NO. 01-15-00388-CV 

IN THE COURT OF APPEALS

FOR THE FIRST JUDICIAL DISTRICT

OF TEXAS AT HOUSTON

IN THE INTEREST OF

M.A.B., IV

M.A.B, JR.,

APPELLANT

VS.

TEXAS DEPARTMENT OF FAMILY AND PROTECTIVE SERVICES,

APPELLEE

ON APPEAL FROM THE 314TH 

DISTRICT COURT OF HARRIS COUNTY, TEXAS

TRIAL COURT CAUSE NO. 2014-00044J

UNOPPOSED MOTION FOR EXTENSION OF TIME 

TO FILE APPELLANT’S BRIEF

COMES NOW, WILLIAM B. CONNOLLY, Appellate Counsel and Attorney

for Appellant, M.A.B., JR., and files this his Unopposed Motion for Extension of

Time to File Appellant’s Brief and in support thereof would respectfully show the

Court the following:

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ACCEPTED

01-15-00388

FIRST COURT OF APPEALS

HOUSTON, TEXAS

6/2/2015 4:45:49 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 6/2/2015 4:45:49 PM CHRISTOPHER A. PRINE Clerk
I.

UNOPPOSED MOTION FOR EXTENSION OF TIME

TO FILE APPELLANT’S BRIEF

Appellant’s Brief is due on June 2, 2015. Appellant’s Counsel requires an

additional period of time to prepare Appellant’s Brief and requests this Court to grant

an unopposed extension of time 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. Appellant’s Counsel would show that his office has

been short staffed for the past few weeks as his legal assistant was diagnosed with a

sudden onset debilitating disease and has left his employment on permanent

disability. Appellant’s associate attorney was also out of the office on personal leave

for her wedding out of the city.

In addition, since the date the Clerk’s Record was filed, Appellant’s counsel

has had 24 court appearances, including two (2) final trials, home visitsto abused and

neglected children in their placements, including one out oftown visit, one mediation,

several office conferences, prepared a Motion for Rehearing for a juvenile proceeding

in the Fourteenth Court of Appeals and has responded to a Mandamus Petition in the

First Court of Appeals.

In addition, Appellant has filed a Motion to Abate seeking a remand for an

evidentiary hearing on Appellant’s claim of ineffective assistance of counsel. If the

Court grants the Motion, Appellant requests that the Court issue a timetable for the

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hearing, the filing of the supplemental record and briefing deadlines.

No previous extensions have been requested by Appellant’s counsel to file the

Brief and no extensions have been granted. Appellant requests that Court grant his

Unopposed Motion for Extension of Time to File Appellant’s Brief and that the Brief

due date be included in the Order related to Appellant’s Motion to Abate Appeal. 

II. 

PRAYER

WHEREFORE PREMISES CONSIDERED, Appellant prays that this Court

grant this Unopposed Motion for Extension of Time to File Appellant’s Brief.

Appellant prays for general relief. 

Respectfully submitted,

CONNOLLY & SHIREMAN, LLP

/s/William B. Connolly

William B. Connolly

State Bar No. 04702400

2930 Revere, Suite 300

Houston, Texas 77098

Telephone (713) 520-5757

Facsimile (713) 520-6644

wbc@conlawfirm.com

ATTORNEY FOR M.A.B., JR.

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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/William B. Connolly 

William B. Connolly

CERTIFICATE OF SERVICE

I certify that a true and correct copy of the foregoing Unopposed Motion for

Extension of Time to File Appellant’s Brief was forwarded to:

Sandra Hachem, Assisstant County Attorney, 1019 Congress, 17th Floor,

Houston, Texas 77002 – via facsimile (713) 437-4700 and e-mail

Sandra.Hachem@cao.hctx.net;

on this the 2 day of June, 2015.

nd

/s/William B. Connolly 

William B. Connolly

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