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CAUSE NO.

25,959

CODY WOMMACK,
Contestant,
v.
MIKE ALCORN,
MARIE SKIPPER
Contestees.

IN THE DISTRICT COURT

OF MORRIS COUNTY, TEXAS

176th JUDICIAL DISTRICT

PETITIONERS MOTION TO ENJOIN V. JAY YOUNGBLOOD


FROM REPRESENTING OR ADVISING CONTESTEES
TO THE HONORABLE JUDGE OF SAID COURT

Now comes Contestant Cody Wommack, represented pro se, and makes this motion for
temporary restraining order; temporary and permanent injunction, that the Court enjoin Virgil Jay
Youngblood, attorney for Contestees Mike Alcorn and Marie Skipper, from advising or representing
said Contestees.
FACTUAL BACKGROUND

1.

The Contestant states on information and belief that Mr. Youngblood is representing the

Contestees pro bono. This action is taken in bad faith because there is no way to separate the
payment received by Mr. Youngblood in his employ with the school district and the payment that he
is supposedly foregoing to represent the Contestees pro bono. Further, if it is accepted that Mr.
Youngblood is donating his time and representation to benefit the personal interests of two
government officials, that is bribery in the amount of the market value of Mr. Youngbloods
representation.

2.

It is also a conflict of interest that the school attorney is representing the public interest,

including the interest of the Contestant, at the same that he is representing the private interests of
the Contestees. The school district is not a party to this suit.
3.

As members of the Daingerfield-Lone Star Independent school board of trustees, the

Contestees have the official role of directly hiring and approving the school attorney. Therefore, the
school attorney is a contractor who is offering the value of his legal representation as a gift.
4.

Mr. Youngblood is fully aware of the fact that the outcome of the election contest is legally

equivalent to the outcome of an election. Daingerfield-Lone Star Independent School District who
employs him must remain neutral. No public monies can be expended for what is a personal interest
of the Contestees according to the Texas Constitution art. III, ss 50, 51, 52. Contestant Cody
Wommack has publicly stated this in an online discussion where he referenced 3 separate Attorney
General Opinions. Mr. Youngblood offered the Contestants public declaration of this fact as
evidence to the Court. The fact that Mr. Youngblood is not accepting payment directly for legal
services means he knew that he couldnt be compensated and is circumventing both the spirit and
letter of the law.
PRAYER
WHEREFORE, Contestant Cody Wommack prays that this Court grant the Contestants
motion to enjoin V. Jay Youngblood, attorney for Daingerfield-Lone Star Independent School
District, from further representing or advising Contestees Mike Alcorn and Marie Skipper.
Contestant further prays that the Court grants such other relief as Contestant may be properly
awarded.

Respectfully submitted,
__________________________
Cody Wommack, pro se
220 Haley
Lone Star, TX 75668
979-229-5805
codywommack@gmail.com

CERTIFICATE OF SERVICE

I certify that a true and correct copy of the above was served on the attorney of record for
both parties by certified mail in accordance with the Texas Rules on Civil Procedure on August 24,
2016:

Jay Youngblood
State Bar of Texas No. 22220200
jyoungblood@powell-leon.com
POWELL & LEON, L.L.P
1001 ESE Loop 323, Suite 450
Tyler, Texas 75701

__________________________
Cody Wommack