DF-24-18010 Litigation Record Search

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PETITIONER’S MOTION TO SIGN AND ENTER FINAL DECREE OF DIVORCE

2026-06-16 Petitioner / Gwendolyn Order 13 matching page(s)
2026-06-16 OUR Motion to Enter Final Decree Final.pdf
StatusHigh confidenceNeeds category review
Page 2PLEADING_BODY
8. At 4:28 p.m. on June 11, 2026, Petitioner sent a proposed Final Decree of Divorce to Respondent and the Court for the Court’s signature. the proposed decree (June 12, 2026) and recusal “supplements” (June 15 and June 16, (No. 05-26-00854-CV) on June 12, 2026. On June 15, 2026, the Court of Appeals returned and rejected five of the ten documents Respondent submitted in connection with that filing. No court has stayed these proceedings. III. ARGUMENT AND AUTHORITIES A. Respondent’s pending motion to recuse is a tertiary recusal motion, and Texas Civil P...
Page 3PLEADING_BODY
B. The motion to recuse is also untimely. 14. Independently, Respondent’s motion to recuse is untimely. It was electronically submitted at 1:21 p.m. on June 11, 2026 — nine minutes before the 1:30 p.m. trial setting, and long after “the tenth day before the date set for trial.” TEX. R. CIV. P. 18a(b)(1). Nothing indicates Respondent neither knew nor reasonably should have known of any asserted ground before that date. C. No stay is in effect; the mandamus filing does not divest this Court of authority. 15. The filing of a petition for writ of mandamus do...
Page 5PLEADING_BODY
THE MARRIAGE OF GWENDOLYN ULIJASZ-MCKEMIE AND JASON MCKEMIE FINAL DECREE OF DIVORCE On June 11, 2026, the Court heard this cause. 1. Appearances Petitioner, GWENDOLYN ULIJASZ-McKEMIE ("Wife"), appeared in person and through her attorneys of record, Jonathan D. Steele and Rebecca Lee Armstrong, announced ready for trial, and proved up her case on Petitioner's pleading and supersedes all prior petitions, including the December 2024 original pleading. Respondent, JASON EMORY McKEMIE (“Husband”), previously appeared and answered pro se. The Court finds this...
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Page 8PLEADING_BODY
W-2. All Accenture Restricted Stock Units (RSUs), vested and unvested, granted to or held in the name of Wife, including the unvested shares, together with all rights to vesting, dividends, and proceeds thereof. W-3. The Chase Checking account ending in x9259 together with all funds on deposit therein. W-4. The Accenture HSA account, together with all funds on deposit therein. W-5. The BMW automobile, together with all keys, title documents, and equipment, subject to the indebtedness thereon as allocated below. W-6. All clothing, jewelry, electronics, ho...
Page 1PLEADING_START
THE MARRIAGE OF § § AND § PETITIONER’S MOTION TO SIGN AND ENTER FINAL DECREE OF DIVORCE TO THE HONORABLE JUDGE OF SAID COURT: Petitioner, Gwendolyn Ulijasz McKemie, files this Motion to Sign and Enter Final Decree of Divorce and respectfully requests that the Court sign and enter the proposed Final Decree of Divorce submitted on June 11, 2026, and attached to this motion as Exhibit A. In support, Petitioner respectfully shows: I. INTRODUCTION 1. The Court heard the final trial in this matter on June 11, 2026. Petitioner appeared and presented evidence. R...
Page 6PROPOSED_ORDER_OR_ORDER
3. Jurisdiction and Domicile The Court finds that the pleadings of Petitioner are in due form and contain all the allegations, information, and prerequisites required by law. The Court, after receiving evidence, finds that it has jurisdiction of this cause and of all the parties and that at least sixty (60) days have elapsed since the date the suit was Respondent had been a domiciliary of Texas for the preceding six-month period ninety-day period. 4. Jury A jury was waived, and all questions of fact and of law were submitted to the Court. 5. Findings on...
Page 7PROPOSED_ORDER_OR_ORDER
8. Division of the Marital Estate The Court finds that the parties have entered into no agreement incident to divorce, that Respondent has wholly made default, and that the division set forth below is therefore ordered by the Court as a just and right division of the parties' marital estate, having due regard for the rights of each party. The Court further finds that the division of the community estate as set forth herein is just and right under the circumstances, including the short duration of the marriage, the disparity in earning capacity, the condu...
Page 9PROPOSED_ORDER_OR_ORDER
W-9. Any and all other community assets in Wife's name, possession, or control not otherwise awarded herein. B. Community Property Awarded to Husband IT IS ORDERED AND DECREED that Husband, JASON EMORY McKEMIE, is awarded the following as his sole and separate property, and Wife is divested of all right, title, interest, and claim in and to that property: H-1. Any and all bank, retirement, or investment accounts in his own name. H-2. The 2018 Jaguar F-Pace automobile, together with all keys, title documents, and equipment, subject to any indebtedness the...
Page 10PROPOSED_ORDER_OR_ORDER
S-4. The Advantigen Biosciences LLC membership units, confirmed as Wife's pre-marital separate property by clear and convincing evidence of inception of title. The Court makes no finding as to the current value of these units, the record containing no current valuation; the membership units themselves, whatever their value, are set aside to Wife as her separate property. S-5. Any and all other property shown by clear and convincing evidence to be Wife's separate estate, having been owned or claimed by her before the marriage, or acquired during the marri...
Page 11PROPOSED_ORDER_OR_ORDER
WD-2. The indebtedness secured by the BMW awarded to her above. WD-3. Any and all other debts, charges, liabilities, and obligations incurred solely by Wife from and after the date of marriage, except as expressly provided otherwise herein. F. Debts Divided Equally Between the Parties IT IS ORDERED AND DECREED that, notwithstanding any other provision of this Decree, the following community debts shall be divided equally between the parties, with each party ordered to pay fifty percent (50%) of the outstanding balance of each such debt, together with the...
Page 12PROPOSED_ORDER_OR_ORDER
10. Change of Name The Court finds that Petitioner specifically requested this name change and that GWENDOLYN LAURA ULIJASZ is a name previously used by Petitioner. IT IS ORDERED AND DECREED that the name of Petitioner, GWENDOLYN ULIJASZ-McKEMIE, is changed to GWENDOLYN LAURA ULIJASZ. 11. Court-Ordered Documents; Execution of Instruments; Turnover IT IS ORDERED AND DECREED that each party shall, at the request of the other party or the other party's counsel, execute, acknowledge, and deliver any deed, title, assignment, release, qualified domestic relati...
Page 13PROPOSED_ORDER_OR_ORDER
13. Costs IT IS ORDERED AND DECREED that costs of court are taxed against the party who incurred them. 14. Denial of Respondent's Counterpetition and Affirmative Relief IT IS ORDERED AND DECREED that Respondent, JASON EMORY McKEMIE, having failed to appear, prosecute, or proceed at trial, all relief requested in Respondent's Original Counterpetition for Divorce, his First Amended Counterpetition for Divorce, and any other pleading or request for affirmative 15. Finality This judgment finally disposes of all claims and all parties, is appealable, and is a...
Page 4CERTIFICATE_OF_SERVICE
CERTIFICATE OF CONFERENCE Respondent appears pro se. The undersigned conferred / attempted to confer with Respondent regarding the relief requested in this motion. Respondent is opposed, as reflected by his Emergency /s/____________________________ Jonathan D. Steele the Texas Rules of Civil Procedure on June 16, 2026: Respondent, Jason McKemie (pro se) via electronic filing manager. /s/__________________________ Jonathan D. Steele Petitioner’s Motion to Sign and Enter Final Decree of Divorce Page 4 of 4

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RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL

2026-06-15 Respondent / Jason Motion - Recuse 20 matching page(s)
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
StatusHigh confidenceNeeds category review
Page 2PLEADING_BODY
This Supplement does not reurge the same grounds asserted in the prior recusals. Each recusal arose from a distinct escalation point in an increasingly severe pattern of procedural breakdown, discovery obstruction, financial concealment, healthcare interference, and trial-preparation sabotage: e Recusal No. 1 addressed the 254th District Court's failure to hear emergency relief, discovery obstruction, medical collapse, and the procedural trap created when counsel withdrew during discovery and reappeared at the discovery deadline to file blanket objection...
Page 3PLEADING_BODY
4.Prohibit Petitioner, her counsel, experts, vendors, investigators, agents, contractors, or anyone acting with or for her from accessing, inspecting, imaging, copying, using, relying on, benefiting from, or receiving any derivative benefit from Jason's stolen hard drives, evidence repositories, trial binders, Apple devices, computers, records, tools, briefcase, passport, medications, or seized litigation materials. 5. Require third-party source verification before any decree is signed or enforced, including healthcare/HSA/FSA/OLE/COBRA records, Accentur...
Page 4PLEADING_BODY
ll. THE FIRST RECORDED EVENT IN THIS CASE MATTERS On January 7, 2025, at the protective-order hearing, Donna Tomlinson of Hargrave Family Law appeared and moved to withdraw from representing Petitioner. Judge Sandra Jackson expressed concern because serious allegations had been made, the matter involved a protective order, and a continuance had already been granted. Donna Tomlinson then stated on the record that proceeding forward with her representation of Gwendolyn Ulijasz-McKemie would violate her ethical oath as an officer of the court. That was not...
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Page 5PLEADING_BODY
Domestic Partnership, joint accounts, joint financial conduct, reciprocal powers of attorney, Ameriprise beneficiary documentation identifying the parties as spouses, and multiple witnesses, including the wedding officiant, confirming the relationship timeline. This evidence destroys the "short marriage" fiction. The decree should not be signed on a Marital timeline contradicted by signed declarations, domestic-partnership documents, powers of attorney, joint investment activity, joint accounts, beneficiary records, and witness testimony. VI. FINANCIAL I...
Page 6EXHIBIT_START
Vil. FALSE DESTITUTION, THIRD-PARTY CONTRACTORS, AND SOURCE- RECORD COLLAPSE Petitioner declared destitution while earning extraordinary income. Her February 7, 2026 Amended roa $150,000 signing bonus, a $34,225.57 cash bonus, Inventory and Appraisement ists Accenture equity, Accenture 401(k) value, Ameriprise IRA/Roth IRA balances, alleged loans, a BMW M340xi with a claimed $55,902 balance, and a Glock firearm. The same inventory advances a July 26, 2024 marriage date contradicted by the signed informal-marriage declaration and other relationship eviden...
Page 11EXHIBIT_START
XVII. FORMER-HUSBAND WITNESS AND ACTIVE WITNESS SUPPRESSION Recent filings from Christopher McNally, Petitioner's former husband and a material witness in this case, show protective-order-extension and fee/body-attachment challenges in Cook County, Illinois. Those filings identify overlapping counsel involvement and the use of protective-order restrictions and coercive relief in a manner that impaired or chilled McNally's ability to communicate or testify. Additional filings state that fees and body-attachment pressure risked impairing his ability to tes...
Page 17EXHIBIT_START
APPENDIX A UNSWORN DECLARATION OF CHRISTOPHER McNALLY My name is Christopher McNally. I am over eighteen years of age. My address is 228 Millbridge Rd., Riverside, Illinois 60546 and my birthday is August 24,1976. I am of sound mind, competent to make this declaration, and the facts stated below are within my personal knowledge and are true and correct. This declaration is provided only in response to subpoena/court testimony request and is not contact with Gwendolyn Ulijasz. I submit this declaration in response to a subpoena/request for sworn testimony...
Page 19EXHIBIT_START
related proceedings and/or body-attachment-type relief. The timing and nature of the proceedings during the July bench trial, and the recent June requests for body- attachment relief, appear calculated to disrupt my ability to comply with the subpoena and provide testimony as a material witness. 16. I have documents, records, messages, court papers, police reports, or other materials that may corroborate my testimony. 17. I Iam willing to appear for testimony, provide documents, and answer questions under oath, subject to appropriate court process and pr...
Page 7EXHIBIT_CONTINUATION
police-video evidence. IX. HEALTHCARE OBSTRUCTION IS LIFE-SAFETY, NOT ARGUMENT Healthcare is central to this Supplement because a decree signed on the proposed record would leave - Jason homeless, bankrupt, without transportation, without the - a man with congestive heart failure ability to afford COBRA, without functional HSA/FSA access, without surgeries, without reliable medication access, and without the practical ability to rebuild employment. Jason needs spinal surgery and surgery for a torn rotator cuff, ruptured bicep, and torn tendons. He has be...
Page 8EXHIBIT_CONTINUATION
Xl. SAPD RECORDS SHOW FALSE-REPORTING ESCALATION AND STOLEN-PROPERTY NARRATIVE SAPD Report No. SAPD26106749 records Petitioner attempting to frame Jason's HSA/benefit-access efforts as fraud. The officer told her it did not appear Jason was attempting to impersonate her, that Jason was authorized on the account, and that no criminal conduct appeared from the benefits-access conduct. The same report records that Petitioner then escalated into a statement that Jason drugged and raped her in 2024 while declining to make a sexual-assault report. SAPD Report...
Page 9EXHIBIT_CONTINUATION
- Two men also appeared and bragged about being paid approximately $500 per hour each approximately $1,000 per hour combined - to monitor or participate in the property event. Jason has their business card. Five hundred dollars would have preserved storage, bodycam, transcripts, or survival property. Petitioner claimed destitution while deploying paid resources at rates Jason could not access to save his own property. This was not ordinary moving. It was a hostile takeover of the residence under the cover of a manufactured writ. Xlill. STOLEN PROPERTY, C...
Page 10EXHIBIT_CONTINUATION
Those stolen hard drives and evidence repositories are Jason's separate property and stolen evidence. Petitioner, her counsel, experts, vendors, investigators, agents, contractors, and anyone acting with or for her must not be permitted to access, inspect, image, copy, use, rely upon, authenticate, test, review, receive, or benefit from those materials in any way. The only permissible relief is preservation of Jason's rights, categorical non-access, categorical non-use, sequestration away from Petitioner and her agents, and return to Jason. XV. ADDRESS C...
Page 12EXHIBIT_CONTINUATION
Jason cannot leave this litigation without enforceable protection against knowingly false criminal allegations, stolen-property-based accusations, healthcare interference, and witness suppression. Without intervention, this does not end. XIX. THE RECORD HAS BEEN SCREAMING FOR EIGHTEEN MONTHS The issue before the Court is no longer whether the parties disagree. The issue is whether this record can honestly be described as ordinary. This record contains more than 120 pleadings, more than 1,400 pages of filings, repeated requests for a court reporter, repea...
Page 13EXHIBIT_CONTINUATION
evidence needed to defend himself, without computers or tools needed to rebuild income, without access to bodycam/dashcam/transcript proof he cannot afford, with parents pulled into bankruptcy, with a father suffering dementia and deprived of memory-care stability, facing false criminal allegations, and at immediate risk of death from untreated or destabilized congestive heart failure and delayed surgical care. That is not a side issue. That is the emergency. XXI. PROPOSED WRITTEN FINDINGS REQUESTED BEFORE ANY DECREE ACTION testimony was taken, or trial...
Page 14EXHIBIT_CONTINUATION
14.The Court has been notified that Jason objects to any final decree, fee award, sanctions award, enforcement step, or trial ruling entered before written resolution of Recusal No. 3 and this Supplement. XXII. REQUEST FOR ORDER 15.grantrecusal or refer Recusal No. 3 and this Supplement for decision before any decree action; 16. stay rendition, signature, entry, transmission, enforcement, fee awards, sanctions, and decree action pending written recusal resolution; 17.orderimmediatethird-partysourceverification of healthcare, HSA/FSA, OLE, COBRA, plan ele...
Page 15EXHIBIT_CONTINUATION
Marriage timeline Sealed in-camera Shows proposed marital timeline is false submission; Declaration of and property division premise is Informal Marriage; domestic inverted. partnership; Ameriprise/POA/witness materials Healthcare ife-safety Healthcare PO materials; Shows decree could cut off medication, ERISA/EBSA notices; COBRA, surgery, HSA/FSA access, and Accenture/OLE/COBRA CHF stability. records; medical letters Financial collapse Amended Inventory; Shows false destitution, missing source discovery deficiency filings; records, alleged loans, and Ac...
Page 18EXHIBIT_CONTINUATION
5. Based on my personal experience, Gwendolyn Laura Ulijasz used legal proceedings and protective-order restrictions in a manner that impaired my ability to speak freely about her conduct, defend myself, communicate with relevant witnesses, or warn others. 6. I am aware that protective-order language or related restrictions have been used or asserted in a way that discourages or prevents me from communicating information about Gwendolyn Laura Ulijasz to third parties. 7. I am willing to testify despite concern that doing so may expose me to retaliation,...
Page 1PLEADING_START_FILE_MARKED
6/15/2026 9:53 AM IN THE MATTER OF THE MARRIAGE OF GWENDOLYN ULIJASZ-MCKEMIE AND FOR MANDATORY WRITTEN RULING BEFORE RENDITION, SIGNATURE, ENTRY, OR ENFORCEMENT OF ANY FINAL DECREE; AND NOTICE OF ADDITIONAL SOURCE EVIDENCE Notice for the Court: Because the Court is expected to determine whether to sign Petitioner's proposed decree today, Respondent is filing this Supplement immediately rather than delaying submission while exhibits are finalized. Additional supporting exhibits, affidavits, police records, timelines, and documentary evidence referenced he...
Page 16CERTIFICATE_OF_SERVICE
Jason McKemie 539 W. Commerce St., Ste. 2010 Dallas, TX 75208 214-868-4901 jmckemie@mckemie.net Gon. Jason McKemie Jason McKemie 539 W. Commerce St., Ste. 2010, Dallas, TX 75208 | 214-868-4901 jmckemie@mckemie.net 16 of 19 Copy from re:SearchTX
Page 20FILING_STAMP_OR_ESERVICE
on the date and to the persons listed below. The rules governing Envelope ID: 116127794 Filing Code Description: Motion - Recuse Filing Description: RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL Status as of 6/15/2026 10:43 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jeffrey ECook jcook@sullivancook.com 6/15/2026 9:53:54 AM SENT Rebecca LArmstrong rebecca@armstronglawtexas.com 6/15/2026 9:53:54 AM SENT Terra Aguirre terra@armstronglawtexas.com 6/15/2026 9:53:54 AM SENT Lauren N.Shaw lauren@armstronglawtexas.com 6/15/2026 9:...

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RESPONDENT'S VERIFIED MOTION TO RECUSE AND REQUEST FOR REFERRAL UNDER TEXAS RULE OF CIVIL PROCEDURE 18a

2026-06-11 Respondent / Jason Motion - Recuse 7 matching page(s)
VERIFIED MOTION TO RECUSE AND REQUEST FOR REFERRAL_8A0E2F01.pdf
StatusHigh confidenceNeeds category review
Page 2PLEADING_BODY
evidence theft, hard-drive theft, trial-material theft, false reporting, source-record concealment, and refusal to restore the conditions necessary for trial. Respondent is the party fighting to survive and obtain a fair trial; he is not the source of the obstruction. Respondent files this Motion despite the known risk because the new evidence and current posture do not merely warrant recusal - they demand it. There is no possibility of fair trial when the opposing party violated mutual injunctions, unlawfully entered the residence, stole the hard drives...
Page 3PLEADING_BODY
A reasonable person could question impartiality where the case is forced to final trial despite known structural impossibility, stolen evidence repositories, stolen hard drives, stolen trial materials, unavailable source financial records, unresolved healthcare/OLE records, unresolved de novo/trial- readiness issues, rejected or unresolved adequate-trial-time requests, and Respondent's present inability to safely appear or present evidence. NEW MATERIAL FACTS SINCE THE PRIOR RECUSAL PROCEEDINGS Since the prior recusal proceedings, Petitioner unlawfully e...
Page 4PLEADING_BODY
Petitioner siphoned approximately $650,000 from marital accounts, declared destitution, and eft Respondent carrying approximately $25,000 per month in marital-estate obligations while Petitioner earned approximately $125,000 per month and Respondent had no income, no counsel, no access to survival funds, and was recovering from spinal surgery. Petitioner then committed perjury through false sworn statements suggesting financial helplessness, while concealing substantial resources and spending heavily on counsel, vendors, investigators, and third-party li...
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Page 5EXHIBIT_START
REQUEST FOR RULING BEFORE EVIDENCE Respondent requests that this Motion be addressed before any evidence is offered. Respondent objects to any witness being called, any exhibit being offered, or any trial evidence being taken before this Motion is decided or referred. lf the Court proceeds despite this Motion, Respondent requests a clear ruling on the record and states that he appears, if at all, under objection and without waiving recusal, mandamus, de novo, due- process, healthcare, discovery, stolen-evidence, trial-readiness, financial-relief, court-r...
Page 1PLEADING_START_FILE_MARKED
6/11/2026 1:21 PM DALLAS CO., TEXAS NO. DF-24-18010 THE MARRIAGE OF § § & § RESPONDENT'S VERIFIED MOTION TO RECUSE AND REQUEST FOR REFERRAL UNDER TEXAS RULE OF CIVIL PROCEDURE 18a TO THE HONORABLE COURT: Respondent, Jason McKemie, files this Verified Motion to Recuse before any evidence has been offered at the June 11,2026, trial setting, before any witness has been called, before any exhibit has been offered, before any testimony has been taken, and before any trial evidence has been received. This filing is made to invoke the recusal procedure before t...
Page 6CERTIFICATE_OF_SERVICE
UNSWORN DECLARATION OF JASON MCKEMIE My name is Jason McKemie. My date of birth is April 8, 1976. My address is 539 W. Commerce St., Ste. 2010, Dallas, Texas 75208. declare under penalty of perjury that the factual statements in this Verified Motion to Recuse are true and correct based on my personal knowledge, documents, videos, audio, court filings, records reviewed by me, and matters stated on information and belief where the basis for that belief is identified. Executed in Texas on June 11, 2026. Jason McKemie and/or email on June11,2026. Jason McKem...
Page 7FILING_STAMP_OR_ESERVICE
on the date and to the persons listed below. The rules governing Envelope ID: 116028734 Filing Code Description: Motion - Recuse Filing Description: VERIFIED MOTION TO RECUSE AND REQUEST FOR REFERRAL Status as of 6/12/2026 9:07 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jeffrey ECook jcook@sullivancook.com 6/11/2026 1:21:45 PM SENT Rebecca LArmstrong rebecca@armstronglawtexas.com 6/11/2026 1:21:45 PM SENT Terra Aguirre terra@armstronglawtexas.com 6/11/2026 1:21:45 PM SENT Lauren N.Shaw lauren@armstronglawtexas.com 6/11/2026 1:21:...

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RESPONDENT'S SUPPLEMENTAL VERIFIED NOTICE OF CURRENT MEDICAL EMERGENCY, INABILITY TO SAFELY APPEAR AFTER TRIAL SETTING, REQUEST TO HALT PROCEEDINGS, REQUEST FOR REMOTE APPEARANCE, AND NON-WAIVER OF ALL OBJECTIONS

2026-06-11 Respondent / Jason Miscellaneous Event 8 matching page(s)
SUPPLEMENTAL EMERGENCY FILING_07490B53.pdf
StatusHigh confidenceNeeds category review
Page 2PLEADING_BODY
Respondent was involved in a car wreck last week. Respondent's vehicle is unsafe for extended travel. Respondent is also currently living in his vehicle, without stable housing, without working phone service, and without the ability to call for emergency help if his condition worsens during travel. Respondent has diverted from attempting to travel to Dallas and is presently in or near Bryan, Texas, where Respondent is being taken for emergency medical evaluation and/or hospital treatment for congestive-heart-failure symptoms. Respondent cannot safely dri...
Page 3EXHIBIT_START
Respondent requests immediate remote-access information by email so Respondent may make every possible effort to appear remotely by Zoom, Webex, Teams, telephone alternative, email link, or any available Wi-Fi method from the hospital, emergency-care setting, or available internet connection. Respondent's phone service is disconnected. Respondent requests that all remote-access information be sent by email to jmckemie@mckemie.net. IV. TRIAL SHOULD NOT PROCEED IN RESPONDENT'S ABSENCE Respondent objects to any trial proceeding, evidence presentation, witne...
Page 4EXHIBIT_CONTINUATION
Respondent has repeatedly informed this Court that Petitioner obstructed Respondent's healthcare access, including medical coverage, HSA access, FSA access, medication access, surgery access, and related benefits. Petitioner obstructed Respondent's healthcare access beginning no later than December 18, 2024. Petitioner caused or participated in a false divorce-based OLE that cut off Respondent's healthcare on October31, 2025, despite no divorce decree existing on that date. Petitioner has repeatedly represented compliance while Respondent contests functi...
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Page 5EXHIBIT_CONTINUATION
8. Provide remote appearance information immediately by email; 9. Rule on Respondent's recusal motion before evidence is received; 10. Rule on Respondent's emergency motion to abate, stay, or continue trial; 11. Preserve all mandamus, appellate, recusal, due-process, healthcare, stolen-evidence, discovery, source-record, court-reporter, de novo, financial-relief, and trial-readiness objections. Respondent further requests any other relief to which Respondent is entitled. Respectfully submitted, [Son fram Jason McKemie 539 W. Commerce St., Ste. 2010 Dalla...
Page 6EXHIBIT_CONTINUATION
UNSWORN DECLARATION OF JASON MCKEMIE My name is Jason McKemie. My date of birth is April 8, 1976. My address is 539 W. Commerce St., Ste. 2010, Dallas, Texas 75208. | declare under penalty of perjury that the factual statements in this Supplemental Verified Notice are true and correct based on my personal knowledge. | have congestive heart failure. have been repeatedly hospitalized for congestive-heart-failure symptoms and related medical complications. | have repeatedly informed the Court that my healthcare has been obstructed and that the obstruction h...
Page 1PLEADING_START_FILE_MARKED
6/11/2026 1:46 PM DALLAS CO., TEXAS DF-24-18010 NO. THE MARRIAGE OF § § & § RESPONDENT'S SUPPLEMENTAL VERIFIED NOTICE OF CURRENT MEDICAL EMERGENCY, INABILITY TO SAFELY APPEAR AFTER TRIAL SETTING, REQUEST TO HALT PROCEEDINGS, REQUEST FOR REMOTE APPEARANCE, AND NON-WAIVER OF ALL OBJECTIONS TO THE HONORABLE COURT: Respondent, Jason McKemie, files this Supplemental Verified Notice after the June 11,2026 1:30 p.m. trial setting because Respondent is medically unable to safely appear in person and this Court must immediately halt any trial proceeding, evidence...
Page 7CERTIFICATE_OF_SERVICE
Jason McKemie Page 7 of 7 Copy from re:SearchTX
Page 8FILING_STAMP_OR_ESERVICE
on the date and to the persons listed below. The rules governing Envelope ID: 116030521 Filing Code Description: Miscellaneous Event Filing Description: RESPONDEN'S SUPPLEMENTAL VERIFIED NOTICE OF CURRENT MEDICAL EMERGENCY, INABILITY TO SAFELY APPEAR AFTER TRIAL SETTING, REQUEST TO HALT PROCEEDINGS, REQUEST FOR REMOTE APPEARANCE, AND NON-WAIVER OF ALL OBJECTIONS Status as of 6/12/2026 9:20 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Rebecca LArmstrong rebecca@armstronglawtexas.com 6/11/2026 1:46:24 PM SENT Terra Aguirre terra@arms...

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RESPONDENT'S NOTICE OF NON-WAIVER OF SANCTIONS, CONTEMPT, FEE OBJECTIONS, CIVIL CLAIMS, ATTORNEY MISCONDUCT CLAIMS, AND OBJECTION TO TREATING ENGINEERED COLLAPSE AS WAIVER

2026-06-11 Respondent / Jason Notice Of Filing 7 matching page(s)
NOTICE OF NON-WAIVER OF SANCTIONS, CIVIL CLAIMS, ATTORNEY MISCONDUCT CLAIMS, AND OBJECTION_2BE3851C.pdf
StatusHigh confidenceNeeds category review
Page 2PLEADING_BODY
2. Fraudulent protective-order applications, false protective-order evidence, and abuse of protective-order process; 3. Fraudulent evidence submissions, fabricated evidence, altered evidence, false exhibits, and use or attempted use of stolen evidence; 4. Perjury, aggravated perjury, coordinated aggravated perjury, false sworn testimony, false declarations, and false representations to the Court; 5. Malicious prosecution, malicious use of process, and malicious continuation of proceedings, where legally available; 6. Abuse of process, itigation abuse, pr...
Page 3PLEADING_BODY
15. Financial sabotage, financial strangulation, concealment or dissipation of marital assets, source-record concealment, account wipeouts, disguised transfers, false characterization of equity/investment compensation, and obstruction of estate reconstruction; 16. Manufactured eviction, concealed lease buyout, landlord/lease-buyout concealment, county court, bankruptcy, or civil remedies; 17.Attorneymisconduct,counselparticipation,former-counselparticipation,current-counsel participation, pro hac vice counsel conduct, law-firm conduct, discovery obstruct...
Page 4PLEADING_BODY
NO WAIVER OF STOLEN-EVIDENCE CLAIMS Respondent does not waive any claim, objection, sanction request, contempt request, exclusion request, preservation request, or civil claim arising from Petitioner's theft of Respondent's hard drives, evidence repositories, binders, paper files, legal work product, printer, printer ink, trial materials, medications, device evidence, Apple evidence, financial records, medical records, and itigation equipment. This was theft. No softer label applies. Petitioner unlawfully entered a residence she was barred from entering,...
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Page 5PLEADING_BODY
Respondent requests that this Notice be made part of the record before any trial evidence is received. Respondent further requests that no final trial, final decree, final property division, fee award, sanctions award, or order be used to imply waiver, release, merger, adjudication, abandonment, consent, or denial of Respondent's independent civil claims, sanctions requests, contempt requests, attorney-misconduct complaints, criminal referrals, disciplinary complaints, healthcare claims, stolen- evidence claims, mandamus complaints, appellate complaints,...
Page 1PLEADING_START_FILE_MARKED
6/11/2026 1:26 PM DALLAS CO., TEXAS DF-24-18010 NO. THE MARRIAGE OF § § & § RESPONDENT'S NOTICE OF NON-WAIVER OF SANCTIONS, CONTEMPT, FEE OBJECTIONS, CIVIL CLAIMS, ATTORNEY MISCONDUCT CLAIMS, AND OBJECTION TO TREATING ENGINEERED COLLAPSE AS WAIVER TO THE HONORABLE COURT: Respondent, Jason McKemie, files this Notice before final trial, final orders, or any ruling that could be used to suggest waiver, abandonment, merger, release, adjudication, or consent. From this point forward, Jason McKemie is referred to as Respondent. Respondent does not waive sancti...
Page 6CERTIFICATE_OF_SERVICE
UNSWORN DECLARATION OF JASON MCKEMIE My name is Jason McKemie. My date of birth is April 8, 1976. My address is 539 W. Commerce St., Ste. 2010, Dallas, Texas 75208. declare under penalty of perjury that the factual statements in this Notice are true and correct based on my personal knowledge, documents, videos, audio, court filings, records reviewed by me, and matters stated on information and belief where the basis for that belief is identified. Executed in Texas on June11,2026. Jason McKemie and/or email on June 11,2026. Jason McKemie Page 6 of 6 Copy...
Page 7FILING_STAMP_OR_ESERVICE
on the date and to the persons listed below. The rules governing Envelope ID: 116029052 Filing Code Description: Notice Of Filing Filing Description: NOTICE OF NON-WAIVER OF SANCTIONS, CIVIL CLAIMS, ATTORNEY MISCONDUCT CLAIMS, AND OBJECTION Status as of 6/12/2026 9:22 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Rebecca LArmstrong rebecca@armstronglawtexas.com 6/11/2026 1:26:44 PM SENT Terra Aguirre terra@armstronglawtexas.com 6/11/2026 1:26:44 PM SENT Lauren N.Shaw lauren@armstronglawtexas.com 6/11/2026 1:26:44 PM SENT Jason McKem...

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RESPONDENT JASON MCKEMIE'S VERIFIED EMERGENCY MOTION TO ABATE, STAY, OR CONTINUE TRIAL; REQUEST FOR REMOTE APPEARANCE; REQUEST FOR DE NOVO TRIAL-READINESS HEARING; REQUEST FOR HEALTHCARE PRESERVATION, TEMPORARY FINANCIAL RELIEF, COURT REPORTER, NON-WAIVER, AND PROTECTION OF STOLEN EVIDENCE

2026-06-11 Respondent / Jason Motion - Miscellaneous 10 matching page(s)
EMERGENCY MOTION TO ABATE, STAY OR CONTINUE TRIAL_F9183942.pdf
StatusHigh confidenceNeeds category review
Page 2PLEADING_BODY
4. Do not treat Respondent's medical collapse, lack of transportation, no phone service, homelessness, no gas money, unsafe vehicle, lack of parking funds, broken laptop screen, hospitalization, inability to physically appear, or need to seek emergency medical care as waiver, abandonment, failure to prosecute, consent to trial, or consent to final orders. 5. Order that all proceedings occur on the record with a court reporter and that no off-record trial-readiness, de novo, recusal, healthcare, financial, or evidence-theft matters be resolved without a v...
Page 3PLEADING_BODY
THIS 1S A AMANUFACTURED COLLAPSE, NOT LATE NOTICE Petitioner and her counsel will say this is late. That is false. Respondent has warned the Court for seventeen months that Petitioner was using false reports, protective-order narratives, healthcare obstruction, financial strangulation, discovery obstruction, housing sabotage, digital access, third- party vendors, and court process to destroy his ability to survive and defend himself. The record already includes repeated requests for emergency financial relief, healthcare enforcement, HSA/FSA access, cour...
Page 4PLEADING_BODY
and Jason Parro. Those matters are relevant because this case follows the same pattern: false narratives, police involvement, protective-order weaponization, financial strangulation, reputational destruction, healthcare interference, and itigation used as a method of control and destruction. Respondent told law enforcement that he feared for his safety and future because he had discovered extensive documentation showing a long pattern of malicious litigation and that Petitioner was going to file false police reports and a false protective order against h...
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Page 5PLEADING_BODY
without printer ink, without a functioning laptop screen, and without the hard drives, binders, paper files, and legal work product Petitioner stole. Respondent has been living out of a vehicle and moving between Houston, Dallas, and Bryan under medical instability. Respondent's vehicle is in repossession status and unsafe. Respondent cannot safely drive four hours without phone service, gas money, headlights, parking funds, trial materials, evidence repositories, or medical stability. Respondent's parents are now also in bankruptcy. Respondent understan...
Page 6PLEADING_BODY
If trial proceeds today and final orders terminate or impair healthcare coverage, Respondent may lose the surgeries and medical care that Petitioner's healthcare obstruction already delayed. Final trial today would reward healthcare obstruction and place Respondent's survival at risk. EVIDENCE THEFT, NOT A PROPERTY DISPUTE Petitioner was not authorized to enter the residence. She was barred from entering and had been repeatedly identified as a risk for theft, destruction, manufactured allegations, law- enforcement escalation, and evidence sabotage. This...
Page 7PLEADING_BODY
Petitioner stole Respondent's Apple TV/device evidence and then used or attempted to use that stolen device to manufacture a false stalking/surveillance narrative with San Antonio Police a false accusation against Department. A device stolen from Respondent was turned into Respondent. Respondent's police reports and report numbers regarding the Dallas theft were stolen from his desk. Respondent has requested open records but has not had time to receive them before today's trial. SOURCE FINANCIAL RECORDS AND HEALTHCARE RECORDS REMAIN UNAVAILABLE The finan...
Page 8PLEADING_BODY
product of medical emergency, financial strangulation, evidence theft, healthcare obstruction, and transportation impossibility - not waiver. Respondent preserves mandamus, appeal, de novo, recusal, due-process, discovery, healthcare, source-record, financial-relief, court-reporter, stolen-evidence, and trial-readiness complaints. REQUEST Respondent requests that the Court grant the relief requested above, abate, stay, or continue trial, preserve healthcare, preserve stolen evidence, prohibit Petitioner and her agents from accessing or benefiting from st...
Page 1PLEADING_START_FILE_MARKED
6/11/2026 1:17 PM DALLAS CO., TEXAS DF-24-18010 NO. THE MARRIAGE OF § § § RESPONDENT JASON MCKEMIE'S VERIFIED EMERGENCY MOTION TO ABATE, STAY, OR CONTINUE TRIAL; REQUEST FOR REMOTE APPEARANCE; REQUEST FOR DE NOVO TRIAL-READINESS HEARING; REQUEST FOR HEALTHCARE PRESERVATION, TEMPORARY FINANCIAL RELIEF, COURT REPORTER, NON-WAIVER, AND PROTECTION OF STOLEN EVIDENCE TO THE HONORABLE COURT: Respondent, Jason McKemie, files this Verified Emergency Motion before any final trial evidence is taken on June 11,2026. From this point forward, Jason McKemie is referre...
Page 9CERTIFICATE_OF_SERVICE
UNSWORN DECLARATION OF JASON MCKEMIE My name is Jason McKemie. My date of birth is April 8, 1976. My address is 539 W. Commerce St., Ste. 2010, Dallas, Texas 75208. | declare under penalty of perjury that the factual statements in this Verified Emergency Motion are true and correct based on my personal knowledge, documents, videos, audio, court filings, records reviewed by me, and matters stated on information and belief where the basis for that belief is identified. Executed in Texas on June 11,2026. Jason McKemie and/or email on June11,2026. Jason McKe...
Page 10FILING_STAMP_OR_ESERVICE
on the date and to the persons listed below. The rules governing Envelope ID: 116028476 Filing Code Description: Motion - Miscellaneous Filing Description: VERIFIED EMERGENCY MOTION TO ABATE, STAY OR CONTINUE TRIAL Status as of 6/12/2026 8:58 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Rebecca LArmstrong rebecca@armstronglawtexas.com 6/11/2026 1:17:47 PM SENT Terra Aguirre terra@armstronglawtexas.com 6/11/2026 1:17:47 PM SENT Lauren N.Shaw lauren@armstronglawtexas.com 6/11/2026 1:17:47 PM SENT Jason McKemie jmckemie@mckemie.net 6/...

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RESPONDENT JASON MCKEMIE'S VERIFIED EMERGENCY MOTION TO ABATE, STAY, OR CONTINUE TRIAL; REQUEST FOR REMOTE APPEARANCE; REQUEST FOR DE NOVO TRIAL-READINESS HEARING; REQUEST FOR HEALTHCARE PRESERVATION, TEMPORARY FINANCIAL RELIEF, COURT REPORTER, NON-WAIVER, AND PROTECTION OF STOLEN EVIDENCE

2026-06-11 Respondent / Jason Motion - Miscellaneous 10 matching page(s)
005 - DF-24-18010_FINAL_Emergency_Motion_Manufactured_Collapse_2026-06-11.pdf
StatusHigh confidenceNeeds category review
Page 2PLEADING_BODY
4. Do not treat Respondent’s medical collapse, lack of transportation, no phone service, homelessness, no gas money, unsafe vehicle, lack of parking funds, broken laptop screen, hospitalization, inability to physically appear, or need to seek emergency medical care as waiver, abandonment, failure to prosecute, consent to trial, or consent to final orders. 5. Order that all proceedings occur on the record with a court reporter and that no off-record trial-readiness, de novo, recusal, healthcare, financial, or evidence-theft matters be resolved without a v...
Page 3PLEADING_BODY
THIS IS A MANUFACTURED COLLAPSE, NOT LATE NOTICE Petitioner and her counsel will say this is late. That is false. Respondent has warned the Court for seventeen months that Petitioner was using false reports, protective-order narratives, healthcare obstruction, financial strangulation, discovery obstruction, housing sabotage, digital access, third- party vendors, and court process to destroy his ability to survive and defend himself. The record already includes repeated requests for emergency financial relief, healthcare enforcement, HSA/FSA access, court...
Page 4PLEADING_BODY
and Jason Parro. Those matters are relevant because this case follows the same pattern: false narratives, police involvement, protective-order weaponization, financial strangulation, reputational destruction, healthcare interference, and litigation used as a method of control and destruction. Respondent told law enforcement that he feared for his safety and future because he had discovered extensive documentation showing a long pattern of malicious litigation and that Petitioner was going to file false police reports and a false protective order against...
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Page 5PLEADING_BODY
without printer ink, without a functioning laptop screen, and without the hard drives, binders, paper files, and legal work product Petitioner stole. Respondent has been living out of a vehicle and moving between Houston, Dallas, and Bryan under medical instability. Respondent’s vehicle is in repossession status and unsafe. Respondent cannot safely drive four hours without phone service, gas money, headlights, parking funds, trial materials, evidence repositories, or medical stability. Respondent’s parents are now also in bankruptcy. Respondent understan...
Page 6PLEADING_BODY
If trial proceeds today and final orders terminate or impair healthcare coverage, Respondent may lose the surgeries and medical care that Petitioner’s healthcare obstruction already delayed. Final trial today would reward healthcare obstruction and place Respondent’s survival at risk. EVIDENCE THEFT, NOT A PROPERTY DISPUTE Petitioner was not authorized to enter the residence. She was barred from entering and had been repeatedly identified as a risk for theft, destruction, manufactured allegations, law- enforcement escalation, and evidence sabotage. This...
Page 7PLEADING_BODY
Petitioner stole Respondent’s Apple TV/device evidence and then used or attempted to use that stolen device to manufacture a false stalking/surveillance narrative with San Antonio Police Department. A device stolen from Respondent was turned into a false accusation against Respondent. Respondent’s police reports and report numbers regarding the Dallas theft were stolen from his desk. Respondent has requested open records but has not had time to receive them before today’s trial. SOURCE FINANCIAL RECORDS AND HEALTHCARE RECORDS REMAIN UNAVAILABLE The finan...
Page 8PLEADING_BODY
product of medical emergency, financial strangulation, evidence theft, healthcare obstruction, and transportation impossibility - not waiver. Respondent preserves mandamus, appeal, de novo, recusal, due-process, discovery, healthcare, source-record, financial-relief, court-reporter, stolen-evidence, and trial-readiness complaints. REQUEST Respondent requests that the Court grant the relief requested above, abate, stay, or continue trial, preserve healthcare, preserve stolen evidence, prohibit Petitioner and her agents from accessing or benefiting from st...
Page 1PLEADING_START_FILE_MARKED
6/11/2026 1:17 PM DALLAS CO., TEXAS DF-24-18010 NO.___________________________________________ THE MARRIAGE OF § § § RESPONDENT JASON MCKEMIE'S VERIFIED EMERGENCY MOTION TO ABATE, STAY, OR CONTINUE TRIAL; REQUEST FOR REMOTE APPEARANCE; REQUEST FOR DE NOVO TRIAL-READINESS HEARING; REQUEST FOR HEALTHCARE PRESERVATION, TEMPORARY FINANCIAL RELIEF, COURT REPORTER, NON-WAIVER, AND PROTECTION OF STOLEN EVIDENCE TO THE HONORABLE COURT: Respondent, Jason McKemie, files this Verified Emergency Motion before any final trial evidence is taken on June 11, 2026. From...
Page 9CERTIFICATE_OF_SERVICE
UNSWORN DECLARATION OF JASON MCKEMIE My name is Jason McKemie. My date of birth is April 8, 1976. My address is 539 W. Commerce St., Ste. 2010, Dallas, Texas 75208. I declare under penalty of perjury that the factual statements in this Verified Emergency Motion are true and correct based on my personal knowledge, documents, videos, audio, court filings, records reviewed by me, and matters stated on information and belief where the basis for that belief is identified. Executed in Texas on June 11, 2026. __________________________________ Jason McKemie and...
Page 10FILING_STAMP_OR_ESERVICE
on the date and to the persons listed below. The rules governing Envelope ID: 116028476 Filing Code Description: Motion - Miscellaneous Filing Description: VERIFIED EMERGENCY MOTION TO ABATE, STAY OR CONTINUE TRIAL Status as of 6/12/2026 8:58 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Rebecca LArmstrong rebecca@armstronglawtexas.com 6/11/2026 1:17:47 PM SENT Terra Aguirre terra@armstronglawtexas.com 6/11/2026 1:17:47 PM SENT Lauren N.Shaw lauren@armstronglawtexas.com 6/11/2026 1:17:47 PM SENT Jason McKemie jmckemie@mckemie.net 6/...

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REQUEST FOR DE NOVO HEARING; OBJECTIONS TO ASSOCIATE JUDGE'S REPORT; REQUEST TO STAY ENTRY AND EFFECT OF REPORT PENDING DE NOVO REVIEW; REQUEST FOR EMERGENCY SETTING BEFORE REFERRING COURT; AND REQUEST FOR ADEQUATE EVIDENTIARY TIME, COURT REPORTER, EXHIBIT ADMISSION, WITNESS TESTIMONY, AND WRITTEN RULINGS

2026-06-04 Court REQUEST FOR DE NOVO HEARING 46 matching page(s)
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
StatusHigh confidenceNeeds category review
Page 2PLEADING_BODY
evidence-theft, protective-order, and sanctions issues. Il. SPECIFIC ISSUES PRESENTED FOR DE NOVO REVIEW Under Texas Family Code § 201.015(b), Jason specifically requests de novo review of the following issues: 1. The denial of Respondent, Jason McKemie's, Motion for Enforcement, Sanctions, Continuance, and Leave to Issue Third-Party Subpoenas. 2. The refusal or failure to consider Jason's continuance / abatement request despite the June 11, 2026, trial setting and the unresolved source-record, discovery, healthcare, stolen-evidence, and trial-readiness...
Page 3PLEADING_BODY
lacking traceable funding, account entry, repayment history, and community-purpose proof. 9. The denial or failure to address sanctions, show-cause relief, adverse inferences, fee shifting against Petitioner and responsible counsel, counsel certification, forensic accounting from third-party financial source records, estate reconstitution under Texas Family Code § 7.009, and disproportionate division under Texas Family Code § 7.001. 10.The denial or failure to enforce healthcare, HSA/FSA, prescription, reimbursement, benefits-card, benefits-portal, QLE,...
Page 4PLEADING_BODY
Petitioner be denied in full, with no later prove-up, no reserved entitlement, and no cost shifting against Jason. 18.The denial or failure to address witness-protection issues involving Christopher McNally and Jonathan Drake Steele. 19.The denial or failure to address trial-readiness defects created by incomplete financial production, blocked source-record subpoenas, missing/stolen evidence repositories, unresolved healthcare access, lack of functional litigation infrastructure, and unresolved witness-protection issues. 20.Any finding, conclusion, recom...
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Page 5EXHIBIT_START
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...
Page 14EXHIBIT_START
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...
Page 15EXHIBIT_START
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...
Page 44EXHIBIT_START
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...
Page 6EXHIBIT_CONTINUATION
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...
Page 7EXHIBIT_CONTINUATION
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...
Page 8EXHIBIT_CONTINUATION
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...
Page 9EXHIBIT_CONTINUATION
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...
Page 10EXHIBIT_CONTINUATION
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...
Page 11EXHIBIT_CONTINUATION
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...
Page 12EXHIBIT_CONTINUATION
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...
Page 16EXHIBIT_CONTINUATION
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....
Page 17EXHIBIT_CONTINUATION
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...
Page 18EXHIBIT_CONTINUATION
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...
Page 19EXHIBIT_CONTINUATION
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...
Page 20EXHIBIT_CONTINUATION
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...
Page 21EXHIBIT_CONTINUATION
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...
Page 22EXHIBIT_CONTINUATION
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...
Page 23EXHIBIT_CONTINUATION
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...
Page 24EXHIBIT_CONTINUATION
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...

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Exhibit Map - Recusal Supplement

2026-06-16 Respondent / Jason Notice Of Filing 158 matching page(s)
Exhibit Map - Recusal Supplement.pdf
StatusHigh confidenceNeeds category review
Page 2EXHIBIT_START
EXHIBIT INDEX AND CLICKABLE REFERENCE MAP 0 https://tinyurl.com/POExhibitIndex Index of Exhibit's with clickable links to supporting documentation. Document includes descriptions of referencd materials for context. DANE PATCHING DECLARATION https://tinyurl.com/DestructionDeclaration A Independent witness evidence regarding April 16 aftermath, destructive handling, electronics and valuables near trash, camera/security damage, and Applicant not being the dangerous actor. APRIL 16 WRIT AFTERMATH / TIMELINE / PHOTOS / VIDEOS https://tinyurl.com/WritAftermath...
Page 3EXHIBIT_START
PROTECTIVE ORDER EXHIBIT MAP Each exhibit uses a 3-row block: ID | NAME | LINK 1 / LINK 2 | DESCRIPTION. Add new exhibits by copying any complete 3-row block. LEASE BUYOUT / MANUFACTURED EVICTION EVIDENCE K https://tinyurl.com/LeaseFraud Supports manufactured eviction/access pressure, housing instability, predicted cleanout, and third-party access setup. DESTROYED AT&T MODEM / SECURITY-SYSTEM DISABLEMENT L https://tinyurl.com/DestroyedModem Shows destruction/disablement of internet, security, alarm, and camera infrastructure during or after April 16. SIG...
Page 7EXHIBIT_START
NO.__________________________________________ APPLICANT § GWENDOLYN LAURA ULIJASZ § TEXAS PHOTO EXHIBIT W | WRIT AFTERMATH I. PRIOR COURT HISTORY AND NOTICE REGARDING PETITIONER’S ACCESS TO THE RESIDENCE Petitioner repeatedly requested access to the marital residence through pleadings and during court hearings. On January 6, 2026, during a motion-to-compel hearing, Judge Abendroth initially approved access over Applicant’s objections. After reviewing the history, however, the Court stated that Petitioner had already been given more than enough time to re...
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Page 26EXHIBIT_START
EXHIBIT C NO.__________________________________________ APPLICANT § GWENDOLYN LAURA ULIJASZ § EXHIBIT - HEALTHCARE OBSTRUCTION CONTRADICTIONS MATRIX This exhibit is designed for rapid judicial review. Each contradiction identifies the statement, the contradictory record, and why the contradiction matters to the issue of healthcare obstruction and ongoing noncompliance. • False 'receipt upload' pretext used to block HSA access. • Claimed compliance despite nonfunctional or cancelled card access. • Objective system records still showing HSA/FSA waivers aft...
Page 29EXHIBIT_START
DF-24-18010NO.__________________________________________ THE MARRIAGE OF § § & § PHOTO EXHIBIT M MEDICAL HARM APRIL 2026 — MEDICAL HARM / TRANSACTION- TRIGGERED FINANCIAL ACCESS INTERFERENCE Recurrent staphylococcal infections began after prescribed antibiotic treatment was interrupted in May 2025, when Respondent reported Applicant’s HSA card lost/stolen during Applicant’s six-day hospitalization. Hospital staff restored access to the HSA card for the first time since Respondent locked the card on December 18, 2024, the application against Applicant. Th...
Page 43EXHIBIT_START
15. DOCUMENTED HISTORY INVOLVING PETITIONER. A certified copy of the relevant Wisconsin Circuit Court records is attached hereto as [Exhibit A]. This exhibit is provided solely to ensure accurate safety context where allegations of danger or the asserted need for armed protection are raised, and to document that such assertions are inconsistent with my history and the publicly documented record. DECLARATION I declare under penalty of perjury that the foregoing is true and correct. Executed on January 11, 2026 At 9:30pm CST _______________________________...
Page 100EXHIBIT_START
Exhibit 7
Page 151EXHIBIT_START
VIDEO INDEX OF APRIL 16, 2026, COORDINATED CLEAN-OUT EXHIBIT V & DESTRUCTION OF THE MARITAL ESTATE EXHIBIT DATE TIME EVENT ID. EVIDENCE / EXHIBITS Respondent left the residence to go to court after identifying defective service and attempting to stop 2:37PM the writ. Respondent closed the garage before leaving. https://tinyurl.com/RushedOut (2) Individual's contracted by Petitioner, drove backwards down the alleyway and backed into back driveway with hatch back the garage within 2min. As they backed in, the garage door was opened 2:39PM from the inside....
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Gwen, I’m sure that receiving this letter might be upsetting and that you would prefer to not read nor process it, I sincerely ask you to do so. It is written with all the love I have to give. I understand that you have an attachment avoidant attachment style, and that those are developed in our youth, and they are carried throughout our lives. I am also aware that they’re techniques and tools they can be utilized to mitigate the impulses that are created by such an attachment style. Your attachment style existed when we met, when we fell in love, when w...
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NO.___________________________DF-24-18010 THE MARRIAGE OF § § & § DECLARATION OF DANE PATCHING IN SUPPORT OF EMERGENCY PROTECTIVE RELIEF My name is Dane Patching. My date of birth is August 26, 1985. I am over eighteen years old, competent to make this declaration, and have personal knowledge of the facts stated below. I live with my wife, Christina Segura, at 4617 Lester Dr., Dallas, Texas 75219. I am not a party to this case. The facts stated in this declaration are true and correct to the best of my knowledge. I. Witness Background and Basis for Perso...
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crystal still inside it. Those contents were broken. 8. In my opinion, this was not a move—it was a teardown. The condition of the property reflects a complete disregard for preservation and is consistent with conduct that would foreseeably cause considerable damage. Items were not simply mishandled or disorganized; they were left in a state that does not occur during any normal packing or removal process. 9. While Jason was in the front area, a vehicle repeatedly circled the house. Jason and I both observed it. Jason told me he had seen that vehicle dur...
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traveled to Wisconsin for four days to attend their ceremonial wedding at her sister Pamela Woodman’s lakehouse in Mauston, Wisconsin. 19. When we first met Gwen, we understood that she had relocated to Texas because of safety concerns involving a former spouse. Jason discussed those concerns with me, and I observed him take deliberate steps to protect her privacy, including avoiding social media and limiting public visibility regarding their whereabouts and marriage. This was a noticeable change from Jason’s prior online presence. Based on what I observ...
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object to Petitioner receiving any remaining belongings. Applicant objected to Petitioner personally entering the residence or receiving property directly from Applicant. Applicant repeatedly stated that any remaining property transfer had to occur through a neutral third party because direct contact or direct transfer created an unacceptable risk of false allegations, planted evidence, property destruction, or further escalation. Petitioner was that she was not permitted to personally re-enter the residence and that any remaining retrieval had to occur...
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Evening of April 16 through approximately 4:00 a.m. — Applicant worked to recover and secure property that had been left outside, damaged, discarded, commingled with trash, or made inaccessible. Approximately 7:00 a.m. the following morning — After sleeping outside in a lawn chair from physical exhaustion to watch the property, Applicant woke to the same blue Lexus sports sedan stopped approximately 15 to 20 feet away, with the driver photographing Applicant through an open window using a DSLR camera. III. COORDINATED ENTRY AND DISABLEMENT OF SURVEILLANC...
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2:46PM ARRIVAL FROM SAN ANTONIO VIA UBER Petitioner had already been denied further unrestricted personal access through prior court property transfer had to occur through a neutral process. Her use of outdated identification was not harmless. It was used to create the appearance of authority at the precise moment her physical entry and removal of property were being challenged. V. PETITIONER’S RECORDED STATEMENT ABOUT “EVIDENCE” At approximately 2:57 p.m., Petitioner was captured on video speaking by phone with multiple outside resources. She stated tha...
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VI. REMOVAL, DESTRUCTION, AND MISCLASSIFICATION OF PROPERTY Once inside, Petitioner took control of the packing and removal process. Property was divided into “keep” and “dispose” categories. In practice, “dispose” became Applicant’s property. Items necessary for survival, litigation, medical access, identity, and daily functioning were removed, damaged, destroyed, discarded, or left behind in a condition designed to make retrieval nearly impossible. This included medications, auto-injectors, hard drives, litigation files, tax records, passport, identifi...
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VIII. CONSTABLE STATEMENT AND PETITIONER LEAVING WITH PROPERTY When Applicant left the courthouse around 5:30 p.m., he spoke with the constable. The constable stated that Petitioner had been inside boxing items from the attic and that he told her to stop and unload the SUV. The constable stated that Petitioner then got into the SUV and left with her security guards. When Applicant asked why the constable could not recover the property, the constable stated that he did not have authority to chase her. This confirms that Petitioner personally removed prope...
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It took approximately 36 hours to bring the property back inside. By approximately 4:00 a.m., Applicant was physically exhausted and slept outside in a lawn chair to watch the property. At approximately 7:00 a.m., Applicant woke to the same blue Lexus stopped approximately 15 to 20 feet away, with the driver photographing Applicant through an open window using a DSLR camera. This was continued surveillance during physical vulnerability, not ordinary neighborhood activity. XI. BROADER FINANCIAL, LEASE, HEALTHCARE, AND LITIGATION CONTEXT The April 16 event...
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XII. FIREARM ACQUISITION AND SAFETY RISK Open records recently produced a police report confirming Petitioner’s acquisition of a firearm. Petitioner stated that she needed the firearm in connection with a property dispute at Public Storage on the exact same date as the first bench trial in the 254th District Court. The report states that Petitioner was not licensed for that firearm. The firearm issue is directly relevant to this request for protective relief and to the requested Rule 204 psychological examination. Petitioner’s acquisition of a firearm in...
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\ APRIL 16TH / WRIT DESTRUCTION High-value items were left in residence while other property was removed or destroyed, reflecting selective and non-standard handling. Bazaart_ED3EFD84-CBAB9726BBCAC.JPEG APRIL 16TH / WRIT DESTRUCTION After providing an invalid ID, Petitioner took control of the property removal; including exclusive choice over everything she desired to keep, of what was disposed, and of what Respondent would be permitted to have after the writ concluded. IMG_1859.jpg APRIL 16TH / WRIT DESTRUCTION Elliptical machine abandoned. IMG_1896.jpg...
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APRIL 16TH / WRIT DESTRUCTION APRIL 16TH / WRIT DESTRUCTION Electronics and heavy items were placed into Glassware, clothing, and household items wardrobe boxes, creating excessive weight commingled in trash bags and discarded and foreseeable damage. Several wardrobe in piles; fragile items broken. boxes appeared to be “loaded in place,” with glass and breakable items at the bottom and A large pile in the front of the residence heavier equipment stacked on top, mostly was over 5 ft tall, with significant property electronics. None of the wardrobe boxes d...
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APRIL 16 WRIT DESTRUCTION APRIL 16 WRIT DESTRUCTION ALL MY SONS / THIRD-PARTY PAYMENT When Applicant returned after the writ was stopped, a 26-foot “All My Sons” moving truck was unloading his property. Applicant spoke with the booking manager, who stated the movers were contracted only to move property from the lawn to the truck and could not bill Gwendolyn Ulijasz because they did not have her payment information. The booking manager identified the payment source as Merritt McClayton Rahilly, Gwendolyn’s close friend, and stated that Gwendolyn was expl...
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APRIL 16 / WRIT AFTERMATH The recovered bags contained unrelated property from multiple rooms mixed with trash, liquids, food, broken debris, electronics, legal papers, photographs, books, kitchen items, and bathroom items. The purchased S/M/L boxes were not used. Instead, wardrobe boxes were packed with non-wardrobe items after my clothing was identified to constables as property to remain in the residence. Fragile items were placed beneath heavy items, including large power supplies, crushing property below, including my great-grandmother’s crystal. Se...

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RESPONDENT’S EMERGENCY RULE 18a STATUS NOTICE REGARDING PENDING VERIFIED RECUSAL, REQUEST FOR WRITTEN RULING OR REFERRAL, AND OBJECTION TO DECREE ACTION

2026-06-16 Respondent / Jason Motion - Miscellaneous 6 matching page(s)
DF-24-18010 - Recusal Notice_Written Ruling_Objection to Decree Action.pdf
StatusHigh confidenceNeeds category review
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witness was called, before any exhibit was offered, before any testimony was taken, and before any trial evidence was received. Jason also requested that the recusal be addressed before evidence and objected to any witness being called, exhibit being offered, testimony being taken, or trial evidence being received before the motion was decided or referred. The e-service record reflects that the Motion to Recuse and Request for Referral was served on June 11, 2026 at 1:21:45 p.m. III. RULE 18a STATUS NEEDS TO BE CLARIFIED BEFORE DECREE ACTION Texas Rule o...
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This notice is made to preserve the record, prevent waiver, and avoid any false record that Jason acquiesced in decree action while the pending verified recusal remained unresolved or unclear. VII. REQUESTED RELIEF Jason respectfully requests that the Court: denied, granted, or referred; 2. direct the Clerk to deliver the pending verified recusal, this notice, the emergency supplement, and the supplemental exhibit map to the respondent judge and regional presiding judge; 3. withhold rendition, signature, entry, transmission, enforcement, or approval of a...
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Jason objects to any rendition, signature, entry, transmission, enforcement, implementation, property transfer, debt allocation, healthcare/benefits effect, injunction, fee award, cost award, sanction, or final-decree effect before: 1. the pending verified recusal is decided; 2. the pending verified recusal is referred; 3. the Court states a written or on-record good-cause basis for proceeding despite the pending verified recusal; or 4. the Court identifies the legal basis for proceeding despite the pending verified recusal and Jason’s pending objections...
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6/16/2026 12:06 PM THE MARRIAGE OF § § & § RESPONDENT’S EMERGENCY RULE 18a STATUS NOTICE REGARDING PENDING VERIFIED RECUSAL, REQUEST FOR WRITTEN RULING OR REFERRAL, AND OBJECTION TO DECREE ACTION TO THE HONORABLE COURT: Jason McKemie, Respondent, files this Emergency Rule 18a Status Notice regarding his at trial and before any final decree action. This filing is not a new motion to recuse. It is a status notice, preservation filing, and objection to decree action while the Rule 18a status of the pending verified recusal remains unresolved on the docket a...
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UNSWORN DECLARATION OF JASON MCKEMIE My name is Jason McKemie. My date of birth is April 8, 1976. My address is 539 W. Commerce St., Ste. 2010, Dallas, Texas 75208. factual statements in this Emergency Rule 18a Status Notice are true and correct based on my available to me, emails received by me, records reviewed by me, and documents in my possession or accessible to me. As of the filing of this notice, I have not located any written order of recusal, written denial, written referral order, or written/on-record good-cause basis for further decree action...
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on the date and to the persons listed below. The rules governing Envelope ID: 116200430 Filing Code Description: Motion - Miscellaneous Filing Description: RESPONDENT'S EMERGENCY RULE 18A STATUS NOTICE REGARDING PENDING VERIFIED RECUSAL, REQUEST FOR WRITTEN RULING OR REFERRAL , AND OBJECTION TO DECREE ACTION Status as of 6/16/2026 12:47 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Rebecca LArmstrong rebecca@armstronglawtexas.com 6/16/2026 12:06:47 PM SENT Terra Aguirre terra@armstronglawtexas.com 6/16/2026 12:06:47 PM SENT Lauren N...

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