On May 02, 2022 a
Motion-Secondary
was filed
involving a dispute between
Baukus, Nicole Nadra,
and
Engle, Scott J.,
Nash, Jamie B.,
for Injury/Damage - Other
in the District Court of Galveston County.
Preview
Received 6/14/2022 3:26 PM
Envelope No. 65434244
CAUSE NO. 22-CV-0763
Nicole Nadra Baukus § In the District Court of
Plaintiff, §
v. §
§ Galveston County, Texas
Scott J. Engle, individually; Jamie §
B. Nash, individually; and Scott J. §
Engle, d.b.a. Montgomery County §
Police Reporter § 405th Judicial District
Defendants. §
ORDER IMPOSING SANCTIONS
On __________________, a hearing was held on the motion of NICOLE
NADRA BAUKUS, Movant, for sanctions pursuant to Section 10.001 et. seq. of the
Texas Civil Practice and Remedies Code in the above-styled and numbered cause.
After considering the motion, response, pleadings, evidence and the arguments of
counsel, the court is of the opinion that Movant’s motion should be GRANTED and
in support thereof, the Court finds the following:
The Court finds good cause exists to sanction SCOTT ENGLE, JAMIE
NASH, SCOTT ENGLE d.b.a. MONTGOMERY COUNTY POLICE REPORTER,
and Nicholas R. Dillard because of the following:
1. Defendants’ Motion to Transfer Venue was served on Movant on May 31,
2022, and was presented for an improper purpose and has a claim, defense or other
1
legal contention that is not warranted by existing law or by a nonfrivolous argument
for the extension, modification or reversal of existing law or the establishment of
new law; each allegation or other factual contention does not have evidentiary
support and is not likely to have evidentiary support after a reasonable opportunity
for further investigation or discovery; each denial is not warranted on the evidence
or is not reasonably based on information or belief because Defendants’
misrepresented Texas Supreme Court case law regarding the date of accrual of a
libel claim when published in the media and ignored Texas’ mandatory venue
statutes applicable to this case which require that this case shall be heard in
Galveston County, Texas.
The Court finds that SCOTT ENGLE, JAMIE NASH, SCOTT ENGLE d.b.a.
MONTGOMERY COUNTY POLICE REPORTER, and Nicholas R. Dillard were
responsible for the above because they are responsible for the filing and service of
the motion.
IT IS THEREFORE ORDERED that SCOTT ENGLE, JAMIE NASH,
SCOTT ENGLE d.b.a. MONTGOMERY COUNTY POLICE REPORTER, and
Nicholas R. Dillard, for violating § 10.001 et. seq. of the Texas Civil Practice and
Remedies Code, are hereby sanctioned. The imposed sanctions shall be:
1. That the violators refrain from performing such and act again;
2. That the violators pay a penalty into the Court registry of $_______________.
2
IT IS FURTHER ORDERED that SCOTT ENGLE, JAMIE NASH, SCOTT
ENGLE d.b.a. MONTGOMERY COUNTY POLICE REPORTER, and Nicholas R.
Dillard pay $_____________ as reasonable attorney’s fees and pay $____________
as reasonable expenses to NICOLE NADRA BAUKUS.
SIGNED an ENTERED on _________________.
____________________________________
JUDGE PRESIDING
3
APPROVED AS TO FORM:
KETTERMAN LAW, PC
By: /s/ Julie A. Ketterman
Julie A. Ketterman
Texas Bar No. 24013722
Email: service@kettermanlawpc.com
PO Box 359
Pearland, Tx 77588
Tel. (713) 725-2817
Attorney for Plaintiff
Nicole Nadra Baukus
4
Automated Certificate of eService
This automated certificate of service was created by the efiling system.
The filer served this document via email generated by the efiling system
on the date and to the persons listed below. The rules governing
certificates of service have not changed. Filers must still provide a
certificate of service that complies with all applicable rules.
Frank Powell on behalf of Julie Ketterman
Bar No. 24013722
fpowell@texasdefender.com
Envelope ID: 65434244
Status as of 6/14/2022 3:30 PM CST
Associated Case Party: NicoleNadraBaukus
Name BarNumber Email TimestampSubmitted Status
Julie A.Ketterman service@kettermanlawpc.com 6/14/2022 3:26:43 PM SENT
Margaret Frost mfrost@texasdefender.com 6/14/2022 3:26:43 PM SENT
Frank Powell fpowell@texasdefender.com 6/14/2022 3:26:43 PM SENT
Associated Case Party: ScottJ.Engle
Name BarNumber Email TimestampSubmitted Status
Nicholas RDillard nicholas.dillard@talltexaslaw.com 6/14/2022 3:26:43 PM SENT
Document Filed Date
June 14, 2022
Case Filing Date
May 02, 2022
Category
Injury/Damage - Other
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Preview
Received 6/14/2022 3:26 PM Envelope No. 65434244 CAUSE NO. 22-CV-0763 Nicole Nadra Baukus § In the District Court of Plaintiff, § v. § § Galveston County, Texas Scott J. Engle, individually; Jamie § B. Nash, individually; and Scott J. § Engle, d.b.a. Montgomery County § Police Reporter § 405th Judicial District Defendants. § ORDER IMPOSING SANCTIONS On __________________, a hearing was held on the motion of NICOLE NADRA BAUKUS, Movant, for sanctions pursuant to Section 10.001 et. seq. of the Texas Civil Practice and Remedies Code in the above-styled and numbered cause. After considering the motion, response, pleadings, evidence and the arguments of counsel, the court is of the opinion that Movant’s motion should be GRANTED and in support thereof, the Court finds the following: The Court finds good cause exists to sanction SCOTT ENGLE, JAMIE NASH, SCOTT ENGLE d.b.a. MONTGOMERY COUNTY POLICE REPORTER, and Nicholas R. Dillard because of the following: 1. Defendants’ Motion to Transfer Venue was served on Movant on May 31, 2022, and was presented for an improper purpose and has a claim, defense or other 1 legal contention that is not warranted by existing law or by a nonfrivolous argument for the extension, modification or reversal of existing law or the establishment of new law; each allegation or other factual contention does not have evidentiary support and is not likely to have evidentiary support after a reasonable opportunity for further investigation or discovery; each denial is not warranted on the evidence or is not reasonably based on information or belief because Defendants’ misrepresented Texas Supreme Court case law regarding the date of accrual of a libel claim when published in the media and ignored Texas’ mandatory venue statutes applicable to this case which require that this case shall be heard in Galveston County, Texas. The Court finds that SCOTT ENGLE, JAMIE NASH, SCOTT ENGLE d.b.a. MONTGOMERY COUNTY POLICE REPORTER, and Nicholas R. Dillard were responsible for the above because they are responsible for the filing and service of the motion. IT IS THEREFORE ORDERED that SCOTT ENGLE, JAMIE NASH, SCOTT ENGLE d.b.a. MONTGOMERY COUNTY POLICE REPORTER, and Nicholas R. Dillard, for violating § 10.001 et. seq. of the Texas Civil Practice and Remedies Code, are hereby sanctioned. The imposed sanctions shall be: 1. That the violators refrain from performing such and act again; 2. That the violators pay a penalty into the Court registry of $_______________. 2 IT IS FURTHER ORDERED that SCOTT ENGLE, JAMIE NASH, SCOTT ENGLE d.b.a. MONTGOMERY COUNTY POLICE REPORTER, and Nicholas R. Dillard pay $_____________ as reasonable attorney’s fees and pay $____________ as reasonable expenses to NICOLE NADRA BAUKUS. SIGNED an ENTERED on _________________. ____________________________________ JUDGE PRESIDING 3 APPROVED AS TO FORM: KETTERMAN LAW, PC By: /s/ Julie A. Ketterman Julie A. Ketterman Texas Bar No. 24013722 Email: service@kettermanlawpc.com PO Box 359 Pearland, Tx 77588 Tel. (713) 725-2817 Attorney for Plaintiff Nicole Nadra Baukus 4 Automated Certificate of eService This automated certificate of service was created by the efiling system. The filer served this document via email generated by the efiling system on the date and to the persons listed below. The rules governing certificates of service have not changed. Filers must still provide a certificate of service that complies with all applicable rules. Frank Powell on behalf of Julie Ketterman Bar No. 24013722 fpowell@texasdefender.com Envelope ID: 65434244 Status as of 6/14/2022 3:30 PM CST Associated Case Party: NicoleNadraBaukus Name BarNumber Email TimestampSubmitted Status Julie A.Ketterman service@kettermanlawpc.com 6/14/2022 3:26:43 PM SENT Margaret Frost mfrost@texasdefender.com 6/14/2022 3:26:43 PM SENT Frank Powell fpowell@texasdefender.com 6/14/2022 3:26:43 PM SENT Associated Case Party: ScottJ.Engle Name BarNumber Email TimestampSubmitted Status Nicholas RDillard nicholas.dillard@talltexaslaw.com 6/14/2022 3:26:43 PM SENT