Citing In the Interest of N.V.R., Telegina argues the notice requirement is not met by a letter or email advising of the hearing date. See In re N.V.R., No. 06-17-00022-CV, 2017 WL 727361 (Tex. App.-Texarkana Feb. 24, 2017, no pet.) (mem. op.). N.V.R. did not hold that service of the Rule 145(f) notice cannot be accomplished by letter or email; rather, it appears the problem with the notice was that it issued less than 10 days before the hearing.

We review the trial court's order for an abuse of discretion. SeeIn re N.V.R. , No. 06-17-00022-CV, 2017 WL 727261, at *1 (Tex. App.—Texarkana Feb. 24, 2017, no pet.) (mem. op.). II. Applicable Law

Thus, we conclude that the trial court erred in sustaining the purported contest of DFPS and ordering mother to pay all costs on appeal. See Pierce v. Blalack, No. 06-17-00027-CV, 2017 WL 1018608, at *2, *4 (Tex. App.—Texarkana Mar. 16, 2017, no pet.) (mem. op.) (holding trial court erred in denying declarant's claim of inability to afford payment of court costs where nothing in record indicated that party's contest complied with requirements of Texas Rule of Civil Procedure 145); In re N.V.R., No. 06-17-00022-CV, 2017 WL 727261, at *2-3 (Tex. App.—Texarkana Feb. 24, 2017, no pet.) (mem. op.) (same); In re A.M., 557 S.W.3d 607, 608-09 (Tex. App.—El Paso 2016, no pet.) (declarant who filed statement of inability to afford payment of court costs entitled to proceed without payment of court costs unless clerk, party, attorney ad litem, or court reporter's motion complied with requirements of Texas Rule of Appellate Procedure 145(f)); In re J.N.F., 116 S.W.3d at 431-32 & n.4 (considering declarant's statement of inability to afford payment of court costs to be "uncontested," where party did not file contest that complied with Texas Rule of Civil Procedure 145); see also Jones v. Stayman, 747 S.W.2d 369, 370 (Tex. 1987) ("Indigency provisions . . . have long been liberally construed in favor of a right to appeal."); In re C.D.S., 172 S.W.3d at 186 (failure to timely appoint counsel for parent that has requested attorney and filed unchallenged statement of inability to afford payment of court costs constitutes reversible error).

Additionally, the authority upon which Rodriguez relies for this assertion is distinguishable from these facts. See In re N.V.R., No. 06-17-00022-CV, 2017 WL 727261 (Tex. App.—Texarkana Feb. 24, 2017, no pet.). In N.V.R., the challenge to the appellant's inability to pay costs was brought by a party—not, as here, a court reporter—and was therefore governed by Rule 145(f)(1)'s "sworn evidence" requirement.

Therefore, we hereby ABATE the appeal and REMAND the cause to the trial court for entry of written "detailed findings" that appellant can afford to pay costs, pursuant to Texas Rule of Civil Procedure 145(f)(6). See id.; see also In Interest of N.V.R., No. 06-17-00022-CV, 2017 WL 727261, at *3 (Tex. App.—Texarkana Feb. 24, 2017, no pet.) (mem. op.) (reversing order assessing costs against indigent party in part because "the trial court's order was unsupported by findings required by Rule 145"); Vodicka v. Tobolowsky, No. 05-17-00961-CV, 2017 WL 5150992, at *1 (Tex. App.—Dallas Nov. 7, 2017, no pet.) (mem. op.) (explaining that the appeal was abated for entry of written findings under Rule 145(f)(6)). The "detailed findings" shall be included in a supplemental clerk's record and must be filed with the clerk of this Court on or before thirty (30) days from the date of this order.

Although the trial court was required to evaluate Koehne's credibility, it was not free to disregard the evidence of Koehne's current financial condition and focus instead on Koehne's financial condition in August 2016, when he had a short-term job and was not in jail. See Sosa, 980 S.W.2d at 816 (granting relief because unrebutted testimony established that expenses exceeded income and no assets were available to finance payment of costs on appeal); In re A.M., - S.W.3d -, No. 08-16-00277-CV, 2016 WL 6835727, at * 3 (Tex. App.—El Paso Nov. 21, 2016, no pet.) (holding trial court abused discretion in concluding appellant could afford to pay court costs where evidence established monthly expenses exceeded average monthly income); In re N.V.R., No. 06-17-00022-CV, 2017 WL 727261, at *3 (Tex. App.—Texarkana Feb. 24, 2017, no pet.) (holding trial court abused its discretion in determining appellant could afford to pay court costs where no evidence controverted his proof of inability). Because Koehne presented evidence he was currently unable to afford the costs on appeal, and no evidence rebutted this testimony regarding Koehne's current financial condition, the trial court's determination that Koehne could afford to pay court costs was "so arbitrary and unreasonable as to be clearly wrong."