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

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

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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

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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