N0. 01-15-00571-CV

 

IN THE COURT OF APPEALS

FOR THE FIRST DISTRICT

OF TEXAS AT HOUSTON 

 

IN THE INTEREST OF

A.G. AND F.G., CHILDREN

 

S.F., APPELLANT

VS.

DEPARTMENT OF FAMILY & PROTECTIVE

SERVICES, APPELLEE

 

 

ON APPEAL FROM 

THE 313TH DISTRICT COURT OF

HARRIS COUNTY, TEXAS

TRIAL COURT CAUSE NO. 2013-06904J 

 

NOTICE OF APPEARANCE OF APPELLATE COUNSEL AND

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, S.F., respondent 

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ACCEPTED

01-15-00571-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

8/19/2015 9:39:24 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 8/19/2015 9:39:24 PM CHRISTOPHER A. PRINE Clerk
mother, and hereby files this notice of appearance of appellate counsel 

and 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 Glenn H. Devlin, Presiding 

Judge, 313th District Court of Harris County, Texas, and entered

June , 2015, Cause No. 2013-06904J, styled “In the Interest 

of A.G. and F.G., Children; In the District Court of Harris County, 313th

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). 

See Attached.

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III.

This is an accelerated appeal. Appellant’s brief is due August 24, 

2015. 

The undersigned is requesting an extension of time up to and 

including September 24, 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 was not the attorney of record in the 

underlying cause. 

 Further, 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. 01-15-00589-CV; styled: In the Interest 

of T.J.C.. II, Child, said brief being due September 3, 2015, absent 

request for a first extension. He also is preparing the appellant’s brief 

in Cause No. 14-15-00601-CV; styled: In the Interest of N.S., Child,

said brief on first extension and being due September 8, 2015.

Additionally, appellate counsel will be making several 

appearances in the district and probate courts of Harris County, Texas

over the next several weeks as well as an appearance in the County 

Court at Law, Austin County, Texas on August 25, 2015.

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

Tex. R. App. P. 10.5.

WHEREFORE, PREMISES CONSIDERED, S.F., Appellant,

prays that the Court take notice that Donald M. Crane has been 

appointed her appellate counsel and, further, grant her unopposed 

motion for first extension of time to file appellant’s brief up to and 

including September 24, 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 S.F.

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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 19th day of August, 2015, a true and 

correct copy of the foregoing Notice of Appearance of Appellate 

Counsel and Unopposed Motion for First Extension of Time to File 

Appellant’s Brief was served in accordance with the TRAP.

1. Sandra D. Hachem

Senior Assistant County Attorney

1019 Congress Avenue, 15th Floor

Houston, Texas 77002-1700

(713) 437-4700 fax

/s/ Donald M. Crane

Donald M. Crane

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