N0. 01

- 15

- 00571

- CV

IN THE COURT OF APPEALS

FOR THE F IRST D ISTRICT

OF TEXAS AT HOUSTON

IN THE INTEREST OF

A.G. AND F.G., CHILD REN

S.F., A PPELLANT

VS.

DEPARTMENT OF FAMILY & PROTECTIVE

SERVICES, APPELLEE

ON APPEAL FROM

THE 31 3 TH DISTRICT COURT OF

HARRIS COUNTY, TEXAS

TRIAL COURT CAUSE NO. 20 13- 06904 J

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

appointed a ttorney ad litem on appeal for Appellant, S.F.

, respondent

Page 1 of 5 ACCEPTED

01-15-00571-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

8/19/2015 9:39:24 PM

CHRISTOPHER PRINE

CLERKmother

, 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, 31 3 th District Court of Harris County, Texas, and entered

June , 2015

, Cause No. 20 1 3

- 0 6904 J , styled “ In the Interest

of A.G. and F.G., Children; In the District Court of Harris County, 31 3 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).

See Attached.

Page 2 of 5I I I.

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

,

2015

.

The u ndersigned is requesting an extension of time up to and

including September 2 4

, 2015 , to prepare and file a ppellant’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 i n the

underlying cause.

Further , appellate counsel would show that good cause exists to

grant the requested extension of time as he also is p reparing the

appellant’s brief in Ca u

se No. 01

- 15

- 00 5 89

- 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

.

Page 3 of 5Finally, this motion to extend time is filed in conformity with

Tex. R. App. P. 10.5.

WHEREFORE, PREMISES CONSIDERED, S.F. , A ppell ant

,

prays that th e Court take notice that Donald M. Crane has been

appointed h er appellate counsel and, further, grant h er u nopposed

m otion for f irst e xtension of t ime to f ile a ppellant’s b rief 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

A

PPELLANT S.F.

Page 4 of 5CERTIFICATE OF CONFERENCE

This motion is unopposed

.

/s/ Donald M. Crane

Donald M. Crane

CERTIFICATE OF SERVICE

I hereby certify that on this 19 th 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, 15 th Floor

Houston, Texas 77002

- 1700

(713) 437

- 4700 fax

/s/ Donald M. Crane

Donald M. Crane

Page 5 of 5