In cases involving indirect contempt, which concern actions committed outside the presence of the court, adequate notice "must be given before the contempt hearing." Fox v. Fox, No. M2009-01884-COA-R3-CV, 2010 WL 4244356, at *6 (Tenn. Ct. App. Oct. 26, 2010); see TENN. R. CRIM. P. 42(b)(1). Mother asserts that she was not properly served with the original or amended verified motion for criminal contempt because the motions were served on her attorney and not on her personally.

Foster [v. Foster, No. M2006-01277-COA-R3-CV,] 2007 Tenn. App. LEXIS 796; 2007 WL 4530813, at *3 [(Tenn. Ct. App. Dec. 20, 2007)].Fox v. Fox, No. M2009-01884-COA-R3-CV, 2010 WL 4244356, at *2 n.4; 2010 Tenn. App. LEXIS 663, at *7-8 n.4 (Tenn. Ct. App. Oct. 26, 2010). The willful disobedience of any lawful order is punishable by criminal contempt.

Appellate courts do not consider the evidence in the light most favorable to the defendant and will only overturn criminal contempt convictions “when the evidence is insufficient to support the trier-of-fact's finding of contempt beyond a reasonable doubt.” Fox v. Fox, 2010 WL 4244356, at *3 (Tenn.Ct.App. Oct. 26, 2010) (citing Hawk v. Hawk, 855 S.W.2d 573, 583 (Tenn.1993)). “Furthermore, appellate courts review a trial court's decision of whether to impose contempt sanctions using the more relaxed abuse of discretion standard of review.”