In the Matter of the Marriage of Terry Brent Williams and Tracy Leann Williams and in the Interest of P.R.W., a Child v. the State of Texas

Opinion

ACCEPTED 15-25-00076-cv

FIFTEENTH COURT OF APPEALS AUSTIN, TEXAS 12/19/2025 9:34 AM

No. 15-25-00076-CV CHRISTOPHER A. PRINE CLERK

FILED IN

15th COURT OF APPEALS

IN THE COURT OF APPEALS AUSTIN, TEXAS FOR THE FIFTEENTH DISTRICT OF TEXAS 12/19/2025 9:34:43 AM

AUSTIN, TEXAS CHRISTOPHER A. PRINE Clerk

IN THE MATTER OF THE MARRIAGE OF TERRY BRENT WILLIAMS AND TRACY LEANN WILLIAMS AND IN THE INTEREST OF P.R.W., A CHILD,

On Appeal from the 369th District Court Leon County, Texas, No. 22-0059CV The Honorable Michael Davis, Presiding

APPELLANT’S RESPONSE TO

APPELLEE’S REQUEST TO AMEND BRIEFING

TO THE HONORABLE FIFTEENTH COURT OF APPEALS:

Appellant, Terry Brent Williams, hereby files this Response to Appellee’s

Request to Amend Briefing to object to amend briefing in this appeal.

First, Appellee incorrectly asserted that Appellant did not request the

supplemental record. As reflected in the filings in this Court, Appellant did in fact

request the transcription of the hearing prior to the filing of Appellant’s Brief, but

the court reporter failed to file it. In his request to supplement the Reply Brief,

Appellant merely requests to change the citations to the record to better aid the court

in its analysis of the case.

Second, the Texas Rules of Appellate Procedure indicate that any party may

designate additional portions of the testimony to be included in the reporters record.

Tex. R. App. P. 34.6(c)(2). In other words, Appellee could have requested the

transcript prior to filing his Appellee’s Brief but declined to do so.

Third, and probably most importantly, it would be an expensive burden on the

Appellant to re-brief this case. The supplemental record does not change the analysis

of the issues and does not change the substantive issues on appeal. The only real

change is that it removes the presumption that the record support’s the trial court’s

findings.

Therefore, for the reasons presented, Appellant requests this Court deny

Appellee’s Motion to supplement the briefing in this case.

December 19, 2025

Respectfully Submitted,

CLOUTHIER LAW, PLLC

/s/Susan J. Clouthier Susan J. Clouthier Tex. Bar No. 24062673 9950 Woodloch Forest Dr., Ste. 1300 The Woodlands, Texas 77380 Tel: (346) 443-4300 Fax: (346) 443-4343 susan@clouthierlaw.com

Attorney for Appellant Terry Brent Williams

3

CERTIFICATE OF SERVICE

I hereby certify that on December 19, 2025, a true and correct copy of

Appellant’s Response was e-served to:

via e-filing

Clint F. Sare Tex. Bar No. 00788354 P.O. Box 1694 Bryan, Texas 77806 Tel: (979) 822-1505 cfs@sarelaw.com

Attorney for Respondent Tracy Leeann Williams

/s/Susan J. Clouthier Susan J. Clouthier

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.

Susan Clouthier on behalf of Susan Clouthier Bar No. 24062673 susan@clouthierlaw.com Envelope ID: 109295816 Filing Code Description: Response Filing Description: Appellant's Response to Appellee's Motion to Amend Briefing Status as of 12/19/2025 9:42 AM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Clouthier Law info@clouthierlaw.com 12/19/2025 9:34:43 AM SENT

Susan J.Clouthier susan@clouthierlaw.com 12/19/2025 9:34:43 AM SENT

Clint F.Sare cfs@sarelaw.com 12/19/2025 9:34:43 AM SENT