                                                                                           ACCEPTED
                                                                                       01-15-00932-CV
                                                                            FIRST COURT OF APPEALS
                                                                                    HOUSTON, TEXAS
                                                                                  12/4/2015 3:46:55 PM
                                                                                 CHRISTOPHER PRINE
                                                                                                CLERK

                      NO. 01-15-00931-CV
                      NO. 01-15-00932-CV
                      NO. 01-15-00933-CV              FILED IN
                                                1st COURT OF APPEALS
  __________________________________________________________
                                                    HOUSTON, TEXAS
                                                             12/4/2015 3:46:55 PM
                 IN THE COURT OF APPEALS        CHRISTOPHER A. PRINE
              FOR THE FIRST JUDICIAL DISTRICT         Clerk

                   OF TEXAS AT HOUSTON
 ___________________________________________________________

               IN THE MATTER OF A.C., Appellant
 ___________________________________________________________

                              A.C., Appellant

                                      v.

                    THE STATE OF TEXAS,
                           Appellee
  _________________________________________________________

                On Appeal from the 315th District Court
                         Harris County, Texas
     Tr. Ct. Cause Nos. 2015-01921J, 2015-02194J & 2015-02097J
  _________________________________________________________

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

TO THE HONORABLE JUSTICES OF THE COURT OF APPEALS:

      A.C., appellant, moves the Court to extend the time to file his brief be

extended to Thursday, December 31, 2015 and in support thereof

respectfully shows:

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

December 3, 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 were 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, A.C., appellant, prays that this Honorable Court

extend the time to file his brief to December 31, 2015.

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

                                      Attorney for Appellant A.C.


                   CERTIFICATE OF CONFERENCE

      Pursuant to TRAP 10.1(a)(5), I certify that Appellee’s counsel, Alan
Curry, is unopposed to this motion.
                                      /s/ william m thursland
                                      ______________________
                                      William M. Thursland



                      CERTIFICATE OF SERVICE

      I certify that on December 4, 2015 a true and correct copy of the
foregoing pleading was served appellee’s counsel, the Harris County District
Attorney’s Office, by fax to (713) 755-5809.


                                      /s/ william m thursland
                                      ________________________
                                      William M. Thursland
