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16-0816-C425
CAUSE NO. ____________________
THE STATE OF TEXAS,
EX REL. DEE HOBBS, COUNTY ATTORNEY
FOR WILLIAMSON COUNTY TEXAS
Plaintiff
V.
JANA DUTY A/K/A JANA L.
HUNSICKER, IN HER OFFICIAL
CAPACITY AS DISTRICT ATTORNEY
OF WILLIAMSON COUNTY, TEXAS,
Defendant
___________JUDICIAL DISTRICT
Page1of12
Envelope# 12087763
I.
NATURE OF THE PENDING ACTION
By nature of this civil removal suit, the State seeks to have Defendant permanently
removed from the public office of District Attorney for Williamson County, Texas due to
incompetency and official misconduct.
This action is pursuant to Chapter 87 of the Texas Local Government Code and is necessary
to guard the public welfare and to protect the interest of the people of Texas.
II.
PARTIES
The STATE OF TEXAS, by and through DEE HOBBS in his official capacity as County
Attorney for Williamson County, Texas and acting on the relation of DEE HOBBS, Relator, files
this suit for removal pursuant to Chapter 87 of the Local Government Code. The STATE OF
TEXAS acting on its own authority and on the relation of the Relator, seeks to remove Jana Duty
from the Office of District Attorney of Williamson County, Texas pursuant to Texas Constitution
Art. 5, Sec. 24 and Chapter 87, Texas Local Government Code. Tex. Const. V, 24; Tex. Loc.
Govt Code Ch. 87 (2016). Relator is a resident of Texas who has lived in Williamson County for
at least six (6) months, and he is not currently under any indictment. Tex. Loc. Govt Code 87.015
(2016).
JANA DUTY A/K/A JANA L. HUNSICKER, Defendant, is the District Attorney for
Williamson County, Texas. On information and belief, Defendant is a resident of Williamson
County, Texas and may be served with citation at 141 Waterford, Georgetown, Williamson
County, Texas 78628.
Page2of12
The STATE OF TEXAS has, concurrently with the filing of this original petition, filed an
Application for Issuance of Citation with a proposed Order on behalf of Relator and requests the
Court approve the issuance of citation to Jana Duty and the service of citation upon her pursuant
to Section 87.016, Texas Local Government Code. Tex. Loc. Govt Code 87.016 (2016).
III.
PRE-TRIAL SCHEDULING ORDER
Following issuance of citation and pursuant to to Rule 166, Texas Rules of Civil Procedure,
the State proposes and request entry of the attached pre-trial scheduling order (attached as Exhibit
A), which includes a discovery schedule and deadlines for other matters listed in Rule 166. Tex.
R. Civ. P. 166.
IV.
DISCOVERY
The discovery in this removal action will be limited. The facts in this case are not disputed,
only whether the uncontested facts rise to the level for removal is in dispute. Due to the nature
and circumstances of this removal action under Chapter 87, Texas Local Government Code, the
State requests that the Court approve an accelerated Discovery Control Plan pursuant to Rule
190.4, Texas Rules of Civil Procedure (Level 3), with discovery limited and tailored to meet the
circumstances of this specific suit. Tex. Loc. Govt Code Ch. 87; Tex. R. Civ. P. 190.4. In order
to meaningfully and effectively prosecute this action, the State requests that, following the issuance
of citation, discovery be conducted in the accelerated, expedited manner set forth in Exhibit A,
proposed Pre-Trial Scheduling Order.
Page3of12
V.
REQUEST FOR DISCLOSURE
Pursuant to Texas Rules of Civil Procedure 194, Defendant is requested to disclose to the
State, within 30 days of service of this request, the information or material described in Rule 194.2.
Tex. R. Civ. P. 194.4.
VI.
JURY DEMAND
The State hereby asserts its demand for a jury trial in this cause. Tex. Loc. Govt Code
87.018 (2016); Tex. R. Civ. P. 216.
VII.
LEGAL GROUNDS FOR REMOVAL
According to Section 87.013(a), Texas Local Government Code, a public officer may be
removed from office upon proof of incompetency or official misconduct. Tex. Loc. Govt Code
87.013(a)(1),(2) (2016).
Incompetency is defined as (A) gross ignorance of official duties; (B) gross
carelessness in the discharge of those duties; or (C) unfitness or inability to promptly and properly
discharge official duties because of a serious physical or mental defect that did not exist at the time
of the officers election. Tex. Loc. Govt Code 87.011(2) (2016).
Official Misconduct is defined as intentional, unlawful behavior relating to official
duties by an officer entrusted with the administration of justice or the execution of the law. The
Page4of12
term includes an intentional or corrupt failure, refusal, or neglect of an officer to perform a duty
imposed on the officer by law. Tex. Loc. Govt Code 87.011(3) (2016).
A public official, including a district attorney, may be removed from office upon petition
and trial if, after trial, a jury finds the evidence that at least one of the statutory grounds for removal
alleged in the removal petition are true. Tex. Loc. Govt Code 87.018(c) (2016).
VIII.
FACTUAL GROUNDS FOR REMOVAL
Defendant was duly elected to the position of District Attorney in November of 2012 and
assumed her official duties on January 1, 2013. The official duties of this public office include:
DUTIES OF DISTRICT ATTORNEYS. Each district attorney shall represent the
State in all criminal cases in the district courts of his district and in appeals
therefrom . . . It shall be the primary duty of all prosecuting attorneys, including
any special prosecutors, not to convict, but to see that justice is done. They shall
not suppress facts or secrete witnesses capable of establishing the innocence of the
accused. Tex. Code Crim. Proc. art. 2.01 (2016).
Defendant after being duly elected to the position of District Attorney in November of 2012
and in assuming her official duties swore and Oath of Office on January 1, 2013 swearing or
affirming:
I, [Jana Duty], do solemnly swear (or affirm), that I will faithfully execute the duties
of the office of District Attorney of Williamson County and of the State of Texas,
and will to the best of my abilities preserve, protect, and defend the Constitution
and laws of the United States and of this State, so help me God. Tex. Govt Code
42.002.
Pursuant to Section 87.015(c), Texas Local Government Code, the State contends that the
following facts are grounds for removal of Defendant from the position of District Attorney for
Williamson County, Texas:
Page5of12
Page6of12
Lawyer Discipline made findings related to the failure to disclose the time-stamps and found that
Defendant violated the following Rules of the Texas Disciplinary Rules for Professional Conduct:
a. 4.01(a) Truthfulness in statements to others: In the course of representing a client
a lawyer shall not knowingly make a false statement of material fact or law to a
third person;
b. 8.04(a)(3) Misconduct:
Due to this violation, Defendant was subsequently found guilty of contempt of the 368th
District court and was sentenced to 10 days jail and a $500.00 fine. See Exhibit D, Judgment of
Contempt and Order of Commitment, attached hereto and incorporated by reference.
A complaint against Defendant was made to the State Bar of Texas. In the Agreed
Judgment of Probated Sentence issued in the matter, the Commission for Lawyer Discipline made
findings related to the violation of the gag order and found that Defendant violated the following
Rules of the Texas Disciplinary Rules of Professional Conduct:
a. 3.04(d) Fairness in Adjudicatory Proceedings: A lawyer shall not knowingly
disobey, or advise the client to disobey, an obligation under the standing rules of
or a ruling by a tribunal except for an open refusal based either on an assertion that
no valid obligation exists or on the client's willingness to accept any sanctions
arising from such disobedience.
b. 8.02(a) Judicial and Legal Officials: A lawyer shall not make a statement that the
lawyer knows to be false or with reckless disregard as to its truth or falsity
concerning the qualifications or integrity of a judge, adjudicatory official or public
legal officer, or of a candidate for election or appointment to judicial or legal office.
See Exhibit B.
This conduct is evidence of Defendants official misconduct because it demonstrates her
intentional, unlawful behavior relating to official duties by an officer entrusted with the
administration of justice or the execution of law and/or the intentional failure, refusal or neglect of
an officer to perform a duty imposed on the officer by law.
Page8of12
C. Defendant was incompetent and engaged in official misconduct by violating the Texas
Disciplinary Rules of Professional Conduct.
A complaint against Defendant was made to the State Bar of Texas. On June 1, 2016, the
Commission for Lawyer Discipline issued an Agreed Judgment of Probated Sentence. See Exhibit
B. In this judgment, the Commission made various findings related to the DVD time-stamps in
the Harmel case and the gag order issued in the same matter. Id. Based on those findings, the
Commission concluded that Defendant violated Rules 4.01(a), 3.04(d), 8.02(a), and 8.04(a)(3) of
the Texas Rules of Professional Responsibility. Id.
This conduct is evidence of Defendants incompetency because it demonstrates her gross
ignorance of her official duties and also her gross carelessness in the discharge of those duties.
Further, it is evidence of Defendants official misconduct because it demonstrates her intentional,
unlawful behavior relating to official duties by an officer entrusted with the administration of
justice or the execution of law and/or the intentional failure, refusal or neglect of an officer to
perform a duty imposed on the officer by law.
IX.
MOTION TO TEMPORARILY SUSPEND DEFENDANT AND TO APPOINT
ANOTHER PERSON TO PERFORM THE DUTIES OF THE DISTRICT ATTORNEY
FOR WILLIAMSON COUNTY, TEXAS
Pursuant to Section 87.017, Texas Local Government Code, the STATE respectfully
requests the temporary suspension of JANA DUTY A/K/A JANA L. HUNSICKER, Defendant,
from the public office of District Attorney for Williamson County, Texas. The STATE further
request that the Court appoint another qualified and competent person to perform the duties of that
office during the pendency of this case.
Page9of12
For purposes of this motion, the STATE hereby incorporates the foregoing allegations as
support for the appropriateness and necessity of a temporary suspension.
X.
REQUESTED RELIEF
WHEREFORE, PREMISES CONSIDERED, the STATE OF TEXAS respectfully
request the following relief from the Court:
1. That the Court enter an order temporarily suspending Defendant from the public office of
District Attorney for Williamson County, Texas during the pendency of this case and
appoint another person to perform the duties of that office during that suspension.
2. That, upon the jury trial of this cause, the Court enter a final judgment permanently ousting
and removing Defendant from her public office as District Attorney for Williamson
County, Texas;
3. That the Court assess and tax costs against Defendant as authorized by Texas Rule of Civil
Procedure 131 and related Rules, or against the Relator as authorized by Section 87.016,
Texas Local Government Code, and related Rules, as circumstances may warrant;
4. That the Court authorize the issuance of appropriate writs of execution providing for the
collection of said costs.
5. Finally, the STATE OF TEXAS requests such other and further relief to which it may be
justly entitled.
Respectfully submitted,
Dee Hobbs
Page10of12
CERTIFICATE OF SERVICE
I hereby certify that a true and correct copy of the foregoing document has been served on
August _______, 2016 to the following counsel in accordance with the Texas Rules of Civil
Procedure:
Daniel Richards
Clark Richards
Attorneys for Defendant
Richards Rodriguez & Skeith, LLP
816 Congress, Ste. 1200
Austin, Texas 78701
Tel: (512) 476-0005
Fax: (512) 476-1513
drichards@rrsfirm.com
crichards@rrsfirm.com
Page11of12
VERIFICATION
STATE OF TEXAS
COUNTY OF WILLIAMSON
Before me, the undersigned authority, on this day personally appeared Dee Hobbs, the
Relator in the above-referenced lawsuit, who upon his oath stated that he has read the foregoing
Petition for Removal and that the facts stated in the foregoing pleading are all within his personal
knowledge, or information and belief, and are true and correct.
Dee Hobbs
I'"'~UBSCRIBED TO AND SWORN BEFORE ME, the undersigned authority, on this
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STEPHANIE J LLOYD
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DECEMBER 6, 2018
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Page 12 of 12
*
*
*
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*
*
*
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201503044
201503662
CF6-15A
6. On May 6, 2015, Respondent sent an email to the trial judge informing him that
she intended to make statements to the Austin American Statesman defending
her actions in the case. Thereafter, in violation of the oral and written gag
orders, Respondent made statements about the case to the Austin American
Statesman which were published in an article on May 7, 2015. During the
afternoon of May 7, 2015, in a series of emails to Respondent and defense
counsel, the judge wrote, "I was trying to schedule everyone to come to court
on Monday, May 11th, however it is my understanding that Ms. Duty will be out
of town on Monday... I want to meet with all counsel tomorrow. I can be
available at any time. . . Please meet in my courtroom at 10:30 am."
Respondent did not appear before the court the next morning, but she did send
two attorneys from her office to represent the State during the meeting.
Respondent later explained in an email to the judge that she felt he had not
respected her and therefore she would not respect him by showing up. She
went on to say, "If you feel I need to be reprimanded for communicating with
The Statesman, I understand. But making a public spectacle out of punishing
me just hurts everyone. No one will come out unscathed."
7. The defense filed an Application for Pre-Trial Writ of Habeas Corpus. The trial
court held a hearing with live testimony and, on September 11, 2015, entered
findings of fact and conclusions of law. On September 17, 2015, Respondent
filed Objections to Judge's Findings of Fact and Conclusions of Law wherein
she stated that the judge had improperly sealed his divorce case to protect his
political career. She further stated:
"[The judge] testified under oath, on August 6, 2015,
when he was subject to the penalties of perjury, that
the defense attorney's had in fact been given all of the
evidence, they just did not know how to use the
evidence. Then, when [the judge] felt he was no longer
subject to the penalties of perjury, and two weeks
before his friend announced that he is going to run
against Ms. Duty, [the judge] cranked out 25 pages of
Findings saying now, that Ms. Duty did in fact withhold
the evidence from the defense attorneys. This is a
blatant lie. If [the judge] refuses to correct these lies,
Ms. Duty will have no choice but to seek sanctions
against him with the Commission on Judicial Conduct.
These lies also raise the question of whether or not
these lies rise to the level of Aggravated Perjury. This
will be investigated as well."
8. The Chief Disciplinary Counsel of the State Bar of Texas has incurred
reasonable attorneys' fees and direct expenses associated with this
Disciplinary Proceeding in the amount of $3,250.00.
CF6-15A
Conclusions of Law
Petitioner and Respondent agree that, based on the foregoing findings of fact, the
following Texas Disciplinary Rules of Professional Conduct have been violated.
Accordingly, the Evidentiary Panel concludes that the following Texas Disciplinary Rules
of Professional Conduct have been violated: 4.01 (a), 3.04(d), 8.02(a), 8.04(a)(3).
Sanction
CF615A
8.
9.
Upon information that Respondent has violated a term of this judgment, the Chief
Disciplinary Counsel may, in addition to all other remedies available, file a motion to
revoke probation pursuant to Rule 2.23 of the Texas Rules of Disciplinary Procedure with
the Board of Disciplinary Appeals ("BODA") and serve a copy of the motion on
Respondent pursuant to Tex.R.Civ.P. 21a.
BODA shall conduct an evidentiary hearing. At the hearing, BODA shall determine
by a preponderance of the evidence whether Respondent has violated any term of this
Judgment. If SODA finds grounds for revocation, BODA shall enter an order revoking
probation and placing Respondent on active suspension from the date of such revocation
order. Respondent shall not be given credit for any term of probation served prior to
revocation.
It is further ORDERED that any conduct on the part of Respondent which serves
as the basis for a motion to revoke probation may also be brought as independent
grounds for discipline as allowed under the Texas Disciplinary Rules of Professional
Conduct and Texas Rules of Disciplinary Procedure.
CF615A
SIGNED this
_j__ day of ~
'2016.
CF6-15A
Savan
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District 8-6 Presiding Member
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Respondent
CF615A
Exhibit C - Order
No. 13-0826-K277
v.
CRISPIN JAMES HARMEL
DISTRICT COURT OF
WILLIAMSON COUNTY
ORDER
The parties, attorneys, and employees of the attorneys in this case are
prohibited from communicating with the press/media regarding this case or
publicly commenting on this case during the pendency of the proceedings .
..
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day of
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Kennon
Presiding dge
368 1h District Court
Williamson County, Texas
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On July 10, 2015, Respondent Jana Duty filed a Motion to Recuse the Honorable
On July 13, 2015, the filing of the Motion to Recuse Judge Rick Kennon was
acknowledged by Judge Billy Ray Stubblefield, Presiding Judge, Third Administrative Region,
and in said acknowledgment, Judge Stubblefield appointed this Court, Judge Doug Shaver, to
hear the Motion to Recuse and to make such orders as justice may require.
3.
On July 22, 2015, Judge Rick Kennon signed an Order ofRecusal and transmitted
On July 29, 2015, the Amended Motion To Hold Jana Duty In Contempt was
filed.
Judgment Of Contempt And Order Of Commitment
Ex. Rel. Jana Duty I CAUSE NO. 15-0486-C368
5.
At the hearing on this matter on August 6, 2015, counsel for Jana Duty stated that,
in their capacity as counsel for Jana Duty, said counsel had received service of the July 29th
Amended Motion To Hold Jana Duty In Contempt on July 29, 2015, and that counsel for Jana
Duty stated on the record at the hearing on August 6, 2015 that Jana Duty expressly waived any
requirement that Jana Duty be personally served with said July 29 Amended Motion To Hold
Jana Duty In Contempt.
6.
The Court finds that the July 29, 2015 Amended Motion To Hold Jana Duty In
Contempt suggested to the court that respondent Jana Duty was and is in contempt of the 368th
District Court, Williamson County, Texas, the Honorable Rick Kennon,
intentional
stated
in open
failure
to appear
her
as
by reason of
on April
9, 2015, for
to the
May 7, 2015 email sent by Judge Rick Kennon of the 368th Judicial Court and thus
intentionally disrespecting the court, and for her intentional
displayed in her email
7.
disrespect
of the Court
On August 6, 2015, all parties and counsel appeared at 9:00AM, and the
court asked for and received the appearances of counsel as follows: Randy Howry and
Archie Carl Pierce announced their appearance as Special Prosecutors in this matter and
Perry Q. Minton and Samuel E. Bassett announced as counsel for Jana Duty. The court
asked whether the parties were ready to proceed to trial, and all parties, by and through
counsel, announced ready for trial.
Judgment Of Contempt And Order Of Commitment
Ex. Rei. Jana Duty I CAUSE NO. 15-0486-C368
that Jana Duty was and is hereby found guilty of contempt of the 368th
District Court as alleged in Count 2 of the Amended Motion To Hold Jana Duty
In Contempt, because her contact of and communication with reporter for the
Austin American Statesmen on or about May 6, 2015 regarding the State of Texas
v. Crispin Harmel was an intentional disobedience to and violation of the Court's
written order entered on April 9, 2015 that prohibited the attorneys in the case of
State of Texas v. Crispin Harmel "from communicating with the press/media
regarding this case or publically commenting on this case during the pendency of
the proceedings." Jana Duty intentionally violated the orders of March 31, 2015
and April9, 2015 by contacting Claire Osborn, a reporter for the Austin American
Statesmen, on May 6, 2015 for the express purpose of discussing the case of State
of Texas v. Crispin Harmel. Said intentional communications by Duty with the
reporter in violation of the court's order appeared in a published article as
evidenced by Movant's Exhibit 6.
(3)
that Jan Duty was and is hereby found guilty of contempt of the 368th
District Court, as alleged in Count 3 of the Amended Motion To Hold Jana Duty
In Contempt, for her intentional failure to appear in the 368th Judicial District
Court in the case of State of Texas v. Crispin Harmel May 7, 2015 at 10:30 a.m.,
such failure to appear being an intentional disrespect to the authority and office of
the 368th Judicial District Court and such conduct tending to bring the 368th
Judicial District Court into disrespect. Jana Duty received and had personal
Judgment Of Contempt And Order Of Commitment
Ex. Rei. Jana Duty I CAUSE NO. 15-0486-C368
8.
filed by non-party Claire Osborn, a reporter for the Austin American-Statesman in connection
with a subpoena served on her on Monday, August 3, 2015.
Chapter 22 of the TEXAS
based on
CNIL
arguments of counsel, the court ultimately sustained the objection to the subpoena of Claire
Osborne.
9.
or asserted by any party, and all parties announcing ready for trial, the court thereafter
proceeded to swear witnesses, place same under the rule, and to hear opening statements
and to hear the evidence.
12.
thereafter pronounced judgment on guilt or innocence as set forth below. Thereafter, the
court reopened the proceedings and received evidence and heard argument in the
punishment phase of the proceedings.
13.
After consideration of the Amended Motion To Hold Jana Duty In Contempt, the
evidence - - in both the guilt or innocence phase and the punishment phase - - and all exhibits
admitted into evidence, and the arguments and remarks of counsel, THE COURT HEREBY
FINDS AND AS FOLLOWS:
(a)
(b)
that the Amended Motion To Hold Jana Duty In Contempt is in all respects proper
and sufficient;
Judgment Of Contempt And Order Of Commitment
Ex. Rei. Jana Duty I CAUSE NO. 15-0486-C368
(c)
that Jana Duty was in all respects afforded due and proper notice of these
proceedings;
(d)
that counsel for Jana Duty received the Amended Motion To Hold Jana Duty In
Contempt;
(e)
that Jana Duty, by and through her counsel, expressly waived personal service of
follows:
(1)
that Jana Duty, was and is hereby found guilty of contempt of the 368th
Harmel to prohibit the attorneys from talking to the media for any reason. Jana
Duty intentionally violated the orders of March 31, 2015 and April 9, 2015 by
contacting Claire Osborn, a reporter for the Austin American Statesmen, on May
6, 2015 for the express purpose of discussing the case of State of Texas v. Crispin
Harmel. Said intentional communications by Duty with the reporter in violation of
Judgment Of Contempt And Order Of Commitment
Ex. Rel. Jana Duty I CAUSE NO. 15-0486-C368
knowledge of a May 7, 2015 email sent by Judge Rick Kennon of the 368th
Judicial District Court which requested her to appear in the 368th Judicial District
Court on May 8, 2015 at 10:30 a.m. Jana Duty failed to appear in Court on May 8,
2015 as requested by Judge Rick Kennon of the 368th Judicial District Court. Jana
Duty was physically available to appear in Court on May 8, 2015 as requested by
Judge Rick Kennon of the 368th Judicial District Court. Jana Duty was available
to appear in court at said time. Jana Duty's intentional failure to appear in Court
on May 8, 2015 as requested by Judge Rick Kennon of the 368th Judicial District
Court was an intentional disrespect of the Court on her part.
(4)
that Jana Duty was and is hereby found guilty of contempt of the 368th
District Court,
In Contempt, for her intentional disrespect to the authority and office of the 368th
Judicial District Court by her use of the language, statements, and
communications directed to the 368th Judicial District Court in her email May 8,
2015 4:06 p.m. and also published to other counsel of record in the underlying
criminal case as follows:
"This meant one of two things, one, it wasn't that
important or two, you did not respect me enough to
give me an answer. Your next response was, "be
in my courtroom at 10:30," even tho [SIC] I had
not responded that that time would work for me, nor
had you answered my question."
"To get an email at 5:30 saying "can you be here?"
then ignoring my request for an explanation as to
why, followed by "be here at 10:30" reeked of
disrespect. I felt, if you do not respect me enough
to give me the information I requested, I will not
give you respect and show up."
Judgment Of Contempt And Order Of Commitment
Ex. Rel. Jana Duty I CAUSE NO. 15-0486-C368
The court finds beyond a reasonable doubt that the conduct as set out
above of Jana Duty with respect to Counts 1, 2, 3, and 4 was criminal contempt of
the 368th District Court in that Jana Duty intentionally obstructed or tended to
obstruct the administration of justice, Jana Duty engaged in intentional conduct
which was in opposition to and was an intentional defiance of the authority and
dignity of the 368th Judicial District Court or its processes, Jana Duty engaged
in conduct which was intentionally disrespectful to the authority of and office of
the 368th Judicial District Court, and Jana Duty engaged in intentional which
tended to bring the 368th Judicial District Court into disrespect.
IT IS THEREFORE, ORDERED, ADJUDGED AND DECREED by this Court that
Relator Jana Duty is;
1. Guilty beyond a reasonable doubt of criminal contempt of the 368th District Court of
Williamson County, as alleged in Count 1 of the Amended Motion To Hold Jana
Duty In Contempt;
2. Guilty beyond a reasonable doubt of criminal contempt of the 368th District Court of
Williamson County, as alleged in Count 2 of the Amended Motion To Hold Jana
Duty In Contempt;
3. Guilty beyond a reasonable doubt of criminal contempt of the 368th District Court of
Williamson County, as alleged in Count 3 of the Amended Motion To Hold Jana
Duty In Contempt;
4. Guilty beyond a reasonable doubt of criminal contempt of the 368th District Court of
Williamson County, as alleged in Count 4 of the Amended Motion To Hold Jana
Duty In Contempt;
IT IS FURTHER ORDERED, ADJUDGED, AND DECREED by the Court that the
following punishments are imposed on Relator Jana Duty for these several acts of contempt set
forth above which the court has found to exist beyond a reasonable doubt:
1.
10 days confinement in jail and a $500.00 fine for her contumacious conduct
found to exist by the Court as alleged in Count 1 of the Amended Motion To Hold
Jana Duty In Contempt;
2.
10 days confinement in jail and a $500.00 fine for her contumacious conduct
found to exist by the Court as alleged in Count 2 of the Amended Motion To Hold
Jana Duty In Contempt;
3.
10 days confinement in jail and a $500.00 fine for her contumacious conduct
found to exist by the Court as alleged in Count 3 of the Amended Motion To Hold
Jana Duty In Contempt;
4.
10 days confinement in jail and a $500.00 fine for her contumacious conduct
found to exist by the Court as alleged in Count 4 of the Amended Motion To Hold
Jana Duty In Contempt;
/b
a,Jiv=---=__
Doug Shaver, Judge Presiding