“Defendant Mary Cummins was duty-bound to obey the commands of the Court contained in the judgment. Defendant failed and refused, and continues to fail and refuse to obey the commands of the Court. Specifically, Defendant has intentionally violated the Court’s order by failing and refusing to permanently remove the above-described statements from the internet. Each statement which Defendant failed and refused to permanently remove constitutes a separate act of contempt of court.
On return of such show cause order, the judge shall proceed to hear proof, and if satisfied that such person has disobeyed the injunction, either directly or indirectly, may commit such person to jail without bail until he purges himself of such contempt, in such manner and form as the judge may direct.
Because Defendant, Mary Cummins, continues to fail and refuses to obey the commands of the Court contained in the injunction, Movant has no alternative but to institute this contempt proceeding to have Defendant held in contempt of court and punished in accordance with Rule 692 of the Texas Rules of Civil Procedure.
WHEREFORE, Movant requests that Defendant, Mary Cummins, be ordered to appear before the Court at a designated date and time and show cause why she should not be held in contempt of court for violations of the injunction contained in the August 27, 2012 Final Judgment and punished accordingly.”