No. 05-15-01041-CV

No. 05-15-01042-CV

No. 05-15-01043-CV

No. 05-15-01044-CV

IN THE 

FIFTH COURT OF APPEALS 

DALLAS, TEXAS 

_______________________________________________________________________ 

IN THE INTEREST OF M.W. AND Z.W., CHILDREN 

IN THE INTEREST OF J.Q.W., A CHILD 

IN THE INTEREST OF J.W., A CHILD 

IN THE INTEREST OF M.B., A CHILD 

________________________________________________________________________ 

On Appeal from the 302ND District Court 

Of Dallas County, Texas 

Cause No. DF-10-13224-U 

Cause No. DF-13-18933-U 

Cause No. DF-14-10757-U 

Cause No. DF-13-18931-U 

_____________________________________________________________________________ 

APPELLANT’S MOTION FOR ADDITIONAL 

TIME TO FILE APPELLANT’S BRIEF and 

MOTION TO ACCEPT FILED BRIEF 

______________________________________________________________________________ 

TO THE HONORABLE JUSTICES OF SAID COURT: 

COMES NOW APPELLANT, Crystal Bowens, who through her attorney of 

ACCEPTED

05-15-01044-CV

FIFTH COURT OF APPEALS

DALLAS, TEXAS

11/13/2015 5:34:25 PM

LISA MATZ

CLERK

 FILED IN 5th COURT OF APPEALS DALLAS, TEXAS 11/13/2015 5:34:25 PM LISA MATZ Clerk
Appellant’s Motion for Additional Time – page 3

record, Stephanie L. Pond, requests additional time to file Appellant’s Brief and 

requests 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 November 12, 2015.

2. Since the second extension was granted, attorney for Appellant has 

had to prepare for and appear at four CPS hearings, three trial settings, 

two home visits to visit children, and one child support hearing. 

3. Appellant’s attorney did not have time to adequately prepare the brief 

in this case.

4. Appellant’s brief was filed today, November 13, 2015, making it one 

day late.

5. Attorney for Appellant, Stephanie L. Pond, and Appellant 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 November 13, 

2015.

 PRAYER

 WHEREFORE, Appellant, Crystal Bowens, requests an extension of 

time to file brief and requests the Court to accept the brief that has been tendered 
Appellant’s Motion for Additional Time – page 3

to the Court.

Respectfully submitted, 

Stephanie L. Pond

701 Commerce 

Suite 200

Dallas, TX 75202

Tel: 214-752-0229

Facsimile: 214-752-5257

Email: stephaniepond@yahoo.com

/s/ Stephanie L. Pond 

 By: Stephanie L. Pond

SBN: 24079817

ATTORNEY FOR CRYSTAL BOWENS, APPELLANT

CERTIFICATE OF SERVICE

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

the Appellees and the Guardian ad Litem in accordance with 9.5 of the Texas 

Rules of Appellant Procedure in the manner indicated below on November 13, 

2015. 

VIA EMAIL: Sandre.Moncriffe@dallascounty.org

Assistant District Attorney

SANDRE MONCRIFFE

VIA EMAIL: gworrell@theworrelllawfirm.com

Guardian ad Litem/Attorney ad Litem for the children

GLYNE WORRELL

VIA EMAIL: Charles.Vaughn@dallascounty.org

Attorney for Appellant

CHARLES VAUGHN

/s/ Stephanie L. Pond____

 By: Stephanie L. Pond