N0. 01

- 15

- 00 845

- CV

IN THE COURT OF APPEALS

FOR THE F IRST D ISTRICT

OF TEXAS AT HOUSTON

IN THE INTEREST OF

D.L.T., D.L., D.L., T.L., D.W. aka D.T.W., D.W., CHILD REN

P.L.W., A PPELLANT

VS.

DEPARTMENT OF FAMILY & PROTECTIVE

SERVICES, APPELLEE

ON APPEAL FROM

THE 31 4

TH DISTRICT COURT OF

HARRIS COUNTY, TEXAS

TRIAL COURT CAUSE NO. 20 14- 03436 J

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 D ONALD M. CRANE (“appellate counsel”),

appointed a ttorney ad litem on appeal for Appellant, P.L.W.,

Page 1 of 6 ACCEPTED

01-15-00845-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

11/23/2015 4:53:09 PM

CHRISTOPHER PRINE

CLERKrespondent mother , and hereby files this 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 F. Phillips , Presiding

Judge, 31 4 th District Court of Harris County, Texas, and entered

September 21 , 2015

, Cause No. 20 14

- 03436 J , styled “ In the Interest of

D.L.T., D.L., D.L., T.L., D.W. aka D.T.W.

, Child ren ; In the District

Court of Harris County, 31 4 th 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 6III.

This is an accelerated appeal. Appellant’s brief is due November

23, 2015.

The undersigned is requesting an extension of time up to and

including December 2 9

, 2015, to prepare and file a ppellant’s b rief citing

the undersigned’ s desire for additional time to review the record (and

any supplementation) in this appeal.

A

ppellate 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

- 00 88 6

- CV; styled: In the Interest of B.J., Jr., B.J.,

D.L., D.L. , Child ren

, said brief being due November 30 , 2015, absent

request for a first extension . Further, Appellate counsel also is

preparing the appellant’s brief in Cause No. 01

- 15

- 00862

- CV, styled:

In the Interest of T

. T.T., T.D.T., Jr., T.T., K.W., K.T., Children, said

brief being due December 2, 2015, absent request for a first extension,

as well as the appellant’s brief in Cause No. 01

- 15

- 00885

- CV, styled:

In the Interest of J.A.O., Child, said brief also being due December 2,

2015, absent request for a first extension.

Additionally, appellate counsel will be making several

appearances in the district courts of Harris County, Texas and a single

Page 3 of 6appearance Monday, November 14 2015, in C ounty Court Number

Two, Brazoria County, Texas, on a probate matter

.

Finally, this motion to extend time is filed in conformity with Tex.

R. App. P. 10.5.

WHEREFORE, PREMISES CONSIDERED, P.L.W., A ppellant

,

prays that th e Court grant h er unopposed m otion for first e xtension of

t

ime to f ile a ppellant’s brief up to and including December 29, 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

A

PPELLANT P.L.W.

Page 4 of 6CERTIFICATE OF CONFERENCE

This motion is unopposed

.

/s/ Donald M. Crane

Donald M. Crane

CERTIFICATE OF SERVICE

I hereby certify that on this 2 3

rd day of November , 2015, a true

and correct copy of the foregoing Appellant’s 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, 15 th Floor

Houston, Texas 77002

- 1700

(713) 437

- 4700 fax

2. Juliane (Juli) Crow

P.O. Box 10152

Houston, Texas 77206

(713) 422

- 2389 fax

3. Gary Polland

2211 Norfolk, Suite 920

Houston, Texas 77098

(713) 622

- 6334 fax

Page 5 of 64. John R. Millard

1 Sugar Creek Center Boulevard, Suite 925

Sugar Land, Texas 77478

1

- 888

- 501

- 6580 fax

5. Douglas Ray York

3355 West Alabama Street, Suite 100

Houston, Texas 77098

- 1863

(713) 586

- 5585 fax

6. JB Lee Bobbitt

1533 West Alabama Street, Suite 100

Houston, Texas 77006

(281) 476

- 7816 fax

7. Michael Francis Craig

1533 West Alabama Street, Suite 100

Houston, Texas 77006

(713) 526

- 3787 fax

/s/ Donald M. Crane

Donald M. Crane

Page 6 of 6