# No. 05

- 14

- 01569

- CV



# IN THE

FIFTH COURT OF APPEALS

DALLAS, TEXAS

_______________________________________________________________________



## IN THE INTEREST OF J.W.C., A CHILD

________________________________________________________________________

On Appeal from the 301 st District Court

Of Dallas County, Texas

Cause No. DF-13 -17254-T

_____________________________________________________________________________



# APPELL ANT’S MOTION FOR ADDITIONAL

TIME TO FILE APPELL ANT’S BRIEF and

MOTION TO ACCEPT FILED BRIEF

______________________________________________________________________________



### TO THE HONORABLE JUSTICES OF SAID COURT:

COMES NOW APPELLANTS, James Cook and Sh au nice Cook, who

through their attorney of record, Jim G. Cobb, request additional time to file

Appell ant’s Brief and request the Court to accept Appellant ’ s brief that has been

tendered to the Court.

In support thereof would show:

1. Said Appellant’s brief was due to be filed by February 19, 2015. ACCEPTED

05-14-01569-CV

FIFTH COURT OF APPEALS

DALLAS, TEXAS

3/5/2015 4:18:42 PM

LISA MATZ

CLERK

### Appellant’s Motion for Additional Time

– page 3



### 2. Attorney for Appellant ’ s had a death in his family on February 18,

2015 with a rapidly scheduled funeral in Tyler, Texas on February 20,

2015 which he attended. On Monday, February 23, 2015, Appellant

attorney ’ s law office was closed due to ba d weather (ice storm) and was

also closed for part of the day on Tues d ay, February 24, 2015 due to

residual ice on the roads.

3. Appellant ’ s brief was filed on Thur s day, February 26, 2015 making it

one week late.

4. Attorney for Appellants, Jim G. Cobb

, and Appellant s request the

Court to grant an extension of time to file said brief and request the

Court to accept the brief that was tendered to the Court on Febr u a ry 26,

2015.

PRAYER

WHEREFORE, Appellant’s, James Cook and Shaunice Cook, request an

extension of time to file brief and request the Court to accept the brief that has

tendered to the Court.

Respectfully submitted,

Jim G. Cobb

### Appellant’s Motion for Additional Time

– page 3 LAW OFFICE OF JIM G. COBB

701 Commerce

Suite 200

Dallas, TX 7520 2

Tel: 214

- 752

- 0229

Facsimile: 214

- 752

- 5257

Email: adijimboy@aol.com

/S/ Jim G. Cobb

____________ By : Jim G. Cobb

SBN: 04443500

ATTORNEY FOR JAMES COOK, APPELLANT

ATTORNEY FOR SHAUNICE COOK, APPELLANT



### CERTIFICATE OF CONFERENCE

I hereby certify that I attempted to confer with the counsel for the other

parties regarding whether they opposed the relief requested in this motion by email

on Thursday, March 5, 201 5

. I also certif y that earlier I spoke with Sylvia

Cantu , Assistant District Attorney, and she had no objections. Glyne Worrell

has not responded as of the date of the filed on this motion

.

/S/ Jim G. Cobb

____________ By: Jim G. Cobb



### CERTIFICATE OF SERVICE

I certify that a true and correct copy of the above was served on Counsel for

the Appell ee and the Guardian ad Litem in accordance with 9.5 of t he Texas Rules

of Appellant Procedure in the manner indicated below on March 5, 2015.

### Appellant’s Motion for Additional Time

– page 3

VIA FACSIMILE 214

- 653

- 6615

AND EMAIL: Sylvia.cantu@dallascounty.org

Assistant District Attorney

SYLVIA A. CANTU

133 N. Riverfront Blvd. #19

Dallas, TX 75207

TEL: 214

- 698

- 2285

FAX: 214

- 653

- 6615

VIA FACSIMILE 214

- 540

- 4945

AND EMAIL: gworrell@theworrelllawfirm.com

Guardian ad Litem/Attorney ad Litem for the child

GLYNE D. WORRELL

4144 N. Central, Suite 230

Dallas, Texas 75204

TEL: 314

- 540

- 5950

FAX: 214

- 540

- 4945

/S/ Jim G. Cobb

____________ By: Ji m G. Cobb