In Bisby v. Dow Chem. Co., 931 S.W.2d 18 (Tex. App.--Houston 1st Dist. 1996, no writ), Dow sought exemplary damages against Bisby for recording of improper liens, for her refusal to remove the cloud on Dow's title, and for returning a letter sent to her by Dow. Bisby did not attend trial and the trial court signed a default judgment against her. Id. at 20. In its judgment, the trial court imposed sanctions against Bisby based on her "filing the three pleadings in this case entitled 'This affidavit is a refusal for Cause Without Dishonor U.C.C. 3-501 and Notice of Default and Notice of Acquiescence of Lien Debtors to Validity of Bona Fide Liens.'" Id. at 21. Bisby appealed by writ of error, challenging the sanctions award based on lack of notice. Id. Dow contended that, because it had included a provision in its original petition that requested exemplary damages, Bisby was on notice that sanctions may be levied against her. Id. The Court concluded that the trial court erred by assessing sanctions because Dow did not seek sanctions based on Bisby's filing of the three pleadings mentioned in the trial court's judgment. Id. In reversing the sanctions award, the Court wrote: "Bisby was denied the opportunity to have a hearing and present evidence to demonstrate that her pleadings were not groundless, brought in bad faith or meant to harass. Because Bisby was not put on notice that sanctions would be imposed upon her for filing the three above-described pleadings, the trial court erred in assessing sanctions." Id.