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
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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
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15792 Fawn Lane
Reno, NV, 89511
530.414.1622
aliciakayglenny@gmail.com

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
eppersonconsultant@gmail.com

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
carissa.crocker@traviscountytx.gov angie.hertel@traviscountytx.gov

Janis Simon Jill Albracht
512.854.9306 512.854.9356
janis.simon@traviscountytx.gov jill.albracht@traviscountytx.gov

Stephanie Goodman
st.goodman@outlook.com

Alicia Dubois
512.854.9301
Alicia.Dubois@traviscountytx.gov

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 aliciakayglenny@gmail.com 12/12/2025 2:45:56 PM SENT

Jeremy J.Epperson jeremy@conversionadvocates.com 12/12/2025 2:45:56 PM SENT