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

MOTION FOR EXTENSION OF TIME 

TO FILE APPELLANT’S BRIEF AND TO SECURE FULL RECORD

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

for Appellant, M.A.B., JR., and files this his Motion for Extension of Time to File

Appellant’s Brief and to Secure Full Record 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

7/20/2015 4:55:42 PM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 7/20/2015 4:55:42 PM CHRISTOPHER A. PRINE Clerk
I.

MOTION FOR EXTENSION OF TIME

Mindful of the Court’s Order, Appellant’s counsel has been diligently

attempting to get the full record before the Court so that briefing could contain

correct and proper referencesto the record. Appellant’s counsel is diligently working

on Appellant’s Brief, which is due on July 20, 2015. Appellant’s counsel filed a

Motion for Supplemental Clerk’s Record on July 13, 2015. On July 17, 2015, this

Court granted the Motion and ordered that the Supplemental Clerk’s Record be filed

within two (2) days of the date of the Order. Although the District Clerk filed a

Supplemental Clerk’s Record on July 17, 2015, it is severely deficient and contains

merely three (3) documents. This Supplemental Clerk’s Record is not in compliance

with the documents requested in Appellant’s Motion and Ordered by this Court. 

Appellant’s counsel has also been attempting to get the Exhibits from the June 30,

2015 Hearing added to the record of this Court. In this regard, Appellant has on this

date filed a Motion to Supplement the Reporter’s Record With the Exhibits From

Hearing Following Abatement . In light of the Clerk’s non-compliance with this

Court’s Order of Supplementation and the missing Exhibits from the Hearing, it is

impossible for Appellant’s counsel to timely complete Appellant’s Brief before July

20, 2013.

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Accordingly, Appellantrequests the Court to order the record be supplemented

and to set a new timetable in conjunction with these Orders so that the Brief can be

properly prepared and presented.

II.

PRAYER

WHEREFORE PREMISES CONSIDERED, Appellant prays that this Court

grant this Motion for Extension of Time to File Appellant’s Brief and to Secure Full

Record.

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

G does not oppose motion

G agrees with motion

G would not say whether motion is opposed

X did not return my messages regarding the motion

John Spjut, Attorney Ad Litem for the Child:

G opposes motion

G does not oppose motion

G agrees with motion

G would not say whether motion is opposed

X did not return my messages regarding the motion

/s/William B. Connolly 

William B. Connolly

CERTIFICATE OF SERVICE

I certify that a true copy of the above Motion was served on: 

Sandra Hachem, Attorney for DFPS, 1019 Congress, 17th Floor, Houston,

Texas 77002 – via e-mail Sandra.Hachem@cao.hctx.net; and

John Spjut, Attorney Ad Litem for Child, 10924 Grant Road, Suite 623,

Houston, Texas 77070 – via e-mail spjutlaw@sbcglobal.net

on this the 20 day of July, 2015.

th

/s/ William B. Connolly 

William B. Connolly

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