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Jason did not understand in real time that he needed to call himself as a witness immediately. That issue consumed approximately fifteen minutes of the limited time available. Petitioner's counsel then repeatedly objected "hearsay" when Jason attempted to read or identify prior prior representations. Jason was unable to overcome those objections in the compressed setting. Asa result: 1. No meaningful exhibit record was admitted. 2. No Rule 1006 summary chart was admitted and tested. 3. No complete production-gap chart was admitted and tested. 4. No sourc...
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EXHIBIT INDEX Exhibit 1 Order Reserving Sanctions, Fee Shifting, Estate Reconstitution, Adverse Inferences, And Healthcare Enforcement For Further Hearing Exhibit 2 Order Granting Leave to Issue Third-Party Subpoenas for Financial, Lease, QLE, Benefits, And Estate Source Records Exhibit 3 Order Granting Leave to Issue Third-Party Subpoenas Concerning April16 Theft, Movers, Security, Contractors, And Chain of Custody Exhibit 4 Subpoena Targets Exhibit 5 Respondent's Motion for Enforcement, Sanctions, Continuance, And Leave to Issue Third-Party Subpoenas E...
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Exhibit -7 Continued. EXHIBIT INDEX Exhibit Title Purpose Procedural history demonstrating repeated filings, unresolved motions, - Exhibit A Motion to Recuse Pleading History discovery disputes, and case-management failures. Notice to Petitioner and counsel regarding discovery deficiencies, Exhibit B Discovery Email missing records, and requests for compliance. Demonstrates Respondent's financial condition, expenses, inability to Exhibit C Sworn Budget absorb continued delay, and need for relief. High Liquidity While Declaring Contradicts claims of finan...
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Respondent has previously included characterizations of Petitioner's finances in PHV-objection or related briefing, including alleged credit-card overpayments and alleged missing funds, such as $67,000 and $650,000 figures. Those figures appear only in Respondent's PHV-objection briefing and are not tied to any produced source document in the May 26 Motion. To the extent Respondent attempts to introduce those characterizations at this hearing, Petitioner objects on grounds including foundation, authentication, hearsay, relevance, Rule 403, and lack of co...
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IV. THE DISTRICT JUDGE MUST HEAR EVIDENCE, NOT MERELY REVIEW THE REPORT Jason requests a full evidentiary de novo hearing. At the de novo hearing, Jason requests permission to present: 1. Jason McKemie's sworn testimony; 3. Petitioner's sworn financial materials; 4. Jonathan Drake Steele's affidavit and fee/protective-expense request; 5. production indexes and Bates logs; 6. Rule 1006 source-record summary charts; 7. missing-statement and account-continuity charts; 8. VEIP/equity/payroll/Accenture compensation records; 9. HSA/FSA/healthcare/OLE/benefits...
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Jason objects to entry of any order reducing the Associate Judge's Report into an enforceable order before the referring District Judge conducts de novo review. Jason further objects to any proposed order submitted by Petitioner, Petitioner's counsel, or any person acting for Petitioner that: 1. expands the Associate Judge's Report; 2. adds findings not made at the hearing; 3. converts the denial into a trial-readiness finding; 4. grants or preserves Petitioner's protective order; 5. grants or preserves Petitioner's fees, costs, protective expenses, vend...
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Jason therefore requests that the Court immediately continue or abate the June11,2026 trial setting until: 1. the District Judge conducts the de novo hearing; 2. the Court makes written rulings on each specified issue; 3. third-party source-record subpoenas are authorized and returned; 4. healthcare/HSA/FSA/OLE/benefits issues are enforced; 5. stolen-evidence non-access, non-use, preservation, and return relief is entered; 6. Petitioner's protective-order and fee/protective-expense requests are denied in full; 7. the Court determines whether the marital...
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6. CONTINUE or ABATE the June 11,2026, trial setting until the marital estate can be reconstructed from complete, continuous, source-verifiable records; 7. DENY Petitioner's Counter-Motion for Protective Order in full to the extent it blocks, restricts, burdens, delays, chills, or prevents source-record verification; 8. DENY Petitioner's request for attorney's fees, court costs, protective expenses, expert/vendor expenses, discovery expenses, or any cost shifting against Jason McKemie in full, with no later prove-up, no reserved entitlement, and no cost...
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16.PRESERVEandSETFORHEARINGJason McKemie's requests for fraud-on-the- community findings, fraud-upon-the-Court findings, estate reconstitution under Texas Family Code § 7.009, disproportionate division under Texas Family Code § 7.001, adverse inferences, reimbursement, add-backs, fee shifting against Petitioner and responsible counsel, sanctions, healthcare enforcement, stabilization relief, and April 16 theft remedies; 17.REQUIREwritten rulings on every item granted, denied, or otherwise decided, identifying whether any denial is based on lack of eviden...
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hearing before the June 11,2026trial setting; and require written rulings identifying whether each item is granted, denied, deferred for separate setting, or not reached. sanctions motion. Jason requests de novo review of the sanctions, show-cause, counsel-certification, fee-shifting, protective-order abuse, and source-record verification issues to the extent those issues were already raised by the filings and hearing record before or at the June 1, 2026, hearing. To the extent the Court determines that any sanctions, counsel-certification, witness-prote...
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6. |was not provided the full amount of time originally allotted to present evidence and argument concerning enforcement, sanctions, continuance, third-party subpoena leave, source-record verification, healthcare enforcement, trial-readiness defects, stolen evidence repositories, and Petitioner's protective-order and fee/protective- expense requests. 7. When attempted to present evidence concerning written email communications between me and Petitioner's former counsel, Petitioner's counsel repeatedly | was attempting to identify, authenticate, objected...
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DALLAS CO., TEXAS NO DF-24-1801 re) THE MARRIAGE OF § § AND § MOTION FOR ENFORCEMENT, SANCTIONS, CONTINUANCE, AND LEAVE TO ISSUE THIRD-PARTY SUBPOENAS TO THE HONORABLE JUDGE OF SAID COURT: Jason McKemie files this Motion for Enforcement, Sanctions, Continuance, and Leave to Issue Third-Party Subpoenas and respectfully shows the Court as follows: I. RELIEF REQUESTED Trial is set for June 1 1, 2026. This motion requests multiple forms of relief, but the threshold issue for the June 1 hearing is trial readiness: No source records, no estate reconstruction....
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Il. PROCEDURAL AUTHORITY Texas Rule of Civil Procedure 190.5 authorizes the Court to modify a discovery-control plan at any time and requires modification when the interest of justice requires. This rule is directly implicated because new and materially changed circumstances now prevent trial readiness without third-party source records. Texas Rules of Civil Procedure 1 176 and 205.3 authorize third-party subpoenas and nonparty production of documents and tangible things. Texas Rules of Civil Procedure 215.2 and 215.3 authorize sanctions, fee shifting, a...
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In the 254th District Court, Respondent served discovery in good faith. Petitioner's legal team then moved to withdraw and remained absent during the discovery period. With approximately one hour Respondent's discovery, and approximately one hour later declared discovery closed. The same pattern repeated in the 302nd District Court. Respondent served discovery. Petitioner responded that Respondent had to identify and label every defect across thousands of pages of production. Respondent did that work. Petitioner then delayed for approximately two months...
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3. Credit-card balances paid off multiple times per month; 4. Significant overpayments to cards; 5. At least one card with approximately $67,000 in overpayments; 6. No reliable way to determine payment source from party-produced statements; 7. No reliable way to determine whether overpayments generated refunds, credits, transfers, or concealed liquidity; 8. No reliable account-lineage records connecting old card numbers, new card numbers, reissued cards, replacement cards, or linked accounts; 9. No single account with contiguous statements from August 20...
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6.. Payroll deductions; 7.. Employer reimbursements; 8. VEIP/equity investment activity; 9. Tax withholding versus equity contribution classification; 10. IRS/tax payments; 11. Loan origination and funding; 12. San Antonio housing reimbursement; 13. Lease payoff/buyout records; 14. Legal retainer payment sources; 15.Third-partycontractorpaymentsources; or 16.April 16 theft chain of custody. Only third-party source records can do that. If Petitioner has been fully forthcoming and compliant with discovery, then this will be a simple and painless process. T...
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Item Amount Total liquid asset value $195,000 Liability Effect of Mislabeling of Asset -$325,000 Total Variance in Estate Value $520,000 The net effect was the conversion of approximately $195,000 in liquid asset value into an apparent negative $325,000 liability, creating a more than half-million-dollar estate distortion. This cannot be tried on party summaries, tax emails, or screenshots. It requires employer-origin, payroll-origin, equity-plan-origin, tax-origin, and bank-origin source records. VII. VISUAL GAP CHART / RULE 1 006 SUMMARY Movant intends...
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1. The accounts cannot be mapped; 2. Account numbers cannot be tied to replacement cards; 3. Payments cannot be sourced; 4. Overpayments cannot be traced; 5. Credits/refunds cannot be located: 6. Loans cannot be authenticated; 7. Tax claims cannot be verified; 8. Employer reimbursements cannot be traced; 9. Legal and contractor spending cannot be allocated; and 10.The estate cannot be reconstructed. No source records, no estate reconstruction. No estate reconstruction, no final trial. IX. SAN ANTONIO HOUSING / RENT / EXPENSE REPORTS Petitioner's San Anto...
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X. DISSIPATION, WASTE, AND ADD-BACKS REQUIRING SOURCE RECORDS Movant requests third-party source-record discovery concerning dissipation, waste, reimbursement, and add-back issues, including: A. Elective Cosmetic Surgery e Petitioner pursued elective cosmetic surgery despite objection from Movant and Movant's prior counsel. Movant requests invoices, payment records, financing records, loan documents, card payments, bank payments, and any related communications so those amounts can be added back, reimbursed, offset, or charged to Petitioner's side of the...
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13. Risk-mitigation firms; 14. Reputational-defense vendors; 15. Due-diligence vendors; 16. Employment-interference vendors; 17. Investigators; 18.All My Sons; 19. Merritt McClayton; 20. Movers, storage providers, booking entities, and third-party payers; and 21.Anyentitypaidtoinvestigate,package,transmit,publish, or support claims against Movant. e Legal fees and legal-adjacent expenditures should be traced and allocated. Movant requests that legal fees be subject to 50% reimbursement/add-back where community funds were used, and that third-party contra...