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
-5- 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.
-6- 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).
-8- 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
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
- 10- 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.
- 12- 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
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
- 14- 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.
- 16- 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
- 17- 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
- 18- 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
- 19- 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.
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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
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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.
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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.
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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).
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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
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