                                                                                          ACCEPTED
                                                                                      01-15-00258-CV
                                                                           FIRST COURT OF APPEALS
                                                                                   HOUSTON, TEXAS
                                                                                4/21/2015 12:43:10 PM
                                                                                CHRISTOPHER PRINE
                                                                                               CLERK

                      NO. 01-15-00258-CV
  __________________________________________________________
                                                      FILED IN
                                                1st COURT OF APPEALS
                 IN THE COURT OF APPEALS            HOUSTON, TEXAS
              FOR THE FIRST JUDICIAL DISTRICT 4/21/2015 12:43:10 PM
                   OF TEXAS AT HOUSTON          CHRISTOPHER A. PRINE
                                                        Clerk
 ___________________________________________________________

             IN THE INTEREST OF M.M-Y.P., CHILD
   ________________________________________________________

                             S.L.R., Appellant

                                      v.

 TEXAS DEPARTMENT OF FAMILY AND PROTECTIVE SERVICES,
                           Appellee
  _________________________________________________________

              On Appeal from the 314th District Court
                       Harris County, Texas
                Trial Court Cause No. 2014-00702J
  _________________________________________________________

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


TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

      S.L.R, appellant, moves the Court to extend the time to file her brief
to Monday, May 18, 2015 and in support thereof respectfully shows:
      1. This is an accelerated appeal and appellant's brief is due on April
21, 2015. The decree terminating her parental rights was signed on February
24, 2015.
      2. Good cause exists to grant this motion. Within the last twenty days

appellant’s counsel prepared and filed original briefs in the following

accelerated appeals: No. 14-14-1030-CV; styled: In re A.L.H.; and no. 14-

15-00094-CV; styled: In re I.M.G. Counsel is also finishing appellant’s

original brief in another accelerated appeal numbered 14-15-00205-CV;

styled: In re: L.E.R, which is due tomorrow.

      3. In addition, within the same time period, counsel prepared for and
tried five cases involving the termination of parental rights and appeared in
approximately 25 non-trial setting.
      4. This extension is not sought for the purposes of delay but rather so
that the ends of justice may be served.
      WHEREFORE, S.L.R., appellant, prays that this motion be granted
and that the time to file her brief be extended to Monday, May 18, 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, S.L.R.
                    CERTIFICATE OF CONFERENCE

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

D. Hachem, 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 Sandra D. Hachem by electronic delivery or by fax to: (713) 437-

4700 on April 21, 2015.

                                /s/ william m thursland
                                ________________________
                                William M. Thursland
