                                                                                             ACCEPTED
                                                                                         01-15-00802-CV
                                                                              FIRST COURT OF APPEALS
                                                                                      HOUSTON, TEXAS
                                                                                    12/2/2015 4:21:39 PM
                                                                                   CHRISTOPHER PRINE
                                                                                                  CLERK

                     NO. 01-15-00802-CV
_____________________________________________________________
                                                      FILED IN
                                                1st COURT OF APPEALS
                 IN THE COURT OF APPEALS            HOUSTON, TEXAS
              FOR THE FIRST JUDICIAL DISTRICT 12/2/2015 4:21:39 PM
                   OF TEXAS AT HOUSTON          CHRISTOPHER A. PRINE
                                                       Clerk
_____________________________________________________________

             IN THE INTEREST OF W.J.B, A CHILD
 ___________________________________________________________

                              T.B.F., Appellant

                                      v.

 TEXAS DEPARTMENT OF FAMILY AND PROTECTIVE SERVICES,
                           Appellee
  _________________________________________________________

              On Appeal from the 310th District Court
                        Harris County, Texas
                 Trial Court Cause No. 2014-18450
  _________________________________________________________

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

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

      T.B.F., appellant, moves the Court to extend the time to file her brief

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

      1. This is an accelerated appeal. The deadline for the brief in this

case is December 2, 2015.

      2. Counsel finished the brief in this case but then realized that the

final decree dated October 6, 2015 was not included in the court record filed
with the Court, even though this Court specifically ordered in November that

the record be supplemented.

      3. Upon realizing the absence of the decree, Counsel immediately

took measures to ensure that the record is supplemented properly as

previously ordered by this Court.

      3. Due to the absence of a material court record, good cause exists to

grant this motion.

      4. This extension is not sought for the purposes of delay but rather so

that the ends of justice may be served.

      WHEREFORE, T.B.F., appellant, prays that this motion be granted

and that the time to file her brief be extended to January 2, 2016.



                                          Respectfully submitted,

                                          s/ Juliane Crow
                                          ___________________________
                                          Juliane Crow
                                          TBN: 24000652
                                          PO Box 10152
                                          Houston, Texas 77206
                                          (281) 382-1395; Fax: (713) 422-2389
                                          Email: jpcrow@yahoo.com

                                          Attorney for Appellant, T.B.F.
                    CERTIFICATE OF CONFERENCE

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

J. Hazeltine-Shedd, is unopposed to this motion.

                                             /s/ juliane crow
                                             ______________________
                                             Juliane P. Crow


                       CERTIFICATE OF SERVICE

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

served on Robert J. Hazeltine-Shedd, appellee counsel, and William M.

Thursland, counsel for appellant B.E.B., by electronic delivery on

December 2, 2015.



                                             /s/ juliane corw
                                             ________________________
                                             Juliane P. Crow
