in the Matter of the Marriage of Andrzej Adamski and Oksana Adamski, 14-16-00099-CV

Andrzej and Oksana Adamski married in 1999; one minor child. Divorce proceedings began in 2012, with jury trial in May 2015 and bench proceedings in October 2015. Andrzej had counsel for the jury phase but proceeded pro se at the bench phase.
Andrzej missed part of the bench trial (did not appear on the third day); the docket shows evidence closed in his absence and the court later signed a final decree on February 2, 2016.
Final decree: joint managing conservatorship, Oksana designated primary residence, transfer of Andrzej’s child social security benefits to Oksana or $750/month child support if benefits not received; division of property (including Polk County real property to Oksana per decree), judgment for fraud against Andrzej ($9,900), and award of $30,000 in attorney’s fees to Oksana.
Andrzej filed a motion for continuance or new trial alleging medical emergency caused his absence and referencing possible child abuse; he attached photographs and a police report but did not request a hearing on the motion and no express ruling appears in the record.
Andrzej appealed raising three issues: (1) child support above statutory guidelines without required findings, (2) marital estate division and attorney’s fees violated a premarital agreement, and (3) trial court erred by denying a new trial/default-relief under Craddock. The appellate record lacks a reporter’s record for trial proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Child support above guidelines	Andrzej: court deviated from 20% guideline without required findings; tax returns show lower net resources	Oksana: (trial evidence presumed to support award); no reporter’s record to show error	Court: Presume trial evidence supports award; without reporter’s record cannot show deviation or missing findings — overruled.
Division of marital estate & attorney’s fees contrary to premarital agreement	Andrzej: premarital agreement designated certain property as his separate property, equal split of joint accounts, and no spousal support; court violated agreement by awards to Oksana and ordering fees	Oksana: (challenged enforceability/introduced contrary evidence at trial); no reporter’s record to show agreement was proved or enforceable	Court: Without reporter’s record, presume evidence supported trial court’s judgment; overruled.
Motion for new trial / default-relief under Craddock	Andrzej: failure to appear caused by medical emergency; met Craddock elements for new trial	Oksana: Andrzej waived relief by not requesting a hearing or presenting evidence; motion overruled by operation of law	Court: Movant waived by failing to request hearing or present evidence; even if preserved, Andrzej failed to prove Craddock elements — overruled.

In re Marriage of Butts, 444 S.W.3d 147 (Tex. App.—Houston [14th Dist.] 2014) (child-support guideline/deviation framework)
Beck v. Beck, 814 S.W.2d 745 (Tex. 1991) (premarital agreements presumptively valid)
Schafer v. Conner, 813 S.W.2d 154 (Tex. 1991) (presumption that record supports trial court when reporter’s record absent)
Dolgencorp of Tex., Inc. v. Lerma, 288 S.W.3d 922 (Tex. 2009) (Craddock standard for post-answer default relief)
Craddock v. Sunshine Bus Lines, Inc., 133 S.W.2d 124 (Tex. 1939) (three-part test for setting aside default judgments)
Holt Atherton Indus., Inc. v. Heine, 835 S.W.2d 80 (Tex. 1992) (motions for new trial and requirements for presenting new matters on appeal)