N0. 01-15-00160-CV

 

IN THE COURT OF APPEALS

FOR THE FIRST DISTRICT

OF TEXAS AT HOUSTON 

 

IN THE INTEREST OF

D.L.D., JR., L.L.S., J.J.S., H.N.S., CHILDREN

 

J.T.D., AKA J.T.S., APPELLANT

VS.

DEPARTMENT OF FAMILY & PROTECTIVE

SERVICES, APPELLEE

 

 

ON APPEAL FROM 

THE 313TH DISTRICT COURT OF

HARRIS COUNTY, TEXAS

TRIAL COURT CAUSE NO. 2013-05778J

 

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 DONALD M. CRANE (“appellate counsel”), 

appointed attorney ad litem on appeal for Appellant, J.T.D., aka J.T.S., 

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ACCEPTED

01-15-00160-CV

FIRST COURT OF APPEALS

HOUSTON, TEXAS

4/27/2015 12:00:00 AM

CHRISTOPHER PRINE

CLERK

 FILED IN 1st COURT OF APPEALS HOUSTON, TEXAS 4/27/2015 12:00:00 AM CHRISTOPHER A. PRINE Clerk
respondent 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, 313th District Court of Harris County, Texas, and entered 

February 3, 2015, styled: Cause No. 2013-05778J; In the Interest of 

D.L.D., JR., L.L.S., J.J.S., H.N.S., Children; In the District Court of 

Harris County, 313th 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).

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III.

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

2015. 

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

supplementation.

The undersigned is requesting an extension of time up to and 

including June 11, 2015, to prepare and file appellant’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 preparing the 

appellant’s brief in Cause No. 14-15—00352-CV; styled: In the Interest 

of S.S.B. and R.D., III, Children, as well as the appellant’s brief in Cause 

No. 01-15-00256-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 weeks.

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

Tex. R. App. P. 10.5.

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WHEREFORE, PREMISES CONSIDERED, J.T.D., aka J.T.S., 

Appellant, prays that the Court take notice that Donald M. Crane has 

been appointed her appellate counsel and, further, grant her

unopposed motion for first extension of time to file appellant’s brief 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

APPELLANT J.T.D., aka

J.T.S.

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CERTIFICATE OF CONFERENCE

This motion is unopposed.

/s/ Donald M. Crane 

Donald M. Crane

CERTIFICATE OF SERVICE

I hereby certify that on April 26, 2015, 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, 15th Floor

Houston, Texas 77002-1700

Sandra.Hachem@cao.hctx.net

(713) 437-4700 fax

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Susan Ryan Solis

2800 East Broadway, Suite C-518

Pearland, Texas 77581

(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 Reporter

313th District Court

1200 Congress, 5th Floor

Houston, Texas 77002

(000) 000-0000 fax

/s/ Donald M. Crane 

Donald M. Crane 

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