On March 24, 2023 a
Motion for Nunc Pro Tunc
was filed
involving a dispute between
Quiroz De Salinas, Altagracia,
and
Salinas, Reynaldo,
for Divorce - No Children (OCA)
in the District Court of Hidalgo County.
Preview
Electronically Filed
12/13/2023 1:36 PM
Hidalgo County District Clerks
Reviewed By: Rachel Bueno
CAUSE NO. F-l l74-23-H
INTHE MATTER 0F § 1N THE DISTRICT COURT
THE MARRIAGE 0F §
§
ALTAGRACIA QUIRoz DE SALINAS §
389T” JUDICIAL DISTRICT
AND §
REYNALDO SALINAS § HIDALGO COUNTY, TEXAS
MOTION FOR JUDGMENT NUNC PRO TUNC
TO THE HONORABLE JUDGE OF SAID COURT:
NOW COMES, REYNALDO SALINAS, Respondent in the above-entitled and
numbered cause and files this his Motion for Judgment Nunc Pro Tunc and would show the
Coun as follows:
The Agreed Temporary Orders entered by the Court on November 1, 2023 were not
approved by Respondent and his counsel and has some clerical errors which are not in
accordance with judgment of the Court rendered on October 4, 2023 at the temporary orders
hearing based on the settlement terms stated on the record by Petitioner, ALTAGRACIA
QUIROZ DE SALINAS, and Respondent, REYNALDO SALINAS.
II.
The following language is omitted fiom the Agreed Temporary Orders by clerical error
and should be included::
“IT IS FURTHER ORDERED that the parties are authorized only as follows:
1. To make expenditures and incur indebtedness for reasonable and necessary living
expenses for food, clothing, shelter, transportation, and medical care.
2. To make expenditures and incur indebtedness for reasonable attorney’s fees and
expenses in connection with this suit.
Electronically Filed
12/13/2023 1:36 PM
Hidalgo County District Clerks
Reviewed By: Rachel Bueno
3. To make withdrawals from accounts in financial institutions only for the purposes
authorized by the Court’s order.
4. To engage in acts reasonable and necessary to conduct the parties’ usual business
and occupation”.
III.
The following language is added to the Agreed Temporary Orders by clerical error and
should be deleted:
/
1. “(aa) tracking or monitoring personal property or a motor vehicle in the
possession of the other party, without the other party’s effective consent,
including by:
i using a tracking application on a personal electronic device in the possession
of the other party or using a tracking device; or
ii. by physically following the other party 0r causing another to physically
follow the other party;
2. “Temporary Spousal Health Insurance Coverage
IT IS ORDERED that Reynaldo Salinas shall continue existing health insurance
coverage for Altagracia Quiroz De Salinas on Reynaldo Salinas’ health insurance
policy”.
IV.
The date for subsequent temporary spousal support payments is incorrect in the Agreed
Temporary Orders by clerical error and should be corrected as follows:
1. IT IS ORDERED that Reynaldo Salinas shall pay as temporary spousal support to
Altagracia Quiroz De Salinas $1,800.00 per month, with the first payment
commencing October 15, 2023 and each month thereafter until fimher orders of
the Court.
V.
Respondent moves the Court to grant his motion for judgment nunc pro tune, vacate the
Agreed Temporary Orders signed on November 1, 2023, and enter Agreed Temporary Orders
Nunc Pro Tunc in accordance with the Coun’s judgment as rendered on October 4, 2023.
Electronically Filed
12/13/2023 1:36 PM
Hidalgo County District Clerks
Reviewed By: Rachel Bueno
PRAYER
WHEREFORE PREMISES CONSIDERED, Respondent prays that his Motion for
Judgment Nunc Pro Tunc be granted and for general relief.
Respectfully submitted,
LAW OFFICES OF DANIEL RAMIREZ
1536 Dove Avenue
McAllen, Texas 78504
Phone: (956) 686-2401
Fax: (956) 686-5260
Email: lawofficesofdanramirezGngail.com
BY: /s/ Daniel Ramirez
DANIEL RAMIREZ
Bar Card No. 16505500
ATTORNEY FOR RESPONDENT
REYNALDO $ALINAS
CERTIFICATE OF SERVICE
I, DANIEL RAMIREZ, hereby certify that on this the 13th
day of December, 2023, a true
and correct copy of the foregoing Motion for Judgment Nunc Pro Tune was forwarded to:
M(s). Nereida Lopez-Singleterry
Attorney at Law
2001 W. Nolana
McAllen, Texas 78504
Attorney for Petitioner
Via E-service/Email: nereidaLsingleteerlawgroun@ggail.com
/s/ Daniel Ramirez
DANIEL RAMIREZ
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.
Daniel Ramirez on behalf of Daniel Ramirez
Bar No. 16505500
lawofficesofdanramirez@gmail.com
Envelope ID: 82536590
Filing Code Description: Motion for Nunc Pro Tunc
Filing Description:
Status as of 12/13/2023 2:08 PM CST
Associated Case Party: Altagracia Quiroz de Salinas
Name BarNumber Email TimestampSubmitted Status
Nereida Lopez-Singleterry nereidaLsingleterrylawgroup@gmail.com 12/13/2023 1:36:43 PM SENT
Document Filed Date
December 13, 2023
Case Filing Date
March 24, 2023
Category
Divorce - No Children (OCA)
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Electronically Filed 12/13/2023 1:36 PM Hidalgo County District Clerks Reviewed By: Rachel Bueno CAUSE NO. F-l l74-23-H INTHE MATTER 0F § 1N THE DISTRICT COURT THE MARRIAGE 0F § § ALTAGRACIA QUIRoz DE SALINAS § 389T” JUDICIAL DISTRICT AND § REYNALDO SALINAS § HIDALGO COUNTY, TEXAS MOTION FOR JUDGMENT NUNC PRO TUNC TO THE HONORABLE JUDGE OF SAID COURT: NOW COMES, REYNALDO SALINAS, Respondent in the above-entitled and numbered cause and files this his Motion for Judgment Nunc Pro Tunc and would show the Coun as follows: The Agreed Temporary Orders entered by the Court on November 1, 2023 were not approved by Respondent and his counsel and has some clerical errors which are not in accordance with judgment of the Court rendered on October 4, 2023 at the temporary orders hearing based on the settlement terms stated on the record by Petitioner, ALTAGRACIA QUIROZ DE SALINAS, and Respondent, REYNALDO SALINAS. II. The following language is omitted fiom the Agreed Temporary Orders by clerical error and should be included:: “IT IS FURTHER ORDERED that the parties are authorized only as follows: 1. To make expenditures and incur indebtedness for reasonable and necessary living expenses for food, clothing, shelter, transportation, and medical care. 2. To make expenditures and incur indebtedness for reasonable attorney’s fees and expenses in connection with this suit. Electronically Filed 12/13/2023 1:36 PM Hidalgo County District Clerks Reviewed By: Rachel Bueno 3. To make withdrawals from accounts in financial institutions only for the purposes authorized by the Court’s order. 4. To engage in acts reasonable and necessary to conduct the parties’ usual business and occupation”. III. The following language is added to the Agreed Temporary Orders by clerical error and should be deleted: / 1. “(aa) tracking or monitoring personal property or a motor vehicle in the possession of the other party, without the other party’s effective consent, including by: i using a tracking application on a personal electronic device in the possession of the other party or using a tracking device; or ii. by physically following the other party 0r causing another to physically follow the other party; 2. “Temporary Spousal Health Insurance Coverage IT IS ORDERED that Reynaldo Salinas shall continue existing health insurance coverage for Altagracia Quiroz De Salinas on Reynaldo Salinas’ health insurance policy”. IV. The date for subsequent temporary spousal support payments is incorrect in the Agreed Temporary Orders by clerical error and should be corrected as follows: 1. IT IS ORDERED that Reynaldo Salinas shall pay as temporary spousal support to Altagracia Quiroz De Salinas $1,800.00 per month, with the first payment commencing October 15, 2023 and each month thereafter until fimher orders of the Court. V. Respondent moves the Court to grant his motion for judgment nunc pro tune, vacate the Agreed Temporary Orders signed on November 1, 2023, and enter Agreed Temporary Orders Nunc Pro Tunc in accordance with the Coun’s judgment as rendered on October 4, 2023. Electronically Filed 12/13/2023 1:36 PM Hidalgo County District Clerks Reviewed By: Rachel Bueno PRAYER WHEREFORE PREMISES CONSIDERED, Respondent prays that his Motion for Judgment Nunc Pro Tunc be granted and for general relief. Respectfully submitted, LAW OFFICES OF DANIEL RAMIREZ 1536 Dove Avenue McAllen, Texas 78504 Phone: (956) 686-2401 Fax: (956) 686-5260 Email: lawofficesofdanramirezGngail.com BY: /s/ Daniel Ramirez DANIEL RAMIREZ Bar Card No. 16505500 ATTORNEY FOR RESPONDENT REYNALDO $ALINAS CERTIFICATE OF SERVICE I, DANIEL RAMIREZ, hereby certify that on this the 13th day of December, 2023, a true and correct copy of the foregoing Motion for Judgment Nunc Pro Tune was forwarded to: M(s). Nereida Lopez-Singleterry Attorney at Law 2001 W. Nolana McAllen, Texas 78504 Attorney for Petitioner Via E-service/Email: nereidaLsingleteerlawgroun@ggail.com /s/ Daniel Ramirez DANIEL RAMIREZ 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. Daniel Ramirez on behalf of Daniel Ramirez Bar No. 16505500 lawofficesofdanramirez@gmail.com Envelope ID: 82536590 Filing Code Description: Motion for Nunc Pro Tunc Filing Description: Status as of 12/13/2023 2:08 PM CST Associated Case Party: Altagracia Quiroz de Salinas Name BarNumber Email TimestampSubmitted Status Nereida Lopez-Singleterry nereidaLsingleterrylawgroup@gmail.com 12/13/2023 1:36:43 PM SENT