In the Interest OF X.H.Q., a Child v. the State of Texas

CourtListener 10661530Txctapp520 ago 2025

Testo completo

IN THE
FIFTH DISTRICT COURT OF APPEALS
AT DALLAS
rILED iN
pppe&S
Court of
No. O5-25-00729-CV
MiS 20 2025
Ruben Modfl.
District
Clerk, Stt’
Anthony Quinones, Appellant,

V.

State of Texas, Appellee.

AMENDED APPELLANT’S BRIEF
On Appeal from Trial Court Cause No. DF-24-17475 303rd
Judicial District Court, Dallas County, Texas
The Honorable LaDeitra Adkins, District Judge

Anthony Quinones
2857 W Walnut Hill Ln apt 2095
irving, TX 75038
Phone 315-775-1515
antlrnnv.rsantos4 8.’Zl vahoo.com
TABLE OF CONTENTS
Page
IDENTITY OF PARTIES AND COUNSEL 2

INDEX OF AUTHORITIES 4

STATEMENT OF THE CASE 5

STATEMENT OF JURISDICTION S

ISSUES PRESENTED 9

STATEMENT OF FACTS 10

SUMMARY OF THE ARGUMENT 12

ARGUMENT AND AUTHORITIES 13

PRAYER FOR RELIEF 17

APPENDIX 20
IDENTITY OF PARTIES AND COUNSEL

The following constitutes a list of all parties to the trial court’s final judgment and
the names and addresses of all trial and appellate counsel:

Petitioner: Name Anthony Quinones
Address

Petitioner’s trial Name Anthony Quinones
counsel: Address 2857 W Walnut Hill Ln apt 2095 Irving,
TX 75038
Telephone 315-775-1515
Fax
E-mail

Petitioner’s appellate Name
counsel: Address
Telephone
Fax
E-mail

Respondent: Name The State of Texas (Office of the Attorney
General, Child Support Division)
Address

Respondent’s trial Name Office of the Attorney General of Texas —

counsel: Child Support Division
Matthew Deal
Deterrean Gamble
Nicole Loya
Telephone 214-752-5508
Fax
E-mail

Respondent’s Name Office of the Attorney General Child
—

appellate counsel: Support Division
Address OAG, Child Support Division, 400 S.

-2-
Zang Blvd., Suite 1100, Dallas, TX 75208
Telephone (512) 460-6000
Fax (512)460-6080
E-mail

Other parties: Emily Velasquez (Obligee/Mother)
(if applicable)

Counsel for other Name
parties: Address
Telephone
Fax
E-mail

INDEX OF AUTHORITIES
CASES Page

Dubai Petroleum Co. v. Kazi,

12S.W.3d71 (Tex.2000) pp.7,13,15

Tex. Dep’t of Parks & Wildlife v. Miranda,

133 S.W.3d 217 (Tex. 2004) pp. 7, 13

Mullane v. Central Hanover Bank & Trust Co.,

339U.S.306(1950) pp.14

Wilson v. Dunn,

800 S.W.2d 833 (Tex. 1990) pp. 14

STATUTES AND OTHER AUTHORITIES

Tex. Fam. Code § 159.603 pp. 10, 12, 13-14

Tex. Farn. Code § 159.605 pp. 9, 14

U.S. Const. amend. XIV p. 14

Tex. Civ. Prac. & Rem. Code § 51.012 p. 8

Tex. Farn. Code § 109.002 p. 8

RULES

Tex. R. App. P. 9.4 p. 19 (Certificate of Compliance)

-4-
STATEMENT OF THE CASE

Nature of the case: This is a UIFSA registrationlmodification proceeding filed

by the Texas Office of the Attorney General (Title IV-D) to

register an Arizona consent decree (Feb. 23, 202fl that

reflected no child-support obligation and $0.00 arrears,

and to impose support in Texas under the label of

“modification.” Mr. Quinones specially appeared and filed

jurisdictional contests, asserting (i) no existing foreign

support order to register/modify, (ii) lack of proper service

of any notice of registration, and (iii) due-process defects.

The obligee’s filings acknowledged no current support

order.

Disposition in the On April 24, 2025, an Associate Judge of the 303rd
trial court:
District Court signed an Order Confirming Registration

and in Suit for Modification of Child Support Order

(UIFSA), setting current child support at $431/month and

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medical support at $250/month. Mr. Quinones promptly

filed a motion to contest registration and modification and

sought a stay. A de novo setting was held before the

referring court on May 16, 2025: no new district-judge

order was signed, and Mr. Quinones preserved all

jurisdictional objections. He filed his notice of appeal.

Disposition in the The appeal is docketed in the Fifth Court of Appeals,
co art of appeals:
No. 05-25-00729-CV. The clerk’s record and the reporter’s

record from the May 1 6, 2025 setting are before the

Court. No appellate disposition has issued; briefing is

pending.

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STANDARD OF REVIEW

Whether a trial court possesses subject-matter jurisdiction is a question of law

reviewed de novo. Tat Dept ofPar/cs & Wi/dli,fè v, Miranda, 133 S.W.3d 217,

226 (Tex. 2004).

Subject-matter jurisdiction cannot be conferred by waiver, consent, or estoppel. If

the trial court lacked jurisdiction, its order is void and must be vacated. Dubai

Petroleum Co v. Kazi, 12 S.W.3d 71, 76—77 (Tex. 2000).

Because Appellant challenges the trial court’s authority under the Uniform

Interstate Family Support Act (UIFSA) to register and “modify” when no

enforceable support order existed, this Court reviews de novo and should

declare the April 24, 2025 order void.

-7-
STATEMENT OF JURISDICTION

This Court has jurisdiction under Tex. Civ. Prac. & Rem. Code §

51.012 and Tex. Fam. Code § 109.002. The order appealed is the April 24, 2025

“Order Confirming Registration and in Suit for Modification of Child

Support Order (UIFSA)” (CR 203—06). Appellant timely filed notice of appeal

on June 13, 2025 (CR 239).

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ISSUES PRESENTED

UIFSA Subject-Matter Jurisdiction

Did the trial court err by confirming registration and modifying where no

enforceable child-support order existed in the issuing state, contrary to Tex.

Fam. Code § 159.603?

[ Defective Notice of Registration (Due Process)

Did jurisdiction fail to vest where the “Notice of Registration of Foreign Support

Order” (CR 76) was never served on Appellant and bears irregularities

(including no file-stamp date), contrary to Tex. Fam. Code § 159.605(a)?

LI Creation of a New Obligation in a Registration Proceeding

Did the court exceed its statutory authority by creating a support obligation even

though the obligee’s filings reflect no current support order (CR 61, 67) and the

registration materials state S0.O0 arrears (CR 76)?

LI Waiver of Service / Special Appearance

Did the court err in treating Appellant’s Waiver of Service (CR 125—26) as a

general appearance where Appellant timely and repeatedly challenged jurisdiction

(CR 130, 134, 222) and subject-matter jurisdiction cannot be waived?
STATEMENT OF FACTS

1. The family’s Arizona dissolution decree (February 23, 2021) did not impose

a child-support obligation. The record reflects SO.0O arrears in the OAG’s

registration packet (CR 76) and the obligee’s filings deny any current

support order (CR 61, 67).

2. On or about December 4, 2024, the OAG initiated registrationlmodification

proceedings in Dallas County. The packet includes a “Notice of

Registration of Foreign Support Order” (CR 76) and transmittal materials

(CR 75—79).

3. The Notice of Registration in the record does not bear a file-stamp date,

and Appellant was never served with that notice as UIFSA requires

(CR 75—79).

4. Appellant filed timely jurisdictional challenges, including Motion to

Challenge Subject-Matter Jurisdiction (CR 130), Request for Judicial

Notice (CR 134), Motion to Contest Registration &

Modification (CR 222), and related filings.

5. The registration materials and the § 105.006 information sheet in the April

24, 2025 order reflect Social Security number endings that do not match

Appellant, creating an identity irregularity within the record. This

discrepancy, combined with the absence of a file-stamp on the “Notice of

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Registration” and lack of service, underscores a defective registration and

notice process. (CR 75—79, 203—06).

6. Despite the absence of an enforceable obligation, the Associate Judge signed

an “Order Confirming Registration and in Suit for Modification of

Child Support Order (UIFSA)” on April 24, 2025 (CR 203—06), imposing

support and medical suppor.

7. A de novo hearing was set and a reporter’s record prepared (RR Vol. 1, May

16, 2025). Appellant preserved jurisdictional objections and pursued appeal.

Appellant filed notices of appeal on April 28, 2025 (CR 234) and June 13,

2025 (CR 239).

- H -
SUMMARY OF THE ARGUMENT

The trial court lacked jurisdiction under UIFSA to register/modify because the

record shows no enforceable foreign support order existed. The OAG’s

registration packet reflects $0.00 arrears (CR 76) and the obligee’s sworn filings

indicate no current support order (CR 61, 67). Tex. Fam. Code §

159.603 authorizes registration of an existing support order—not the creation of

a new obligation.

Jurisdiction also failed because the Notice of Registration (CR 76) was never

served and is irregular (no file-stamp date), violating § 159.605(a). Without

proper service, the court could not acquire jurisdiction to confirm, enforce, or

“modify.”

Finally, the court exceeded UIFSA authority by creating a support

obligation within a registration proceeding. And Appellant’s Waiver of Service

(CR 125—26) cannot cure subject-matter defects; he preserved jurisdictional

objections in multiple filings (CR 130, 134, 222). The April 24, 2025 order (CR

203—06) is void and must be vacated.

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ARGUMENT AND AUTHORITIES

I. Dc Novo Review Applies to Jurisdiction

Whether a court has subject-matter jurisdiction is reviewed de novo.Mirandc,, 133

S.W.3d at 226. Ifjurisdiction is absent, the order is void and must be

vacated. Duhai Petro/euni, 12 S.W.3d at 76—77.

II. UIFSA Allows Registration Only of an Existing Support Order; None

Existed Here

UIFSA authorizes registration of a foreign support order for

enforcement/modification. Tex. Fam. Code § 159.603. The record shows no

existing obligation to register:

• OAG’s packet lists $0.00 arrears (CR 76).

• The obligee’s sworn “General Testimony” filings indicate no current

support order (CR 61, 67).

Because no enforceable support order existed, Texas lacked subject-matter

jurisdiction to “confirm registration” or to modify. The court erred by entering

the April 24, 2025 confiniation/modification order (CR 203—06).

III. Lack of Proper Notice of Registration Deprived the Court of Jurisdiction

1l
- 1.) -
U1FSA requires that the nonregistering party be served with notice of

registration. Tex. Fam. Code § 159.605(a). The record copy of the notice

(CR 76) bears no file-stamp date, and Appellant was never served with it

(CR 75—79). Without proper notice, the court could not obtain jurisdiction to

confirm/enforce or modify. See, e.g., Wilson v. Dunn, 800 S.W.2d 833, 836 (Tex.

1990) (proper service is fundamental to jurisdiction). UIFSA requires strict

compliance with notice and accurate identifying information in the registration

packet. See Tex. Earn. Code § 159.602—.605. Here, the record shows a notice with

no file-stamp and no service on Appellant, and it contains mismatched SSN data

undermining reliable identification. Those defects together denied due process and

prevented jurisdiction from vesting. See Wilson v. Dunn, 800 S.W.2d 833, 836

(Tex. 1990).

In addition to statutory notice, due process requires notice reasonably calculated to

apprise the patty and an opportunity to be heard; the combination of missing file-

stamp, lack of service, and identity discrepancy fails that standard. See U.S. Const.

amend. XIV; Mid/one v. Cent. Hanover Bank & Tr, Co.. 339 U.S. 306, 3 14—15

(1950).

IV. The Court Created an Obligation in a Registration Proceeding—UIFSA

Prohibits That

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A registration action under § 159.603 is for enforcement (and, if the statute’s

prerequisites are met, modification of an existing order). It does not authorize

creation of a new child-support obligation where none exists. The record shows:

• The obligee’s forms deny any current support order (CR 61, 67).

• The OAG’s notice states S0.00 arrears (CR 76).

• Yet the court imposed new support obligations on April 24, 2025 (CR 203—

06).

This exceeded the tribunal’s statutory authority and requires vacatur.

V. Waiver of Service Does Not Confer Subject-Matter Jurisdiction;

Objections Were Preserved

Appellant signed a Waiver of Service (CR 125—26), but subject-matter

jurisdiction cannot be waived or created by consent. Dubai Petroleum, 12

S.W.3d at 76—77. Appellant timely and repeatedly contested

jurisdiction (CR 130, 134, 222). The court’s order is therefore void and must be

vacated.

RELIEF REQUESTED

Because the trial court lacked jurisdiction under IJIFSA, failed to ensure proper

registration notice, and exceeded its statutory authority by creating a support

- 15 -
obligation in a registration proceeding, the April 24, 2025 Order (CR 203—06)

is void and must be vacated.

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PRAYER FOR RELIEF

Appellant, Anthony Quinones, respectfully prays that this Court:

1. Vacate the April 24, 2025 “Order Confirming Registration and in Suit

for Modification of Child Support Order (UIFSA)” entered in Cause

No. DF-24-1 7475 by the 303rd Judicial District Cour of Dallas County,

Texas (CR 203—06);

2. Reinstate and give full faith and credit to the Arizona decree reflecting no

enforceable support obligation, as evidenced in the registration materials

(CR 75—79) and obligee filings (CR 61, 67);

3. Declare that no enforceable Texas child-support obligation exists against

Appellant arising from this registration action; and

4. Grant such other and further relief to which Appellant may’ be justly entitled.

Respectfully submitted,

Name Anthony Quinones
Address 2857 W Walnut Hill Ln apt
2095 Irving, TX 75038
Telephone No. 315-775-1515
Facsimile No.
E-mail address
Pro Se

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AMENDED CERTIFICATE OF SERVICE

In accordance with the Texas Rules of Appellate Procedure I certify that a
copy of this Appellant Brief was served on Respondent The Attorney General of
Texas through counsel of record, in person on August 20, 2025

Nrn6AØouiy Quinones
ProRe

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CERTIFICATE OF COMPLIANCE

Pursuant to TEX. R. APP. P. 9.4, I hereby certify that this Appellant
Brief contains 2006 words. This is a computer-generated document created in
Microsoft Word, using 14-point typeface for all text, except for footnotes which
are in 12-point typeface. In making this cer ificate of compliance, I am relying on
the word count provided by the software used to prepare the document.

/
/4//
Name Aflhhony Quinones
Pro Se

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Docusign Envelope ID: 8B39B21 E-9D94-4A2A-A2F3-5298D6A2DD04

NOTICE: TFIIS DOCUMENT CONTAINS SENSITIVE I)ATA
NC P Name: A NT/ION V OL/IiVOVES
CP Name: E7tJ]L)’ iTLISQL7EZ
OAG Number: 0014623286
CAUSE NUMBER DF-24-1 74 75

IN THE INTEREST OF IN THE 303RD DJSTRJCTCOURT

AjO;L4RA HA/LIE QUJNOiVES OF
A CHILD DALLAS COUNTY, TEXAS

ORDER CONFIRMING REGISTRATION AND IN SUIT FOR MODIFICATION OF

CHILD SUPPORT ORDER (UIESA)
On the 24th day of April, 2025, the Court held a hearing in ibis cause.
The Office of the Attorney General appeared by its Attorney of Record.
Atv’TI-IONYQUINONES, the Jet/her of the child, is the Obligor, and appeared prose virtually.

It is FOIJNI) that EMILY VELASQUEZ, the ,no/he, of the child, is the Obligee.

It is FOUNI) pursuant to Texas Family Code Chapter 159. that this court has, or assumes, jurisdiction over
ANTI-/ONY QUINONES and the subject matter of this suit.

A record of the proceedings was made by Court Reporter, ORALIA GUZMAN.

CHILDREN
The following child is the subject of this suit:

Name Se boB SSN

XIOMAR ItAIt!E OUINONES F 713’2018 xxx-xx-x230

REGISTRATION OF ORDERS
It is FOUND that the validity of one or more of the foreign Orders registered in this ease was contested. After
hearing the evidence and argument of counsel, IT IS FOUND thai the following order(s) is/are valid and enforceable:
Name of Order: CONSENT DECREE FOR DISSOLUTION OF MARRIAGE WITH MINOR CHILD
Date: February 23, 2021 Court: Superior Court of Arizona
Cause No. FC2OI9-098395 County: Marieopa State: AZ
AlL Orders listed above are attached hereto.
IT IS ORDERED that the above order(s) is (are) CONFIRMED.
It is FOUND that the order entitled CONSENT DECREE FOR DISSOLUTION OF MARRIAGE WITH MINOR
CHILD, dated 2/23/2021, selling support in the amount of $0.00 per month is the order that controls the amount of
prospective support.

Order Confirming Registration and in Suit for Modification of Child Support Order (UIFSA) Page I of 13
Docusign Envelope ID: 8B39B21 E-9D94-4A2A-A2F3-5296D6A2DD04

ARREARACES
It is FOUND and CONFIRMED that ANTHONY QU1iVONES is in aicars in the amount of 50.00 as of April 24,
2025. This includes all child support unpaid and owing and any unpaid balance owed on previously confirmed arrearages
or retroactive support judgments as of the specified date.

MODIFICATION OF SUPPORT ORDER
It is FOUND that since rendition of the support and health care coverage order entitled CONSENT DECREE FOR
DISSOLUTION OF MARRIAGE WITH MINOR CUILD signed on February 21, 2021 there has been a material and
substantial change in the circumstances of the child or parties. or it has been three years since the order was rendered or
last modified and the monthly amount of the child support award under the order differs by either 20 percent or $100 from
the amount that would be awarded in accordance with the child support guidelines, which warrants the following
inodi tication of the existing support order.

Order Confirming Registration and in Suit for Modification of Child Snpport Order (UIFSA) Page 2 of 13
Docusign Envelope ID: BB39B21E-9D94-4A2AA2F3-5298D6A2DD04

FINDINGS REGARDING MEDICAL SUPPORT, DENTAL SUPPORT, AND ChILD SUPPORT
OBLIGATIONS

Ii is FOUND:
A1VTHONYQU/NONES’s gross monthly resources are $2,782.00.
Reasonable cost, based upon 9°¼ of ANTI-tONY QUINONESc gross monthly resources is 5250.42
A2VTHONYQUINONES is obligated to provide support for the following:

(A) The number of children before the court is one (I).
(B) The number of minor children not before the court residing in the same household with
ANTHONY QUINONES is zero (0).
(C) The number of children not before the court for whom ANTHONY QUINONES is obligated by a
court order to provide medical support, and who are not counted under Paragraph (A) or (B) is
zero (0/).
(D) The number of children not before the court for whom ANTHONY QUINONES is obligated by a
court order to provide dental support, and who are not counted under Paragraph (A) or (B) is
zero (0).
(E) The number of children not before the court for whom ANTHONY QLI/NONES is obligated by a
court order to provide child support, including those counted in (C) above, and who are not
counted under Paragraph (A) or (B) is zero (0).

EAuIL}’ VELASQUEZ provides health insurance coverage for zero (0) other minor children.
EMILY VELASQUEZ provides dental insurance coverage for zero (0) other minor children.

MEDICAL SUPPORT
(MORE THAN ONE OPTION MAY BE APPROPRIATE)
U I. Health insurance is available or is in effect for the child through the following parents employment or
membership in a union, trade association, or other organization at a reasonable cost to
ANTHONY Q U/NONES:
U EMILY VELASQUEZ at an actual cost of S per month.
U ANTHONY QUINONES at an actual cost of S per month.
U EMILY VELASQUEZ through the United States Armed Forces (TRICARE).
U ANTHONY QUINONES through the United States Armed Forces (TRICARE).

U 2. Health insurance is not available under option #1, or good cause exists to vary from #1, and health
insurance is availahle to the following parent from another source at a reasonable cost to
ANTHONY Q U/NONES:
U EMILY VELASQL/EZat an actual cost of$ per month.
o ANTHONY QL.TVONES at an actual cost of $ per month.

3. No parent has access to private health insurance at a reasonable cosi or good cause exists to vary from #1
or #2.

U 4. Notwithstanding the findings made above, it is FOUND that good cause exists to deviate from the
statutory priorities in ordering health insurance for the following reason(s):

Order Confirming Registration and in Suit for Modification of Child Support Order (UIFSA) Page 3 of 13
Docusign nveIcpe ID: BB39821 E-9D94-4A2A-A2F3•5298D6A2DD04

DENTAL SUPPORT
(MORE THAN ONE OPTION MAY BE APPROPRIATE)
D 1. Dental insurance is available or is in effect for the child through the following parent’s employment or
membership in a union, trade association, or other organization at a reasonable cost to
ANTHONY OU!NOiVES:
O EMILY VELASQUEZ at an actual cost of S per month.
o ANTHONY QUI;VONES at an actual cost of S per month.
o EMILY VELASQUEZ through the United States Armed Forces (TRICARE).
0 ANTHONY QLI]NONES through the United States Armed Forces (TRIC’ARE).

0 2. Dental insurance is not available under option #1, or good cause exists to vary from #l,and dental
insurance is available to the following parent from another source at a reasonable cost to
ANTHONY QUINONES:
0 EMILY VELASQUEZ at an actual cost of $ per month.
0 ANTHONY QUINONES at an actual cost of $ per month.

3. No parent has access to private dental insurance at a reasonable cost therefore neither party is ordered to
provide dental itisurancc for the child.

0 4. Notwithstanding the Findings made above, it is FOUND that good cause exists to deviate from the
statutory priorities in ordering dental insurance for the following reason(s):

It is further FOUND that the following orders regarding health insurance and dental insurance are in the best
interest of the child.

CHILD SUPPORT FINDINGS
It is FOUND:
(1) the net resources of ANTHONY QUINONES per month are $2,155.22;
(2) the percentage applied to ANTHONY QUIWOVES’s net resources for child support is 20%.

Order Confirming Registration and in Suit for Modification of Child Support Order (UIFSA) Page 4 of 13
Docusign Envelope ID: BB39B21 E-9D94-4A2A-A2F3-5298D6A2DD04

GOVERNMENT MEDICAL ASSISTANCE PROGRAM OR HEALTH PLAN
EMILY VELASQUEZ is ORDERED to apply, within 15 days after entry of this order, on behalf of the child for
participation in a government medical assistance program or health p]an. Upon enrollment, EvIlLY VELASQUEZ is
ORDERED to maintain such health coverage in full force and effect for any child, subject of this suit, by payiTig any and
all applicable fees required for the coverage, including but not limited to. enrollment fees, and premiums until the first of
the following events occurs for the child:
1. the child reaches the age of eighteen years or graduates from high school, whichever occurs later, subject
to the provisions for support beyond the age of eighteen years set out below:
2. the child marries:
3. the child dies:
4. the child enlists in the armed forces of the United States and begins active service as defined by section 101 of
title 10 of the United States Code; or
5. the child’s disabilities are otherwise removed for general purposes.

If the child is eighteen years of age and has not graduated from high school, IT IS ORDERED that this obligation
shall not terminate but shall continue for as long as the child is enrolled

1. under chapter 25 of the Texas Education Code in an accredited secondary school in a program leading toward a
high school diploma or under section 130.008 of the Education Code in courses for joint high school and junior
college credit and is complying with the minimum attendance requirements of subchapter C of chapter 25 of the
Education Code or
2. on a full-time basis in a private secondary school in a program leading toward a high school diploma and is
complying with the minimum attendance requirements imposed by that school.

EMILY VELASQUEZ is ORDERED to furnish ANTHONY QUINONES and the Office of the Attorney General
Child Support Division. a true and correct copy of the health insurance policy or certification and a schedule of benefits
within 30 days following the signing of this order.

EMILY VELASQUEZ is ORDERED to furnish ANTHONY QUINON’ES the insurance cards and any other forms
necessary for use oCthe insurance within 30 days following the signing of this order.

EMILY VELASQUEZ is ORDERED to provide, within three days of receipt by her, to ANTHONY QUINONES
any insurance checks, other payments, and/or explanations of benefits relating to any medical expenses for the child that
ANTHONY QUINONES incurred or paid.

Order Confirming Registration and in Suit for Modification of Child Support Order (UIFSA) PageS of 13
Docueign Envelope ID: BB39B2IE-9D94-4A2A-A2F3-5298D6A2DD04

CASH MEDICAL SUPPORT
Pursuant to Texas Family Code § 154.l82(b)(3). ANT [OW)’ QL/JNONES is ORDERED to pay
EMILY J’EL4SOUEZ cash medical support, as additional child support, of S250.OO each month, beginning the 1st day of

May. 2025, payable on or before the same day of each month thereafter until the earliest occurrence of one of the events
specified below happens for every child, subject of this suit:
1. thc child reaches the age of eighteen years or graduates from high school, whichever occurs later, subject to the
provisions for support beyond the age of eighteen years set out below:
2. the child marries;
3. the child dies;
4. the child enlists in the armed forces of the United States and begins active service as defined by section 101 of
title 10 of the United States Code; or
5. the child’s disabilities are otherwise removed for general purposes.

If the child is eighteen years of age and has not graduated from high school, IT IS ORDERED that the obligation
to pay medical support for that child shall not terminate but shall continue for as long as the child is enrolled

1. under chapter 25 of the Texas Education Code in an accredited secondary school in a program leading toward a
high school diploma or tinder section 130.008 of the Education Code in courses forjoint high school and junior
college credit and is complying with the minimum attendance requirements of subchapter C of chapter 25 of the
Education Code or
2. on a full-time basis in a private secondary school in a program leading toward a high school diploma and is
complying with the minimum attendance requirements imposed by that school.

ANTHONY QUINO.\ES is allowed to discontinue payment of cash medical support, for the period of time
ANTHONY QUJJVO1VES is providing coverage if:

(1) health insurance for the children becomes available to ,4VTHONY QUINONES at a reasonable cost: and
(2) ANTHONY QUINONES enrolls the child in the insurance plait; and
(3) ANTHONY QUINOWES provides EMILY VELASQUEZ. and the Office of the Attorney General. the Title IV
D agency, the information required under Texas Family Code § 154.185.

NO CREDiT FOR INFORMAL PAYMENTS
ANTHONY QUINONES is ORDERED to pay all cash medical support, if ordered, through the registry prescribed
in this decree, and any direct payments or any expenditures incurred during periods of possession shall be deemed in
addition to and not in lieu of the medical support ordered herein.

Order Confirming Registration and in Suit for Modification of Child Support Order (UIFSA) Page 6 of 13
Docusign Envelope ID: B539B21 E-9D94-4A2A-A2F34296D6A2DD04

ADDITIONAL HEALTH CARE EXPENSES
Pursuant to Texas Family Code §154.183(c). additional health care expenses to be allocated between the parties
include the following:

(1) any reasonable and necessary health care expenses of the child, including vision and dental expenses, that arc
not reimbursed by insurance: and
(2) any amounts paid by either party as deductibles or copayments for health care services for the child.

Additional health care expenses, including vision and dental care expenses of the child are allocated as follows:

EMILY VELASQUEZ is ORDERED to pay 50% and ANTHONY QUINONES is ORDERED to pay 50% of
the total health care expenses, including vision expenses that exceed the amount of cash medical support ordered.
EUILY VELASQUEZ is ORDERED to pay 50% and ANTHONY QUINONES is ORDERED to pay 50% of
additional dental care expenses.
If the cash medical support is discontinued pursuant to the ‘CASH MEDICAL SUPPORT” provision because
ANTHONY QUJNONES obtains health insurance for the child, ANTHONY QUINONES shall be responsible for 100% of

the child’s total health care expenses incurred in any month in which he neither pays the cash medical support nor
provides health care coverage for the child.
The party who incurs a health care expense, including vision or dental care expcnse on behalf of the child, ts
ORDERED to submit to the non-incurring party(ies) all forms, receipts, bills, statements, and explanations of benefits
reflecting the expenses within 30 days after he or she receives them. The party shall itemize those expenses for which
payment or reimbursement is sought. Each non-incurring party who is also a parent is ORDERED to pay his or her share
or percentage of the expenses either by paying the provider directly or by reimbursing the incurring party within 30 days
after the non-incurring party receives the forms, receipts., bills, or statements.If the incurring conservator fails to furnish
to the non-incurring conservator the forms, receipts, bills, statements, and explanations of benefits reflecting the expenses
within 30 days after the incurring conservator receives them, the non-incurring conservator is ORDERED to pay the non-
incurring conservator’s percentage of the unreimbursed portion of the health care expenses either by paying the health

care provider directly or by reimbursing the incurring conservator for any advance payment exceeding the conservator’s
percentage of the unreimbursed portion of the health care expenses within 90 days after the non-incurring conservator

receives the forms, receipts, bills, statements, and/or explanation of benefits.

WARNING
A parent ordered to provide health insurance, or to pay additional child support for the cost of health
insurance who fails to do so is liable for 100% of necessary health care expenses, including vision or dental
expenses of the child, without regard to whether the expenses would have been paid if health insurance or denial
insurance had been provided, and the cost of health insurance premiums, denial insurance premiums, or
contributions, if any, paid on behalf of the child.

Order Confirming Registration and in Suit for Modification of Child Support Order (UIFSA) Page 7 of 13
Docusign Envelope ID: BB39B21 E.9D94-4A2A-A2F3-5298D6A2DD04

CURRENT CHILD SUPPORT
.1A’THONY QULVONES is ORDERED to pay EMiL V VELASQUEZ current child support of S431.00 each month

beginning the 1st day of May. 2025, payable on or before that date and on or before the same day of each month
thereafter until the first month following the date of the earliest occurrence of one of the events specified below:
I. any child reaches the age of eighteen years or graduates from high school, whichever occurs later,
subject to the provisions for support beyond the age of eighteen years set out below:
2. any child marries;
3. any child dies;
4. any child enlists Hi the armed forces of the United States and begins active service as defined by
sections 101 of title 10 of the United Slates (‘ode; or
5. any child’s disabilities are otherwise removed for general purposes.

Ifa child is eighteen years of age and has not graduated from highsehool, IT IS ORDERED that the obligation to
pay child support for that child shall not terminate but shall continue for as long as the child is enrolled:
I. under chapter 25 of the Texas Education Code in an accredited secondary school in a program leading toward a
high school diploma or under section 130.008 of the Education Code in courses for joint high school and junior
college credit and is complying with the minimum attendance requirements of subchapter C of chapter 25 of the
Education Code, or
2. on a full-time basis in a private secondary school in a program leading toward a high school diploma and is
complying with the minimum attendance requirements imposed by that school.

NO CREDIT FOR INFORMAL PAYMENTS
ANTHONY QUINO;VES is ORDERED to pay all child support through the registry prescribed in this decree, and
any direct payments by him or any expenditures incurred during his periods of possession shall be deemed in addition to
and not in lieu of the child support ordered herein.

Order Confirming Registration and in Suit for Modification of Child Support Order (UIFSA) Page 8 of 13
Docusign nveIope ID: 5B39B21E-9D944A2A-A2F3-5298D6A2DD04

PAYMENT OF SUPPORT AND COSTS
Pursuant to Texas Family (‘ode. Chapters 231 and 234, all support rights are assigned to the Title IV-D agency.
and ANTHONY QUINONES is ORDERED to pay all support through the State Disbursement Unit at:
Texas Child Support Disbursement Unit
PU Box 659791
San Antonio. TX 78265-9791
for distribution according to law. All payments shall be identified by:
Obligor name ANTHONY QUINONES,
Obligee name EMILY VELASQUEZ,
Office of the Attorney General case number 0014623286,
cause number DF-24-] 7475, and
the date on which the withholding occurred.
ANTHONY QUINONES is ORDERED to pay court costs AS BILLED to the District Clerk of DALLAS County,
Texas on or before the 24th day of June, 2025 directly to:
FELICIA PITRE
DIST CLK FAMILY FILE DESK
600 COMMERCE. 1ST FLOOR
DALLAS, TX 75202
INCOME WITHHOLDING
Pursuant to Texas Family Code Chapter 158 and § I 59305(b)(3j. any employer of ANTHONY QULVONES.
current or subsequent. is ORDERED to withhold income from (lie disposable earnings oCANTHONYQUINONES for the
child’s support as set out in the ORDER/NOTICE TO WITHHOLD INCOME FOR CHILD SUPPORT. Any income
withheld from ANTHONY QUINONES’s disposable earnings for child support and paid according to this order shall be
credited against his child support obligation, but shall not discharge any of his child support obligation that exceeds the
amount so credited.
It is FOUND that ANTHONY QUINONES is liable for all court ordered child support, regardless of the amouuts
withheld by any employer or entity, and ANTHONY QUINONES is ordered to pay any court ordered child support not
withheld by any employer or entity directly to the Texas Child Support Disbursement Unit as ordered.
The Clerk of the Court. upon request, is ORDERED to cause a certified copy of the ORDER/NOTICE TO
WITHHOLD INCOME FOR CHILD SUPPORT, with a copy of Texas Family Code Chapter 158 attached, to he
delivered to ANTHONY QULVONE.S’s employer.
ANTHONY QLJINONES is ORDERED to provide any subsequent employer with a copy of the ORDER/NOTICE

TO WITHHOLD INCOME FOR CHILD SUPPORT.
STATUTORY WARNINGS

FAILURE TO OBEY A COURT ORDER FOR CHILD SUPPORT OR FOR POSSESSION OF OR ACCESS TO A
CHILD MAY RESULT IN FURTHER LITIGATION To ENFORCE THE ORDER, INCLUDING CONTEMPT OF

Order Confirming Registration and in Suit for ModiFication of Child Support Order (UIFSA) Page 9 of 13
Docusign Envelope ID: BB39B21 E-9D94-4A2A-A2F3-5298D6A2DD04

COURT. A FINDING OF CONTEMPT IAY BE PUNISHED BY CONFINEMENT IN JAIL FOR UP TO SIX MONTHS. A
FINE OF UP TO S560 FOR EACH VIOLATION. AND A MONEY JUDGMENT FOR PAYMENT OF ATTORNEY’S FEES
AND COURT COSTS.
FAILURE OF A PART’ TO MAKE A CHILD SUPPORT PAYMENT TO THE PLACE AND IN THE MANNER
REQUIRED BY A COURT ORDER MAY RESULT IN THE PARTY NOT RECEIVING CREDIT FOR MAKING THE
PAYMENT.
FAILURE OF A PARTY TO PAY CHILD SUPPORT DOES NOT JUSTIFY DENYING THAT PARTY
COURT-ORDERED POSSESSION OF OR ACCESS TO A CHILD. REFUSAL BY A PARTY TO ALLOW POSSESSION
OF OR ACCESS TO A CHILD DOES NOT JUSTIFY FAILI’RE TO PAY COURT-ORDERED CIIILD SUPPORT TO
THAT PARTY.
EACH PERSON WHO IS A PARTY TO THIS ORDER IS ORDERED TO NOTIFY EACH OTHER PARTY, THE
COURT, AND THE STATE CASE REGISTRY OF ANY CHANCE IN THE PARTY’S CURRENT RESIDENCE ADDRESS,
MAILING ADDRESS, HOME TELEPHONE NUMBER, EMAIL ADDRESS, NAME OF EMPLOYER, ADDRESS OF
EMPLOYMENT, DRIVER’S LICENSE NUMBER, AND WORK TELEPHONE NUMBER. THE PARTY IS ORDERED
TO GIVE NOTICE OF AN INTENDED CHANGE IN ANY OF THE REQUIRED INFORMATION TO EACH OTHER
PARTY, THE COURT, AND THE STATE CASE REGISTRY ON OR BEFORE THE 60TH DAY BEFORE THE
INTENDED CHANGE. IF THE PARTY DOES NOT KNOW OR COULD NOT HAVE KNOWN OF THE CIIANGE IN
SUFFICIENT TIME TO PROVIDE 60-DAY NOTICE, THE PARTY IS ORDERED TO GIVE NOTICE OF THE CHANGE
ON OR BEFORE THE FIFTH DAY AFTER THE DATE THAT THE PARTY KNOWS OF THE CHANGE.
THE DUTY 10 FURNISH TIllS INFORMATION TO EACH OTHER PARTY, THE COURT, AND THE STATE
CASE REGISTRY CONTINUES AS LONG AS ANY PERSON, BY VIRTUE OF THIS ORDER, IS UNDER AN
OBLIGATION TO PAY CHILD SUPPORT OR ENTITLED TO POSSESSION OF OR ACCESS TO A CHILD.
FAILURE BY A PARTY TO OBEY THE ORDER OF THIS COURT TO PROVIDE EACH OTIIFR PARTY, TIlE
COURT AND. THE STATE CASE REGISTRY WITH CHANGE IN THE REQUIRED INFORMATION MAY RESULT IN
FURTHER LITIGATION TO ENFORCE THE ORDER. INCLUDING CONTEMPT OF COURT. A FINDING OF
CONTEMPT MAY BE PUNISHED BY CONFINEMENT IN JAIL FOR UP TO SIX MONTHS. A FINE OF UP TO 5500
FOR EACH VIOLATION, AND A MONEY JUDGMENT FOR PAYMENT OF ATTORNEY’S FEES AND COURT COSTS.

NOTICE TO THE STATE CASE REGISTRY
As is required by the preceding section, any change of a party’s residcntial address, mailIng address, home
telephone number, email address, name of employer, address of employment. driver’s license number, and work telcphone

number arc to be reported by mail to the:

State Case Registry
Contract Services Section
MC 046S
P.O. Box 12017
Austin, TX 78711-2017
in addition to reporting the change(s) to the other parties and the Court.

Order Confirming Registration and in Snit for Modification of Child Support Order (UIFSA) Page 10 of 13
Docusign nveIopo ID: BB39B21 E-9D94-4A2A-A2F3-5298D6A2DD04

REVIEW
Pursuant to 42 Usc 666(a)(I0). a parent subject to a child support order, at least every three years, has the right
to request a review of the ordered child support amounts by contacting the Child Support Division of the Office of the
Attorney General.

THE COURT MAY MODIFY THIS ORDER THAT PROVIDES FOR THE SUPPORT OF A CHILD, IF:

I. THE CIRCUMSTANCES OF THE CHILD OR A PERSON AFFECTED BY THE ORDER HAVE

MATERIALLY AND SUBSTANTIALLY CHANGED; OR

2. IT HAS BEEN THREE YEARS SINCE THE ORDER WAS RENDERED OR LAST MODIFIED AND THE
MONTHLY AMOUNT OF THE CHILD SUPPORT AWARD UNDER THE ORDER DIFFERS BY EITHER 20

PERCENT OR 5100 FROM THE AMOUNT THAT WOULD BE AWARDED IN ACCORDANCE WITH THE
CHILD SUPPORT GUIDELINES.

Order Confirming Registration and in Suit for Modification of Child Support Order (UIFSA) Page II of 13
Docusign nveIope ID: BB39B21E-9D944A2A2F3-5298D6A2DDO4

INFORMATION PURSUANT TO TEXAS FAMILY CODE § 105.006
Court: 303RD DISTRICTCOURTDALLAS County, Texas
Cause Number: DF-24-J 7475
PRIMARY JOINT MANAGING or MANAGING CONSERVATOR I OBLIGEE INFORMATION:
Name: EMILY VELASQUEZ
Residence Address: 904 NACA CIA AVE
COMP TON CA 90220-2239-99
Mailing Address (if different):
Social Security Number: xxx-xx-x60 7
Driver License Number:
Home Phone:
Email Address: EMIL Y VELASQUEZ98@GIVL4IL. COM
Employer:
Employment Address:

Work Phone:
JOINT MANAGING or POSSESSORY CONSERVATOR I OBLIGOR INFORMATION:
Name: ANTHONY QLJINONES
Residence Address: 2857 IV TIALNUT [-[ILL LN
APT 2095
IRVING TX 75038-5284-99
Mailing Address (if di f’ferenl):
Social Security Number: xx-xx-x533
Driver License Number: xxxxx445
Home Phone:
Email Address: ANTHONY.RSANTOS48@YAHOO.COM
Employer: MCKESSON MEDICAL SURGICAL INC
Employment Address: 6555 STATE HIGHWAY 161
IR VThJG TX 75039-2402-55
Work Phone:
Expected termination date of obligation to pay child support and of orders for possession of, or access to, a
child (date of expected emancipation of all minors): July 3. 2036.

The Court has iiol ordered that special restrictions be placed on the distribution of this infonation pursuant
to Texas Family Code § 105.006(c).

Order Confirming Registration and in Suit for Modification of Child Support Order (UIFSA) Page 12 of 13
Docusign Envelope ID: BB39B21 E-9D94-4A2A-A2F3-5298D6A2DD04

4/24/2025
Date Signed:

Dociasigned by:

3C Feeonet-42D
ASSOCIATE JUDGE PRESIDING

Cause Number DF-24- 17475; DALLAS County. Texas

faS4td Atap
GABRIELLE R. GEORGE SBN 24098379 -

GABRIEL ARTEAGA SBN 24096734 -

JOYCE NWACIIUKWU SBN 24070347 -

MARIANNE T. WARREN SFIN 00785183 -

JECICA BROWN-MITChELL SI3N 24136766 -

HALEY POLK SBN 24140176
-

KAMERON DAVIS-STEPHENS SRN 24120427 -

IIEATFIER IKEJIANI SBN 24091979 -

DONNA SCIIARDT SBN 17727450-

MORGAN BRIDGEWATER S[3N 24118338 - --

LOGAN NUTT SBN 24098186
- ANThONY QUINONES, Obligor
ASHLEY PhILIP SBN 24090951
-

KAREN E. YOUNG SBN 22199500-

Attorney of Record
Child Support Division
400 S ZANG BLVD
SUITE 1100
DALLAS, TX 75208-6646
Email CSD-Legal-4 1 3@oag.texas.gov
Telephone No. (214)752-5508
Toll Free 1(800)252-8014
FAX No. (214)583-6252

Order Confirming Registration and in Suit for Modification of Child Support Order (UIFSA) Page 13 of 13

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