N0. 01

- 15

- 00160

- CV

IN THE COURT OF APPEALS

FOR THE F IRST D ISTRICT

OF TEXAS AT HOUSTON

IN THE INTEREST OF

D.L.D., JR., L.L.S., J.J.S., H.N.S., C HILD REN

J.T.D., AKA J.T.S., 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- 05778J

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, J.T.D., aka J.T.S.

,

Page 1 of 6 ACCEPTED

01-15-00160-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

4/27/2015 12:00:00 AM

CHRISTOPHER PRINE

CLERKrespondent mother

, 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

February 3, 2015

, styled: Cause No. 20 1 3

- 0 5778 J ; In the Interest of

D.L.D., JR., L.L.S., J.J.S., H.N.S., Child ren ; 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).

Page 2 of 6I I I.

This is an accelerated appeal. Appellant’s brief is due April 27

,

201 5

.

The Clerk’s Record and the Reporter’s Record are in need of

supplementation

.

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

including June 11 , 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

.

Further , appellate counsel would show that good cause exists to

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

appel lant’s brief in Ca u

se No. 14

- 1 5

— 00352

- CV; styled: In the Interest

of S.S.B. and R.D., III , Child ren

, as well as the appellant’s brief in Cause

No. 01

- 1 5

- 00 256

- CV; styled: In the Interest of M.B.M., and J.J.M.,

Children

.

Additionally, appellate counsel will be making several

appearances in the district and probate courts of Harris County, Texas

over the next several w eeks.

Finally, this motion to extend time is filed in conformity with

Tex. R. App. P. 10.5.

Page 3 of 6WHEREFORE, PREMISES CONSIDERED, J.T.D., aka J.T.S.

,

Appellant

, 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 June 11

, 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 J.T.D., aka

J.T.S.

Page 4 of 6CERTIFICATE OF CONFERENCE

This motion is unopposed

.

/s/ Donald M. Crane

Donald M. Crane

CERTIFICATE OF SERVICE

I hereby certify that on April 26 , 201 5

, that 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 to Sandra Hachem, Sr.

Assistant Harris County Attorney , counsel for DFPS by electronically

delivery through prodoc e

- Filing

, on Susan Ryan Soliz , attorney ad

litem, through e

- Filing

, on Theodore F. Trigg through e

- Filing

, on John

S. Maisel through e

- Filing

, and James Mark Cooper through e

- Filing

.

Sandra D. Hachem,

Senior Assistant County Attorney

Attorney for Appellee,

Department of Family and Protective Services

1019 Congress Avenue, 15 th Floor

Houston, Texas 77002

- 1700

Sandra.Hachem@cao.hctx.net

(713) 437

- 4700 fax

Page 5 of 6Susan Ryan Solis

2800 East Broadway, Suite C

- 518

Pearland , Texas 77 581

(281) 317

- 9908 fax

Theodore F. Trigg

P.O. Box 10009

Houston, Texas 77206

(713) 956

- 7666 fax

John S. Maisel

917 Franklin Street, Suite 100

Houston, Texas 77002

(713) 228

- 4800 fax

James Mark Cooper

300 Fannin Street, Suite 220

Houston, Texas 77002

- 2030

(713) 4554

- 7710 fax

Rachel L. Gamez, CSR

Texas CSR 9222

Deputy Court R eporter

313 th District Court

1200 Congress, 5 th Floor

Houston, Texas 77002

(000) 000

- 0000 fax

/s/ Donald M. Crane

Donald M. Crane

Page 6 of 6