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
11/12/2025 4:16 PM
No. 15-25-00076-CV CHRISTOPHER A. PRINE
CLERK
§ IN THE FILED IN
Terry Brent Williams, § COURT OF AAUSTIN,
PPEALS,TEXAS
15th COURT OF APPEALS
Appellant, § FOR THE
11/12/2025 4:16:42 PM
v. § TENTH JUDICIAL DISTRICTA., PRINE
CHRISTOPHER
Tracy Leeann Williams, § WACO, TEXASClerk
Appellee. §

OBJECTION TO POST-BRIEFING REQUEST
TO ALTER APPELLANT’S DESIGNATED RECORD

The Rules of Appellate Procedure contain clear requirements for a

party’s designation of the record. A request for a reporter’s record is to be

made at or before the time for perfecting appeal and must be filed with the

trial court clerk. Tex. R. App. Proc. 34.6(b)(1), (2). Even if a request is

untimely, if the court reporter tenders the requested record for filing, it is to

be filed. Tex. R. App. Proc. 34.6(b)(1), (2).

On April 15, 2025, Appellant made a timely request for preparation of

the reporter’s record specifically identifying two hearings. (CR 192). That is

the only request that was filed in accordance with Rule 34.6(b)(2). As

discussed in Appellee’s brief Rule 34.6(c) establishes the effect of requesting

a partial record. While Rule 34.6(d) permits supplementation of the record

with items that have been “omitted,” construing that part of the Rule as

permitting a party who designated a partial record to avoid the effect of part

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(c) by simply seeking a supplemental record after the briefs are filed, would

negate procedure it establishes, and the cases construing the effect of the Rule.

That is what Appellant seeks to do now. After both parties filed their

briefs, Appellant filed a reply which sought to have the Court consider a

transcription that was never requested under the Rules and not submitted by

the court reporter. Appellee objects to the record never requested and omitted

from the request which was filed.

Without filing a motion in accordance with Rule 10, Appellant now

seeks to have the Court “assist” in securing the record that was never

requested in accordance with the Rules. That would not be consistent with

the Rules. That is particularly so where the attachments to Appellant’s letter

show Appellant’s counsel first contacted the court reporter who transcribed

the September 2024 hearing until July 17, 2025. That was after the reporter’s

record was due. It was also almost two months before Appellant filed his

brief. Although counsel for Appellant was aware of the September 2024 at

the time of filing, the brief makes no mention of the September 2024 hearing

and was filed without any continuance to properly request and secure a record

of that hearing. Appellee objects to altering the appellate record at this stage

in the appeal.

Respectfully submitted,

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_/s/_Clint Sare_______
Clint F. Sare
Tex. Bar No. 00788354
PO Box 1694
Bryan Texas 77806
cfs@sarelaw.com
979-822-1505

CERTIFICATE OF SERVICE

I certify a copy of the foregoing document was served on counsel for
Appellant, Susan Clothier, by electronic service on November 12, 2025.

_/s/_Clint_Sare_______

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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.

Envelope ID: 107975967
Filing Code Description: Other Document
Filing Description:
Status as of 11/12/2025 4:22 PM CST

Case Contacts

Name BarNumber Email TimestampSubmitted Status

Susan J.Clouthier susan@clouthierlaw.com 11/12/2025 4:16:42 PM SENT

Clint F.Sare cfs@sarelaw.com 11/12/2025 4:16:42 PM SENT