APPEAL FORM MODEL:

(Last Name Father, Mother, First Name):

Perez Equis Juan.

(Actor)

VS

Food Debtor _________

(Defendant)

Trial: Alimony

EXP: No 500000/ 2010.

C. JUDGE ____________ CIVIL IN THE FEDERAL DISTRICT

PRESENT.

C._______________________________, Mexican, of legal age, by

my own right and on behalf and representing my minor child(ren) named
____________________________________ last names ______________________________

NORMA GUADALUPE CASTILLO LÓPEZ.

VS

JORGE LUIS ALDANA MÁRQUEZ.

ALIMONY.

Booklet 33/2006.

C. THIRD FAMILY COURT OF FIRST INSTANCE

FROM THE JUDICIAL DISTRICT OF THE CENTER, IN VILLAHERMOSA,

TABASCO; ON DUTY.

PRESENT.

NORMA GUADALUPE CASTILLO LÓPEZ, with the authority I have in the current case,
I appear before you in order to:

EXPOSER

That in response to the request made by your honor in the preceding order, for
through this means I come to express that the designation conferred to professionals in
rights indicated in my initial complaint, it is for the position of representatives
judicial in terms of what is established in articles 2892, 2894, fractions II and IV fraction
of the Civil Code in force in the State of Tabasco, as well as articles 84 section II and others
applicable relatives of the current Civil Procedure Code in the State of Tabasco.

For the above reasons and based on

To you, Mr. Judge, I respectfully request that you kindly serve:

FIRST. Consider me presented, in the terms of this motion, making the

designated manifestation, having the designated professionals as judicial officers
in my initial complaint filing.

SECOND. Law interns are also authorized for the

effects mentioned in my initial writing.

I protest the necessary.

NORMA GUADALUPE CASTILLO LÓPEZ.

C. THIRD FAMILY COURT OF FIRST INSTANCE

FROM THE JUDICIAL DISTRICT OF THE CENTER, IN VILLAHERMOSA,

TABASCO; IN TURN.

PRESENT.

NORMA GUADALUPE CASTILLO LÓPEZ, with the authority I have in the present case,
I appear before you in order to

E X P O N E R

That in response to the request made by your honor in the preceding order, for
In the middle of the present, I come to manifest UNDER FORMAL PROTEST OF TELLING THE TRUTH that I do not
I have in my possession the certified copies that are being requested from me, as this process
jurisdictional took place in the year 1987; for this reason, I request that I be granted a
reasonable extension of the term granted, in order to process the application for your
Your Honor.
I also point out to your honor that I only have copies of it in my possession.
process, which I attach to the account course, where the following data is recorded
process:

Jorge Luis Aldana Márquez and Norma Guadalupe Castillo López

Voluntary Divorce

File Number 091/987

Same that was filed and processed before the Second Family Court of First Instance,
authority to which the certified copies of the ruling have been timely requested
Final and the order that declares it executable, in accordance with what was requested by you
Your Honor.

For the aforementioned and founded

To you, Mr. Judge, I respectfully request your service.

UNIQUE: Grant the request as it is not contrary to law.

PROTEST IS NECESSARY

______________________________________

NORMA GUADALUPE CASTILLO LÓPEZ.

I appear before you for the purpose of:

E X P O N E R

That through the present writing, being within the time

and therefore, based on the provisions of Article 253 of the procedural code of the State
from Tabasco, I respectfully come to FILE THE APPEAL against
the agreements, orders and resolutions issued during the evidence hearing held with
date ________________________, By virtue of causing the grievances that I make
to be worth in this course.

In order to comply with legal provisions, I designate as my address to hear and receive
all kinds of citations, notifications, and documents located at ______________________

LAWYERS:

Authorizing to hear and receive them on my behalf, as well as to display, receive, and collect all
class of documents and values, including personal ones, to the gentlemen lawyers:

INTERNS
authorizing for such purposes the interns of the Bachelor of Law,

Pointing out as evidence to integrate the appeal testimony the referred hearing of
date ________________, as well as the writings in which the position papers are displayed,
the own terms of the positions displayed by the plaintiff and the defendant, the
demand, the response to it and the document from this party that answers the view to the
exceptions produced by the defendant presented and stamped by this Honorable Court on date
_____________________ .

Continuing with the challenge of the account, I would like to express the legal injuries that
it causes me the car that is fought, they are contained in the following:

AGGRAVATING

FIRST GRIEVANCE.

SOURCE OF THE GRIEVANCE: The point of agreement from the referred hearing of
__________________________ , , which is of the following tenor:

"The judge citizen proceeds to qualify the set of positions, deeming them legal."
first to the ninth, from the eleventh to the twentieth, twenty-second, twenty-fourth,
twenty-fifth, twenty-seventh, and twenty-eighth, discarding the tenth.
twenty-third and twenty-sixth for being insidious, twenty-first for being the same as the
twentieth position, twenty-ninth for not being subject to the litigation, besides the confessional
it is not suitable evidence for signature recognition, the above in accordance with the
articles 252, 253 and 254 of the current civil procedural code...

Violations of Legal Provisions:

Articles 253 and 227 of the Code of Civil Procedure of the State of Tabasco.

CONCEPTS OF RAPE.

The provision 253 of the Procedural Code is violated to the detriment of my client, which states
that the positions must refer to one's own facts that are the subject of the debate, since in
the present case, which is a lawsuit for child support in favor of the minor
__________________________ , and __________________________ , the request is updated
of food in favor of the first and the proportional regulation of food expenses to
favor of the second, where the defendant asserts in his response that he is at the
current payment because it says that it provides alimony for another child of the parties of
name __________________________, so that regarding the positions
discarded, the tenth:

That the youngest daughter born from the concubinage named ______________________, has never...
having alimony in your favor is essential to demonstrate behavior
the omission that the defendant has incurred since the birth of the minor mentioned, who has never
he has received from his father what corresponds to a child support payment; a negative fact of which
there is a lack of other evidence that can prove it by its very nature,
especially when our civil code establishes the nature of the facts that have
Legal consequences as stipulated in Article 1874.- Concept of legal fact:

"Legal fact is any event carried out with or without the participation or action of man,"
that is supposed by a legal norm, in order to produce legal consequences,
consist of creating, transmitting, modifying, conserving or extinguishing legal rights or duties
or specific legal situations. In such a way that there is no other means to prove the absence.
of compliance with that pension on time, as it is clear that in matters where
claims child support, claims the non-fulfillment of an obligation to give and that
such non-compliance arises from one or more omissions that turn out to be successive in nature,
Now then, the use of the word 'ever' implies continuous and permanent omission in the context in
the one that was formulated and said context is in no way tendentious to confuse the
intelligence of the absorber, as it is merely a matter of establishing a continuous omission,
permanent, persistent and in effect until today. Similarly, it should be noted that there is no
insidious in the formulated position, as it in no way seeks to obfuscate intelligence
of the absorbent and obtain an answer different from reality; the term insidia according to the real
Academia means: 'trap, words or action that involve bad intention,' and in none
it is done with bad intention, as it was about establishing a widespread omission in the
time and valid until the moment the hearing was held and even until today.
Furthermore, the A quo has sufficient and ample powers to determine whether the absconding party
According to your instruction, level of education, and preparation, you may or may not understand the question.
and in their case explain it.

The same legal logical reasoning applies to the rejection of the position.
TWENTY-THIRD "That the absolvent has never covered the tuition costs of his
youngest daughter named __________________________" AND TWENTY-SIXTH: "That she has never
paid for the washing and ironing of your clothes." since this position is aimed at
demonstrate in your case whether the defendant contributes or not, with their personal expenses, such as the
care of your clothing. Regarding the use of the words 'never' and 'never', the court has issued
established case law, which even if it pertains to a different subject than family law, is applicable
the logic of reasoning visible in the record No. Record: 190.108, Subject(s): Labor
Ninth Era, Instance: Second Chamber, Source: Judicial Weekly of the Federation and its
Gazette, Volume: XIII, March 2001, Thesis: 2a./J. 11/2001, Page: 119.

FOR THE REASONS STATED AND FOUNDED BEFORE YOU:

C. FAMILY COURT JUDGE; I respectfully request:

UNIQUE: To acknowledge the submitted appeal with as many copies as

are required, expressing the grievances that are being asserted, so that prior legal procedures can be followed,
revoke and modify the specific part of the ruling that is challenged, ordering to allow entry
that corresponds to the demand and its consequent legal effects on food
provisional and definitive in her case for the undersigned.

I protest what is necessary.

Promoter

Mexico City, on the fifth day of May, 2010.

RELEVANT COMMENTS:

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