Alicia Glenny v. Jeremy Epperson

ACCEPTED 15-25-00160-CV NOTICE: THIS DOCUMENT FIFTEENTH COURT OF APPEALS CONTAINS SENSITIVE DATA AUSTIN, TEXAS 12/12/2025 2:45 PM Court of Appeals Number: 15-25-00160-CV CHRISTOPHER A. PRINE Trial Court Case Number: D-1-FM-23-007793 CLERK IN THE INTEREST OF O.G., A CHILD FILED IN 15th COURT OF APPEALS AUSTIN, TEXAS ALICIA GLENNY, § IN THE COURT OF2:45:56 12/12/2025 APPEALS PM Petitioner/Appellant, § CHRISTOPHER A. PRINE § FOR THE FIFTEENTH DISTRICT Clerk v. § § OF TEXAS AT AUSTIN JEREMY EPPERSON, § Respondent/Appellee. § _________________________________________ FIRST OPPOSED MOTION FOR EXTENSION OF TIME TO FILE APPELLANT'S BRIEF / COMPLY WITH COURT NOTICES _________________________________________ TO THE HONORABLE JUDGES OF SAID COURT: COMES NOW, Appellant ALICIA GLENNY, pro se, files this First Opposed Motion for Extension of Time to File Appellant's Brief / Comply with Court Notices pursuant to Tex. R. App. P. 10.1(a)(4), 10.5(b), and 35.3(b)(2). In support, Appellant shows: 1. The Reporter's Record was due on December 5, 2025, but remains outstanding, as noticed by the Court on December 9, 2025. Tex. R. App. P. 35.3(b)(2) (requiring appellant to pay for preparation).

2. On December 9, 2025, the Court noticed Appellant for nonpayment of the $205 appellate filing fee. Tex. R. App. P. 20.4(a).

3. On November 18, 2025, Appellant filed a Statement of Inability to Afford Payment of Court Costs or an Appeal Bond in the trial court (Cause No. D-1-FM-23-007793). Tex. R. Civ. P. 145.

4. On November 19, 2025, Appellant filed Petitioner's Motion for Indigency Determination in the trial court, detailing material financial changes due to job loss on October 7, 2025. Tex. R. Civ. P. 145.001(c).

ITIO O.G. – A Child First Opposed Motion for Extension of Time to File Page 1 of 3 NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA

5. Appellant set a hearing on these motions for December 3, 2025, and filed a Motion to Appear Remotely on November 19, 2025, due to Nevada residency, lack of travel funds, childcare constraints, and Appellee's refusal to consent. Tex. R. Civ. P. 21(b).

6. Appellant filed a duplicate Statement of Inability to Afford Payment of Court Costs or an Appeal Bond with this Court on November 19, 2025. Tex. R. App. P. 20.1(b)(1).

7. The trial court declined to rule on submission for the Motion to Appear Remotely, resulting in no rulings on indigency or costs due to Appellant's inability to appear in person.

8. On December 9, 2025, Appellant received notice that the Clerk's Record was filed.

9. On December 9, 2025, Appellant requested trial-court rulings by submission on the indigency motions, which remain denied.

10. To date, Appellant's indigency filings remain uncontested. Tex. R. Civ. P. 145.001(e) (requiring contest within specified time).

Good Cause Exists. The delay stems from unavoidable indigency proceedings and trial-court inaction, not negligence. Tex. R. App. P. 10.5(b)(1)(A)-(C) (extension for good cause: accident/delay, diligence, no prejudice). Appellant has acted diligently amid financial hardship and seeks only a 45-day extension to resolve payment issues and prepare the brief upon record completion. No injury results to Appellee. See Verburgt v. Dorner, 959 S.W.2d 615, 616-17 (Tex. 1997) (first extension reasonable if good cause shown).

WHEREFORE, Appellant requests: (1) a 45-day extension to January 27, 2026, to file the brief and comply with the Reporter's Record notice; (2) an order directing the trial court to rule on indigency; and (3) all other relief.

DATED this 12th day of December 2025.

Respectfully submitted, /s/________________________ Alicia Glenny (pro se Petitioner/Appellant) ITIO O.G. – A Child First Opposed Motion for Extension of Time to File Page 2 of 3 NOTICE: THIS DOCUMENT CONTAINS SENSITIVE DATA

15792 Fawn Lane Reno, NV, 89511 530.414.1622 [email protected] CERTIFICATE OF SERVICE I certify that by my signature above, that on DECEMBER 12, 2025, a true and correct copy of this First Opposed Motion for Extension of Time to File Appellant's Brief / Comply with Court Notices was served in accordance with Tex. R. App. P. 9.5 on all registered parties via the Electronic Filing Manager and by email to: Jeremy J. Epperson 2103 Lear Lane Austin, Texas 78745 314.221.1755 [email protected] pro se Respondent/Appellee Additionally, in accordance with Tex. Civ. Prac. & Rem. Code § 51.017, a copy was served on the court reporter responsible for the reporter’s record for the hearings in this cause by email to: Carissa Crocker Angie Hertel 512.854.9054 512.854.9350 [email protected] [email protected] Janis Simon Jill Albracht 512.854.9306 512.854.9356 [email protected] [email protected] Stephanie Goodman [email protected] Alicia Dubois 512.854.9301 [email protected]

ITIO O.G. – A Child First Opposed Motion for Extension of Time to File Page 3 of 3 Automated Certificate of eService This automated certificate of service was created by the efiling system.

The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules.

Envelope ID: 109049393 Filing Code Description: Motion - Exempt Filing Description: First Opposed Motion for Extension of Time to File Appellant's Brief / Comply with Court Notices Status as of 12/12/2025 3:04 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Alicia Glenny [email protected] 12/12/2025 2:45:56 PM SENT Jeremy J.Epperson [email protected] 12/12/2025 2:45:56 PM SENT