Affirmed and Memorandum Opinion filed March 12 , 2024.

In The 

## Fourteenth Court of Appeals

NO. 14

- 22

- 00690

- CV

DEEPA B. WILLINGHAM , Appellant

V.
CHARLES RICHARD WILLINGHAM , Appellee

On Appeal from the 245th District Court

Harris County, Texas Tri al C ourt Cause No. 2018

- 64132

M E M O R A N D U M O P I N I O N
Deepa Willingham brings this pro se appeal from the final decree of divorce dissolving her marriage to Richard Willingham

. The parties originally entered into a mediated settlement agreement b efor e first Deepa and then Richard filed for bankruptcy. The parties subsequently brought issues that developed during the
bankru ptc y proceedings to the former mediator to act as arbitrator. The trial court
then entered the final decree , dissolving the ma r riage and divi ding the parties ’ community property
, among other things

. Deepa raised three objections before the2

mediator and the trial court and now ra ises similar issues in this appeal
, contending
that (1) the arbitrator and the trial court improperly t r eated Deepa ’ s share of a California homestead exemption differently than they did Richard ’ s share of the
homest e ad exemption ; (2) Richard was awarded a painting that is allegedly the property of Deepa ’ s daughter ; and (3) the arbitrator and the trial court abused their
discretion in failing to recognize and examine Rich ard ’ s alleged fraudulent

conve yance

. 1 We affirm. Legal Standards
In a final decree of divorce, a trial court is generall y required to order a division of the community property that the court deems just and right. See Tex. Fam. Code § § 7.001, 7.002 ; Cayan v. Cayan , 38 S.W.3d 161, 164 (Tex. App.

— Houst on [14th Di st.] 2001, pe t. denied). I f the parties enter ed into a mediated settlement agreement that meets the requirements of Family Code section
1 53.0071(d), a party is entitled to judgment on the MSA and a trial court generally
does not have discretion to decline to enter judgment on or deviate from the MSA.
See Tex. Fam. Code § 153.0071(d) ; In re A.D.B. , 640 S.W.3d 604, 610 (Tex. App.

— Houston [14 t h Dist.] 2022 , no pet. )

. As with all litigants , we liberally construe briefs and other filings that are
submit ted by pro se parties, and we hold pro se litigants to the same standards as licensed attorneys and require them to comply with all applicable la w s and rules of procedure. See Mansfie ld State Bank v. Cohn , 573 S.W.2d 181, 184

– 85 (Tex. 1978); Rogers v. City of Hous

. , 627 S.W.3d 777, 786 n.1 (Tex. App.

— Houston [14th Dist.] 2021, no pet.).

1 We pre sume with ou t d eciding that Deepa preserved each of her issues in the trial court. Our consideration of the issues raised should not be taken as gener ally condoning the ra ising of such issues in divorce cases involving MSAs or arbitration rulings.3 Homestead Exemption
As stated, in her first issue, Deepa con t e nds that the arbitrator and the trial

court improperly treated her share of funds related to a California ho mestead

exe mption differentl y than they did Richard ’ s share o f the funds

. The exemption in question appears to have resulted in funds being disburse d in Deepa ’ s California bankruptcy proceeding

. As Deepa points out, t he exemption was addressed in the
followi ng paragrap h of the final decree, which appeared in the portion of the
decree li sting property awarded to Deepa as her sole and separate property :
The distribution received [by Deepa] through her Chapter 7 bankruptcy proceeding in the amount of $99,500.00 [ .] The Cali fornia bankruptcy court made an award of the CA homestead exempt ion of $175,000, $87,000 to [ De epa] and $88,000 to [Richard] . Of the $8 8 ,000, the Texas trustee holds it entirely in escrow. The trustee will pay $12,500 to [Deepa] , leavi ng her wit h an aggreg ate of $99,500. [Richard] ’s share is $75,500, and trustee is exp ected to apply that to the trus tee’s costs. It appears that Deepa may b e m isunderstanding exactly what is happening with the homestead exemption distribution. As can be seen from th e above

par agraph, the total distribution was $175,000. Of that, Deepa rece ived $99,500
total as her sole and separate property and Richar d receiv e d $75,500

. The only
difference s between the handling of these two amounts is that Deepa received $24,000 more and Richard ’ s share is expected to be used to pay the ex penses of
Richard ’ s bankruptcy trustee , which would presumably be community debt

. 2 It is

a lso worth noting that the distribution is mentioned only in the section of the
decree li sting property awarded to Deepa and not in the section listing property awarded to Richard. This is probably because the amoun t for Richard was

2 The par ties sugg es t t hat the $12,500 payment from the Texas trustee in Ric hard ’ s bankruptcy case to Deepa was in settlement of an appeal Deepa had filed in a federal case , but the reason for thi s payment is irrelevant to o ur analysis

.4

distributed to the T exa s trustee and was expected to c over the trustee ’ s costs.
Nevertheless, Deepa asserts that the arbitrator
, and subsequently the trial court, treated her $99,500 share of the distribution as community property
, of
which Richard would then receive half
, or $ 4 9,750 , while Richard ’ s $75,500 share
would not be so divided . Deepa does not cite any place in the final decree or otherwise in the record supporting such an interpretatio n. To the contrary, Deepa ’ s $99 ,500 share is clearly listed as her sole and separate property and not as an item requiring further division . We find no merit in Deepa ’ s argument , and accordingly,
we overrule her first issue. 3
The Painting
In her second issue, Deepa complains that Richard was awarded a painting
that was painted by
, and all e gedly still belongs to
, Deepa ’ s daughter . Deepa does not cite where in the decree this painting is supposedly award e d to Richard

. However, e ven a ssuming the decree c an be interpreted as awarding the painting to
Richard , Deepa does not explain how she has s tandin g to assert he r daughter ’ s ownership of th e p ainting; the record indicates that Deepa ’ s daughter was a n adult when she completed the painting and Deepa does n ot assert otherwis e. See generally Heckman v. Williamson Cnty. , 369 S.W.3d 137, 150 (Tex. 2 0 12)

. Moreover , a divorce decree generally cannot extinguish the rights to property of a third part y not before the court

. See, e.g. , Martin v. Martin , No. 2

- 08

- 490

- CV, 2010 WL 2331448, at *2 n.6 (T ex. App.

— Fort Wor th June 10, 2010 , pet. denied ) (m em. op.) ; K.B. v. N.B. , 811 S.W.2d 634, 641 (Tex. App.

— San Antonio 1991 ,

3 It is possible that Deepa is complain ing because the $75,500 identified as Richard ’ s share was not listed in the portion of the decree enumerating property awarded to Richard as h is sole and separate property

. She may be meaning to assert th at the failure to so list the amount

some how resulte d i n a division of community property that was not just and right. See Tex. Fam. Code § § 7.001, 7.002 ; Cayan , 38 S.W.3d at 164

. But , she does not actually make this argument
, an d we d e cline to craft such a n argument for her

. See Rogers , 627 S.W.3 d at 7 8 7

– 8 8.5

writ denied ) . Accordingly, we overrule the second issue. Fraud Allegation
In issue three, Deepa contends that the arbitrator and the trial court abused
their discretion in failing to take jud i cial notice o f and examine Rich ard ’ s alle ged ly
fraudulent conve yance o f real property

. According to Deepa, Richard inherited property in Cali fornia , placed a deed of trust against it, and then used approximately $180,000 in community property fund s to pay do wn the debt on his separate property

. S he further alleges that Richard sold the pr operty to a broker in violation of the mutual injuncti ons in this case and the broker subsequently sold the property for more money.
Deepa acknowledges that the pr operty i n question was Richard ’ s separate property and that the remaining debt secured by that property was listed in the case
documents as Ri chard ’ s separate debt. She alleges, however, that Richard covered up the fact that he previously had used communit y proper t y to pay down this separate debt and unde rtook a fraudulent conveyance to the broker b y selling the property for less than it was worth. She contends that she should have been made an equitable subrogee in the propert y and been awarded $90,000 as her shar e of the
misa p plied community fun ds.

In su pport of her factual assertions, Deepa primarily cites to appendi ces attached to her brief , but we cannot consider attachments to a brief that are no t also parts of the appellate record

. See, e.g. , Chamie v . Mem ’ l H ermann Health Sys. , 561 S.W.3d 253, 256 ( Tex. App.

— Houston [14th Dist.] 2018 , no pet. ) ; Marriage of
Atherton , No. 14

- 17

- 00601

- CV, 2018 WL 6217624, at *5 (Tex. App.

— Houston [14th Dist.] Nov. 29, 2018 , pet. denied ) (mem. op.)

. Deepa al so suggests th at evide n ce of fraud i s in the public record and a vailable for judicial notice
, but she does not specify what that evidence is or how it establishe s Richard committed6

fraud. 4
In support of her legal arguments, Deepa cites only generally to the entire
Calif ornia Un i form Voidable Transactio ns Act , see Cal if ornia Civ il Code sections
3439 through 3439.14
, and to a California case that generally discusses th at state ’ s rules governing equitable subrogees, see JP Morgan Chase Bank, N.A. v. Banc of
Am erica Prac tice Sol utio n s , Inc. , 147 Cal. Rptr. 3d 287, 290 ( Cal. Ct. App. 2012)

. She does not discuss how these authorities apply in this case
, and she does not
discuss an y Texas authority relevant to this issue. An appellant ’ s brief “must contain a clear and concise ar gument f o r the

content ions made, wit h appropriate citations to authorities and to the record

. ” Tex. R. App. P. 38.1(i) ; see also Nguyen v. Pham , 640 S.W.3d 266, 275 (Tex. App.

— Houston [14th Dist.] 2021, pet. denied) ; O.A.O. v. R.S.O. , No. 14

- 20

- 00870

- CV,
2 022 WL 1 7 099872, at *1 (Tex. App.

— Houston [14th Di st.] Nov. 22, 2022 , no pet. )

. The fact that Deepa is appearing pro se does not excuse her from these requirements. See Rogers , 627 S.W.3d at 786 n.1, 787

– 88

. Appellant ’ s third i ssue is inadequate ly briefed. A ccordi ngl y, we overrul e the third issue.

We a ffir m the trial court ’ s final decree.

/s/ Frances Bourliot Justi ce

Panel consists of Chief Justice Christopher and Ju stices Bourliot and Hassan.

4 Within Deepa ’ s appendices are two grant deeds, but even were we to consider these documents, they do not by themselves ind icate any fraud occurred.