respect forthe for theJudge, Judge,SCHWAGER SCHWAGER
voluntarily voluntarily agreed agreed to takethe to take objectionable the objectionable videos downduring videos down during the pendencyooff the the pendency the TEMPORARY TEMPORARY INJUNCTION INJUNCTIONhearing. hearing.TheAgreement isreflected The Agreementis n theJuly30,2014 reflected oon the July 30, 2014
transcript. transcript.
6. DEFENDANTS 6. DEFENDANTS presented no MOTION presented no MOTION F ORGAG FOR ORDER d GAG ORDER espitetthe despite heCourt's invitation Court's invitation to to
dothe do untilOCTOBER sameuntil the same OCTOBER 9,2014 - the same 9, datethe samedate thehearing theirsanctions ontheir hearing on motions sanctions motions
occurred. occurred. Significantly, JILL YOUNG, JILL YOUNG, RUSSJONES RUSS JONESANDDEFENDANTS AND DEFENDANTSparticipated inaa participated in
fourday four temporary day temporary injunction injunction hhearing earingin whichthe in which PLAlNTIFFS' the PLAINTIFFS' claimsfor claims false for false
imprisonment, imprisonment, assault andbattery, assault and battery, conspiracy, conspiracy, breach breach of trust, a of trust, ndbreach and offiduciary duty breach of duty wereproven were provenw ithcredible with credible evidence, evidence, if if not not asa matter oflaw.Ifthey as a matter believed of law. If they believed PLAINTIFFS' PLAINTIFFS' ORIGINAL, ORIGINAL, FIRSTORSECOND AMENDED FIRST OR SECOND AMENDED PETITIONS PETITIONS were frivolousor were frivolous groundless or groundless in in violation violation ofRule of I0,13, Rule 10, or91a - or 13, or thatPLAIN 9la - orthat TIFFShad PLAINTIFFS standing nostanding had no toassert to them,any assert them, anyone one offive of fiveattorneys attomeys couldhave could haveasserted appropriate asserted appropriate MOTIONS MOTIONS TODISMISS TO PLAINTIFFS' DISMISS PLAINTIFFS' lawsuit. lawsuit. Notably, none ofthem Notably, none filedany of them filed suchMOTION. any such MOTION.
Silverado Appx. 0530 No. 1-15-567-CV 1619 7. DEFENDANTS' counsel, 7. DEFENDANTS' JILL YOUNG counsel, JILL RUSS J AND RUSS YOUNG AND ONES JONES aalllljoined together joined together inmost in most pleadings filedby regardless oneanother regardless filed by one ofwhether of whether SARAH SARAH PACHECO PACHECO ANDHER AND HER
CLIENTS CLIENTS were taking were taking a 180 degree d 180degree iversion diversion from prior p from prior ositions positions or not. or Themost not. The egregious mostegregious example example thefact isthe is thatJILL fact that YOUNG, JILL YOUNG, RUSS JONES, RUSSJONES, ANDTHE AND COURT THECOURT INVESTIGATOR INVESTIGATOR
concludedpprior all concluded all riorto 2014thatthe MARCH2014 to MARCH Guardianship that the Guardianship Application Application hhad ad no meritand no merit and
shouldbedismissed should dueto be dismissed due to less alternatives, lessrestrictive alternatives, suchas such DurablePower asaa Durable ofAttorney- Powerof Attorney -
butchanged but theiropinions changed their basedsolely opinions based solelyon unambiguous onunambiguous loyalty loyalty SARAH toSARAH to PACHECO. PACHECO.
Nothing Nothing inthis in changed matterchanged this matter to justifythe tojustify theabout facedecision about face ofJILL decision of YOUNG JILL YOUNG RUSS orRUSS or
JONES' JONES' support ofDEFENDANTS, supportof DEFENDANTS, except for"who" exceptfor theapplicant. wasthe "who" was applicant.
8. Bias 8. Bias was repeatedly was repeatedly demonstrated demonstrated byJONES by JONES A AND YOUNG p NDYOUNG riorttooSCHWAGER'S prior SCHWAGER'S lawsuit lawsuit
beingfiled and everbeing ever andseemingly immediately seemingly immediately upon theGuardianship uponthe Application's Guardianship Application's filing
December December l0,2013.Shortly 10, 2013. Shortly after appointment, afterappointment, both JONES bothJONES andYOUNG and YOUNG spent lessthan spentless