eric Cougler, is unopposed to this motion.
/s/ william m thursland
______________________
William M. Thursland
CERTIFICATE OF SERVICE
I certify that on December 7, 2015 a true and correct copy of the
foregoing pleading was served appellee’s counsel, Eric Cougler, Assistant
Harris County District Attorney, by fax to (713) 755-5809.
/s/ william m thursland
________________________
William M. Thursland