Irma Perez v. Victor Manuel Perez, Jr.

El Paso County - 388th District Court Filed 3/12/2021 3:32 PM
08-21-00043-CV Norma Favela Barceleau
District Clerk
El Paso County
2017DCM0562
In the District Court of El Paso County, Texas
388th Judicial District
In the Matter of §
FILED IN
The Marriage of § 8th COURT OF APPEALS
§ EL PASO, TEXAS
IRMA PEREZ, § 3/15/2021 11:53:00 AM
§ ELIZABETH G. FLORES
Petitioner, § Clerk
§
and § Cause No. 2017DCM0562
§
VICTOR MANUEL PEREZ, JR. §
§
Respondent, §
§
and in the Interest of §
S.A.P. and A.B.P., §
Children §
PETITIONER IRMA PEREZ’S NOTICE OF APPEAL
OF FEBRUARY 12, 2021 JUDGMENT NUNC PRO TUNC
To the Honorable Judge Marlene Gonzalez:
Now comes Petitioner Irma Perez, and, pursuant to Texas Rules of Appellate Procedure 25
and 26, files this Notice of Appeal:
1. This Notice of Appeal is filed in the Matter of the Marriage of Irma Perez and Victor
Manuel Perez, Jr., and in the Interest of S.A.P. and A.B.P., Children, Cause No. 2017-
DCM-0562, In the 388th District Court, El Paso County, Texas.
2. The orders appealed from are the Order Regarding Respondent’s Perez Motion for
Judgment Nunc Pro Tunc, which was signed on February 12, 2021, and the Final Decree
of Divorce after Motion for New Trial and Judgment Nunc Pro Tunc, entered on March 12,
2021. The Order Regarding Respondent’s Perez Motion for Judgment improperly
corrected judicial error beyond the Court’s plenary power. Thus, the Final Decree of
Divorce after Motion for New Trial and Judgment Nunc Pro Tunc, entered pursuant to the
Court’s order granting Respondent’s Motion for Judgment Nunc Pro Tunc is void, and is
also being appealed.
3. Petitioner Irma Perez desires to file her appeal with the Eighth Circuit Court of Appeals
for the State of Texas in El Paso, Texas.
Respectfully submitted,
RAY | PENA | McCHRISTIAN, P.C.
5822 Cromo Drive
El Paso, Texas 79912
T: (915) 832-7200
F: (915) 832-7333
redwards@raylaw.com
ralvarez@raylaw.com
March 8, 2021 /s/ Rob Edwards
ROB EDWARDS
State Bar No. 24058290
REBECCA H. ALVAREZ
State Bar No. 24104139
CERTIFICATE OF SERVICE
I certify that on this date, a true and correct copy of this instrument was served via
electronic mail to:
George Mansouraty
Attorney at Law
1554 Lomaland
El Paso Texas, 79935
georgemansouraty@sbcglobal.net
/s/ Rebecca H. Alvarez
Rebecca H. Alvarez