                                                                                           ACCEPTED
                                                                                       01-15-00803-CV
                                                                            FIRST COURT OF APPEALS
                                                                                    HOUSTON, TEXAS
                                                                                  12/2/2015 4:44:09 PM
                                                                                 CHRISTOPHER PRINE
                                                                                                CLERK

                      NO. 01-15-00803-CV
  __________________________________________________________
                                                      FILED IN
                                                1st COURT OF APPEALS
                 IN THE COURT OF APPEALS            HOUSTON, TEXAS
              FOR THE FIRST JUDICIAL DISTRICT 12/2/2015 4:44:09 PM
                   OF TEXAS AT HOUSTON          CHRISTOPHER A. PRINE
                                                       Clerk
 ___________________________________________________________

 IN THE INTEREST OF A.L.F., D.P.F-A., E.E.F., B.E.H., Jr., and R.F.B.,
                          CHILDREN
   ________________________________________________________

                              B.J.B., Appellant

                                      v.

 TEXAS DEPARTMENT OF FAMILY AND PROTECTIVE SERVICES,
                           Appellee
  _________________________________________________________

              On Appeal from the 310th District Court
                       Harris County, Texas
                Trial Court Cause No. 2014-01773J
_____________________________________________________________

    APPELLANT'S FIRST UNOPPOSED MOTION FOR EXTENSION
                   OF TIME TO FILE BRIEF

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

      B.J.B., appellant, moves the Court to extend the time to file his brief

to Monday, January 4, 2016 and in support thereof respectfully shows:

      1. This is an accelerated appeal. Appellant’s brief is due on

December 2, 2015.
      2. Good cause exists to grant this motion. Within the last four and a
half weeks, counsel prepared and filed appellant’s brief in the following
accelerated appeals: No. 14-15-00799-CV; styled: In re J.D.A.; no. 14-15-
00601-CV; styled: In re N.S. and, no. 14-15-00864-CV; styled: In re B.M.S.
Counsel is currently finishing the appellant’s briefs in no. 14-15-00882-CV;
styled: In re K.I.B.C. due on December 5, 2015 and no. 14-15-00904-CV;
styled: In re B.J.C., et al. due on December 14, 2015.
      3. In addition, this week trials are scheduled for two parental
termination cases where counsel represents the mother in a case numbered
2014-04419J; styled: In the Interest of R.A., Child in the 313th District Court
and a father in a case numbered 2014-00645J; styled: In the Interest of R.P.,
et al., Children in the 315th District Court.
      4. Finally, in the last thirty days counsel has appeared in
approximately 28 district and county court non-trial setting.
      5. This extension is not sought for the purposes of delay but rather so
that the ends of justice may be served.
      WHEREFORE, B.J.B, appellant, prays that this motion be granted
and that the time to file her brief be extended to Monday, January 4, 2015.


                                          Respectfully submitted,
                                          /s/ william m thursland
                                          ___________________________
                                          William M. Thursland
                                          TBN: 20016200
                                          440 Louisiana St., Ste. 1130
                                          Houston, TX 77002
                                          Email: wmthursland@hotmail.com
                                          (713) 655-0200 x 105;
                                          Fax: (713) 655-9035
                                      Attorney for Appellant, B.J.B


                    CERTIFICATE OF CONFERENCE

      Pursuant to TRAP 10.1(a)(5), I certify that appellee’s counsel, R.J.

Hazeltine-Shedd, is unopposed to this motion.

                                             /s/ william m thursland
                                             ______________________
                                             William M. Thursland


                       CERTIFICATE OF SERVICE

      I certify that a true and correct copy of the foregoing pleading was

served on R.J. Hazeltine-Shedd, appellee counsel, Donald Crane, counsel for

appellant father and Juli Crow, counsel for appellant mother, by electronic

delivery on December 2, 2015.

                                             /s/ william m thursland
                                             ________________________
                                             William M. Thursland
