N0. 01-15-00845-CV

 

IN THE COURT OF APPEALS

FOR THE FIRST DISTRICT

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., CHILDREN

 

P.L.W., APPELLANT

VS.

DEPARTMENT OF FAMILY & PROTECTIVE

SERVICES, APPELLEE

 

 

ON APPEAL FROM 

THE 314TH DISTRICT COURT OF

HARRIS COUNTY, TEXAS

TRIAL COURT CAUSE NO. 2014-03436J 

 

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, P.L.W., 

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ACCEPTED

01-15-00845-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

11/23/2015 4:53:09 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 11/23/2015 4:53:09 PM CHRISTOPHER A. PRINE Clerk
respondent 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, 314th District Court of Harris County, Texas, and entered

September 21, 2015, Cause No. 2014-03436J, styled “In the Interest of 

D.L.T., D.L., D.L., T.L., D.W. aka D.T.W., Children; In the District 

Court of Harris County, 314th 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).

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III.

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 29, 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.

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. 01-15-00886-CV; styled: In the Interest of B.J., Jr., B.J., 

D.L., D.L., Children, 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 

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appearance Monday, November 14 2015, in County 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., Appellant,

prays that the Court grant her unopposed motion for first extension of 

time to file appellant’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

APPELLANT P.L.W.

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CERTIFICATE OF CONFERENCE

This motion is unopposed.

/s/ Donald M. Crane 

Donald M. Crane

CERTIFICATE OF SERVICE

I hereby certify that on this 23rd 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, 15th 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

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4. 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

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