in the Interest of X.F.H., Z.T.A.A. and J.D.K., Children ( 2015 )

ACCEPTED
14-15-00492-CV
FOURTEENTH COURT OF APPEALS
HOUSTON, TEXAS
7/14/2015 12:00:24 PM
CHRISTOPHER PRINE
CLERK
NO. 14-15-00492-CV
IN THE COURT OF APPEALS FILED IN
14th COURT OF APPEALS
HOUSTON, TEXAS
FOR THE FOURTEENTH JUDICIAL DISTRICT
OF TEXAS AT HOUSTON 7/14/2015 12:00:24 PM
CHRISTOPHER A. PRINE
Clerk
IN THE INTEREST OFX.F.H., Z.T.A.A. AND J.D.K.
F.J.K.H.,
APPELLANT
TEXAS DEPARTMENT OF FAMILY AND PROTECTIVE SERVICES,
APPELLEE
ON APPEAL FROM THE 315TH
DISTRICT COURT OF HARRIS COUNTY, TEXAS
TRIAL COURT CAUSE NO. 2012-05963 J
MOTION FOR EXTENSION OF TIME
TO FILE APPELLANT’S BRIEF
COMES NOW, W. Leslie Shireman, Appellate Counsel and Attorney for
Appellant, F.J.K.H., and files this his Motion for Extension of Time to File
Appellant’s Brief and in support thereof would respectfully show the Court the
following:
I.
MOTION FOR EXTENSION OF TIME
Appellant’s Brief was due on July 13, 2015. Appellant’s Counsel requires an
additional period of time to prepare Appellant’s Brief and requests this Court to grant
2015.07.14 M TN EX T TIM E 1ST.w pd
an extension of time of one week for him to file the Brief. In support of this Motion,
Appellant’s Counsel would show that he has not previously been able to adequately
prepare the Brief in this cause. Extensive roof repairs are in progress at Appellant’s
office building since July 7, resulting in serious disruptions (including but not limited
to loss of air conditioning) to the practice of Appellant’s Counsel.
In addition, this appeal involves a total of four children (the trial in this matter
involved two separate cases tried together, both of which are on appeal; the
companion cause number is 14-05-00489-CV) and a record of over 700 pages,
resulting in additional time being spent to adequately brief each case.
This is the first extension requested by Appellant’s Counsel. Two previous
extensions requested by the court reporter were granted for a total of 14 days.
Appellant’s Counsel requests that the Court extend the due date for Appellant’s Brief
to be filed to Monday, July 20, 2015.
II.
PRAYER
WHEREFORE PREMISES CONSIDERED, Appellant prays that this Court
grant this Motion for Extension of Time to File Appellant’s Brief.
Appellant prays for general relief.
Respectfully submitted,
CONNOLLY & SHIREMAN, LLP
/s/W. Leslie Shireman
2015.07.14 M TN EX T TIM E 1ST.w pd 2
W. Leslie Shireman
State Bar No. 24047791
2930 Revere Street, Suite 300
Houston, Texas 77098
Telephone (713) 520-5757
Facsimile (713) 520-6644
wbc@conlawfirm.com
ATTORNEY FOR APPELLANT
CERTIFICATE OF CONFERENCE
As required by Texas Rule of Appellate Procedure 10.1(a)(5), I certify that I
have conferred, or made a reasonable attempt to confer, with all other parties —
which are listed below — about the merits of this Motion with the following results:
Sandra Hachem, Attorney for TDFPS:
G opposes motion
X does not oppose motion
G agrees with motion
G would not say whether motion is opposed
G did not return my message regarding the motion
/s/W. Leslie Shireman
W. Leslie Shireman
CERTIFICATE OF SERVICE
I certify that a true and correct copy of the foregoingMotion for Extension of
Time to File Appellant’s Brief was forwarded to:
Sandra Hachem, Assistant County Attorney, 1019 Congress, 17th Floor,
Houston, Texas 77002 – via electronic filing manager at
Sandra.Hachem@cao.hctx.net;
on this the 14th day of July, 2015.
/s/W. Leslie Shireman
W. Leslie Shireman
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