CAUSE NO.

25,959

CODY WOMMACK,

Contestant

V.

MIKE ALCORN AND MARIE SKIPPER,

Contestees

Filed 12/15/2016 12:36:13 PM

Gwen Ashworth
District Clerk
Morris County, Texas
By: Londa Clark
Deputy

IN THE DISTRICT COURT

276TH JUDICIAL DISTRICT

MORRIS COUNTY, TEXAS

CONTESTEES MOTION FOR SANCTIONS AGAINST CONTESTANT

COME NOW, Contestee MARIE SKIPPER (Contestees), and file this, her Motion for
Sanctions against Contestant, and in support thereof, and would show unto the Court the following:
A.
CLAIMS AGAINST MARIE SKIPPER ARE FRIVOLOUS AND
HAVE NO BASIS IN LAW OR FACT
1.

As demonstrated by the uncontested summary judgment evidence contained in

Contestee Marie Skippers Motion for Summary Judgment, the Ms. Skipper and the Contestant
were not candidates for the same elected office. Contestant ran as a candidate for the Daingerfield
Lone Star ISD Board of Trustees At Large, Position 4 while Marie Skipper ran as a candidate
for the At Large, Position 3 seat.
2.

Since Marie Skipper and Contestant did not run for the same office, Contestant has

no legal right to file an election contest concerning Contestee Skippers election. Contestants
claims against Ms. Skipper are groundless and brought in bad faith or groundless and brought for
the purpose of harassment. Therefore, Contestant should be sanctioned in accordance with Rule
13 of the Texas Rules of Civil Procedure.

CONTESTEES MOTION FOR SANCTIONS

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B.
Contestee Marie Skipper requests that Contestant be sanctioned in the amount of FIVE
THOUSAND AND NO/100 DOLLARS ($5,000.00). Through November 30, 2016, $4,098.58 in
legal fees and expenses have been incurred on behalf of Contestee Marie Skipper.
C.
PRAYER
WHEREFORE, PREMISES CONSIDERED, Contestee Marie Skipper prays that this
Court grant the relief requested in this Motion for Sanctions, and further prays for such other and
further relief to which Contestee may show herself to be entitled, at law or in equity.
Respectfully Submitted,
POWELL & LEON, L.L.P.
1001 ESE Loop 323, Suite 450
Tyler, Texas 75701
Telephone: (903) 526-6618
Fax: (903) 526-5766

By:
V. Jay Youngblood
State Bar of Texas No. 22220200
jyoungblood@powell-leon.com
ATTORNEYS FOR CONTESTEE

CONTESTEES MOTION FOR SANCTIONS

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CERTIFICATE OF SERVICE
A true and correct copy of the foregoing instrument has been served on the 15th day of
December, 2016 by Certified Mail, Return Receipt Request and by USPS Priority Mail on the
following:
Cody Wommack
220 Haley
Lone Star, Texas 75668
CMRRR # 7015 1520 0000 0126 8208

V. Jay Youngblood

CONTESTEES MOTION FOR SANCTIONS

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