#
2024-12-20
Respondent / Jason
Proposed Order/Judgment
Page 1
PLEADING_START_FILE_MARKED
PROPOSED AMENDED TEMPORARY EX PARTE ORDER_F39B0508.pdf
...ection 71.004, (A) D FINDS Family Code. THEREFORE, the Court grants the application and issues this Temporary Ex Parte Order. No bond is required. Page 1 of 6 (Rev. 811612024) Copy from re:SearchTX
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2024-12-20
Respondent / Jason
Proposed Order/Judgment
Page 2
PLEADING_BODY
PROPOSED AMENDED TEMPORARY EX PARTE ORDER_F39B0508.pdf
...the information required by Section 411.042(b)(6), Government Code, into the statewide law enforcement information system maintained by the Texas Page 2 of 6 (Rev. 8I16I2024) Copy from re:SearchTX
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2024-12-20
Respondent / Jason
Proposed Order/Judgment
Page 3
PLEADING_BODY
PROPOSED AMENDED TEMPORARY EX PARTE ORDER_F39B0508.pdf
...onal numbers) The Court ORDERS the clerk to remove from the public records of the Court the telephone numbers of persons protected by this Order. Page 3 of 6 (Rev. 08:16:2024) Copy from re:SearchTX
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2024-12-20
Respondent / Jason
Proposed Order/Judgment
Page 4
PLEADING_BODY
PROPOSED AMENDED TEMPORARY EX PARTE ORDER_F39B0508.pdf
...ES THIS ORDER MAY BE PUNISHED FOR CONTEMPT OF COURT BY A FINE OF AS MUCH AS $500.00 OR BY CONFINEMENT IN JAIL FOR AS LONG AS SIX MONTHS, OR BOTH. Page 4 of 6 (Rev. 08:16:2024) Copy from re:SearchTX
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2024-12-20
Respondent / Jason
Proposed Order/Judgment
Page 5
PLEADING_BODY
PROPOSED AMENDED TEMPORARY EX PARTE ORDER_F39B0508.pdf
...arges against you. If you have questions about how long you will be ineligible to possess a firearm or ammunition, you should consult an attorney. Page 5 of 6 (Rev. 08:16:2024) Copy from re:SearchTX
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2024-12-20
Respondent / Jason
Proposed Order/Judgment
Page 6
PLEADING_BODY
PROPOSED AMENDED TEMPORARY EX PARTE ORDER_F39B0508.pdf
...en the orders. X. DURATION OF PROTECTIVE ORDER . (Duration cannot exceed 20 days) This Order expires on Signed on HONORABLE JUDGE JUDGE PRESIDING Page 6 of 6 (Rev. 08:16:2024) Copy from re:SearchTX
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2024-12-20
Respondent / Jason
Proposed Order/Judgment
Page 7
PLEADING_BODY
PROPOSED AMENDED TEMPORARY EX PARTE ORDER_F39B0508.pdf
...nd possession of the following property, and Respondent shall not interfere with Applicant’s use and possession of the property: Home: 5609 La Foy B1Vd., Dallas, Texas 75209 during the time period of December 21 at 9am to December 27 at 9am (Enter address) (TCIC Form FCC-03) Automobile: (Enter year, make, model, and color of automobile) (TCIC Form PCO-08) D Other Property: (Enter description, name, or another identifier) (TCIC Form PCO-08) (B) Respondent shall not interfere with Applicant’s use and possession of the following property: (Enter a descriptio...
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2024-12-20
Respondent / Jason
Proposed Order/Judgment
Page 8
PLEADING_BODY
PROPOSED AMENDED TEMPORARY EX PARTE ORDER_F39B0508.pdf
STALKING PROTECTIVE ORDER In lieu of a finding that family violence occurred, the Court FINDS that probable cause exists to believe that Respondent committed an offense under Section 42.072, Penal Code, Stalking, and the nature of the scheme or course of conduct engaged in by Respondent in committing the offense indicates that Respondent is likely in the future to engage in conduct prohibited by the section. Therefore, the Court grants the application and enters this Protective Order against Respondent. (Art. 73.052, Code Cn‘m. Proc.) Copy from re:Search...
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2024-12-20
Respondent / Jason
Proposed Order/Judgment
Page 9
FILING_STAMP_OR_ESERVICE
PROPOSED AMENDED TEMPORARY EX PARTE ORDER_F39B0508.pdf
...68 crystal@jhfamilylaw.com Envelope ID: 95552884 Filing Code Description: Proposed Order/Judgment Filing Description: AMENDED TEMPORARY EX PARTE ORDER Status as of 12/20/2024 12:37 PM CST Associated Case Party: GWENDOLYN ULIJASZ MCKEMIE Name BarNumber Email TimestampSubmitted Status Crystal Martinez crystal@jhfamilylaw.com 12/20/2024 12:26:38 PM SENT Donna Tomlinson donna@jhfamilylaw.com 12/20/2024 12:26:38 PM SENT Associated Case Party: JASON MCKEMIE Name BarNumber Email TimestampSubmitted Status Brant M.Webb firm@webbfamilylaw.com 12/20/2024 12:26:38 P...
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#022
2024-12-20
Respondent / Jason
Proposed Order/Judgment
Page 1
PROPOSED_ORDER_OR_ORDER
PROPOSED AMENDED EMERGENCY EX PARTE TRO AND ORDER SETTING HERING FOR TEMPORARY ORDERS_F13EE2D2.pdf
...ing Order. After review and consideration of Petitioner’s Emergency Ex Parte Temporary Restraining Order against Jason McKemie and supporting affidavit dated December 20, 2024, the Court finds that effective immediately for the preservation of the property and the protection of the parties the Temporary Restraining Order is GRANTED. IT IS ORDERED that, effective immediately, Jason McKemie, as well as his agents, servants, employees, and attorneys, and all persons in active concert or participation with him who receive actual notice of this Temporary Restra...
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#022
2024-12-20
Respondent / Jason
Proposed Order/Judgment
Page 2
PLEADING_BODY
PROPOSED AMENDED EMERGENCY EX PARTE TRO AND ORDER SETTING HERING FOR TEMPORARY ORDERS_F13EE2D2.pdf
...whether personal property, real property, or intellectual property, and Whether separate or community property, except as specifically authorized by order of this Court. 12. Incurring any debt, other than legal expenses in connection with this suit, except as specifically authorized by order of this Court. 13. Withdrawing money from any checking or savings account in any financial institution for any purpose, except as specifically authorized by order ofthis Court. 14. Spending any money in either party’s possession or subject to either party’s control for...
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#022
2024-12-20
Respondent / Jason
Proposed Order/Judgment
Page 3
PLEADING_BODY
PROPOSED AMENDED EMERGENCY EX PARTE TRO AND ORDER SETTING HERING FOR TEMPORARY ORDERS_F13EE2D2.pdf
...telephone, cable television, or any other contractual service, including security, pest control, landscaping, or yard maintenance, at 5609 La Foy Blvd., Dallas, Texas 75209 or in any manner attempting to withdraw any deposits for service in connection with any of those services. 31. Excluding Petitioner from the use and enjoyment of the residence located at 5609 La Foy Blvd., Dallas, Texas 75209. 32. Entering, operating, or exercising control over any motor vehicle in the possession of Petitioner. 33. Tracking or monitoring personal property or a motor...
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#022
2024-12-20
Respondent / Jason
Proposed Order/Judgment
Page 4
PLEADING_BODY
PROPOSED AMENDED EMERGENCY EX PARTE TRO AND ORDER SETTING HERING FOR TEMPORARY ORDERS_F13EE2D2.pdf
...is waived. IT IS FURTHER ORDERED that the clerk shall issue notice to Jason McKemie to appear, and Jason McKemie is hereby ordered to appear at 1:30 p.m. on December 31, 2024 at Dallas, Texas 75202, for a hearing on Petitioner’s request that this Temporary Restraining Order be made into a Temporary Injunction against Jason McKemie during the pendency of this divorce or until further orders of this Court. The Court may make further orders on such matters as it deems appropriate at the hearing, including but not limited to the following matters: l. Intenti...
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#022
2024-12-20
Respondent / Jason
Proposed Order/Judgment
Page 5
PLEADING_BODY
PROPOSED AMENDED EMERGENCY EX PARTE TRO AND ORDER SETTING HERING FOR TEMPORARY ORDERS_F13EE2D2.pdf
...whether personal property, real property, or intellectual property, and whether separate or community property, except as specifically authorized by order of this Court. 12. Incurring any debt, other than legal expenses in connection with this suit, except as specifically authorized by order of this Court. 13. Withdrawing money from any checking or savings account in any financial institution for any purpose, except as specifically authorized by order ofthis Court. 14. Spending any money in either party’s possession or subject to either party’s control for...
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#022
2024-12-20
Respondent / Jason
Proposed Order/Judgment
Page 6
PLEADING_BODY
PROPOSED AMENDED EMERGENCY EX PARTE TRO AND ORDER SETTING HERING FOR TEMPORARY ORDERS_F13EE2D2.pdf
...telephone, cable television, or any other contractual service, including security, pest control, landscaping, or yard maintenance, at 5609 La Foy Blvd., Dallas, Texas 75209 or in any manner attempting to withdraw any deposits for service in connection with any of those services. 31. Excluding Petitioner from the use and enjoyment of the residence located at 5609 La Foy Blvd., Dallas, Texas 75209. 32. Entering, operating, or exercising control over any motor vehicle in the possession of Petitioner. 33. Tracking or monitoring personal property or a motor...
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#022
2024-12-20
Respondent / Jason
Proposed Order/Judgment
Page 7
PLEADING_BODY
PROPOSED AMENDED EMERGENCY EX PARTE TRO AND ORDER SETTING HERING FOR TEMPORARY ORDERS_F13EE2D2.pdf
SIGNED on at A.M./P.M. JUDGE PRESIDING PETITIONER’S AMENDED EMERGENCY Ex PARTE TEMPORARY RESTRAINING ORDER PAGE 7 0E 7 CAUSE N0: DF—24—18010 IMMO MCKEMIE Copy from re:SearchTX
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#022
2024-12-20
Respondent / Jason
Proposed Order/Judgment
Page 8
FILING_STAMP_OR_ESERVICE
PROPOSED AMENDED EMERGENCY EX PARTE TRO AND ORDER SETTING HERING FOR TEMPORARY ORDERS_F13EE2D2.pdf
...sed Order/Judgment Filing Description: PETITIONER AMENDED EMERGENCY EX PARTE TEMPORARY RESTRAINING ORDER AND ORDER SETTING HERING FOR TEMPORARY ORDERS Status as of 12/20/2024 12:40 PM CST Associated Case Party: GWENDOLYN ULIJASZ MCKEMIE Name BarNumber Email TimestampSubmitted Status Crystal Martinez crystal@jhfamilylaw.com 12/20/2024 12:28:07 PM SENT Donna Tomlinson donna@jhfamilylaw.com 12/20/2024 12:28:07 PM SENT Associated Case Party: JASON MCKEMIE Name BarNumber Email TimestampSubmitted Status Brant M.Webb firm@webbfamilylaw.com 12/20/2024 12:28:07 P...
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2024-12-20
Petitioner / Gwendolyn
AMENDED MOTION
Page 1
PLEADING_START_FILE_MARKED
PETITIONER'S AMENDED REQUEST FOR EMERGENCY EX PARTE TEMPORARY RESTRAINING ORDER_F77DC859.pdf
12/20/2024 12:19 PM DALLAS CO., TEXAS NO- THE MARRIAGE 0F § § AND § PETITIONER’S AMENDED REQUEST FOR EMERGENCY EX PARTE TEMPORARY RESTRAINING ORDER This Amended Requestfor Emergency Ex Parte Temporary Restraining Order is brought by Gwendolyn Ulijasz-McKemie, who shows in support: I. Requestfor Ex Parte Temporary Restraining Order Gwendolyn Ulijasz-McKernie requests the Court to dispense with the issuance of a bond and requests that Jason McKemie be temporarily restrained immediately, without hearing, after notice and hearing be temporarily enjoined, pen...
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2024-12-20
Petitioner / Gwendolyn
AMENDED MOTION
Page 2
PLEADING_BODY
PETITIONER'S AMENDED REQUEST FOR EMERGENCY EX PARTE TEMPORARY RESTRAINING ORDER_F77DC859.pdf
...whether personal property, real property, or intellectual property, and whether separate or community property, except as specifically authorized by order of this Court. 12. Incurring any debt, other than legal expenses in connection with this suit, except as specifically authorized by order of this Court. 13. Withdrawing money from any checking or savings account in any financial institution for any purpose, except as specifically authorized by order ofthis Court. 14. Spending any money in either party’s possession or subject to either party’s control for...
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2024-12-20
Petitioner / Gwendolyn
AMENDED MOTION
Page 3
PLEADING_BODY
PETITIONER'S AMENDED REQUEST FOR EMERGENCY EX PARTE TEMPORARY RESTRAINING ORDER_F77DC859.pdf
...telephone, cable television, or any other contractual service, including security, pest control, landscaping, or yard maintenance, at 5609 La Foy Blvd., Dallas, Texas 75209 or in any manner attempting to withdraw any deposits for service in connection with any of those services. 31. Excluding Petitioner from the use and enjoyment of the residence located at 5609 La Foy Blvd., Dallas, Texas 75209. 32. Entering, operating, or exercising control over any motor vehicle in the possession of Petitioner. 33. Tracking or monitoring personal property or a motor...
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2024-12-20
Petitioner / Gwendolyn
AMENDED MOTION
Page 4
PLEADING_BODY
PETITIONER'S AMENDED REQUEST FOR EMERGENCY EX PARTE TEMPORARY RESTRAINING ORDER_F77DC859.pdf
expenses in connection with this suit. 3. To make withdrawals from accounts in financial institutions only for the purposes authorized by the Court’s order. 2. Requestfor Temporary Orders and Injunction Petitioner requests the Court, after notice and hearing, to dispense with the issuance of a bond, to make temporary orders and issue any appropriate temporary injunctions for the preservation of the property and protection of the parties as deemed necessary and equitable. Petitioner requests that the Court enjoin Respondent from the following: 1. Intention...
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2024-12-20
Petitioner / Gwendolyn
AMENDED MOTION
Page 5
PLEADING_BODY
PETITIONER'S AMENDED REQUEST FOR EMERGENCY EX PARTE TEMPORARY RESTRAINING ORDER_F77DC859.pdf
12. Incum'ng any debt, other than legal expenses in connection with this suit, except as specifically authorized by order of this Court. 13. Withdrawing money from any checking or savings account in any financial institution for any purpose, except as specifically authorized by order ofthis Court. 14. Spending any money in either party’s possession or subject to either party’s control for any purpose, except as specifically authorized by order of this Court. 15. Withdrawing or borrowing money in any manner for any purpose from any retirement, profit-sharing,...
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2024-12-20
Petitioner / Gwendolyn
AMENDED MOTION
Page 6
PLEADING_BODY
PETITIONER'S AMENDED REQUEST FOR EMERGENCY EX PARTE TEMPORARY RESTRAINING ORDER_F77DC859.pdf
...telephone, cable television, or any other contractual service, including security, pest control, landscaping, or yard maintenance, at 5609 La Foy Blvd., Dallas, Texas 75209 or in any manner attempting to withdraw any deposits for service in connection with any of those services. 31. Excluding Petitioner from the use and enjoyment of the residence located at 5609 La Foy Blvd., Dallas, Texas 75209. 32. Entering, operating, or exercising control over any motor vehicle in the possession of Petitioner. 33. Tracking or monitoring personal property or a motor...
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#
2024-12-20
Petitioner / Gwendolyn
AMENDED MOTION
Page 7
PLEADING_BODY
PETITIONER'S AMENDED REQUEST FOR EMERGENCY EX PARTE TEMPORARY RESTRAINING ORDER_F77DC859.pdf
...ning order be made a temporary injunction. Gwendolyn Ulijasz-McKemie prays for general relief. Respectfully submitted, HARGRAVE FAMILY LAW 4201 Spring Valley Road, Suite 1210 Dallas, Texas 75244 Tel: (214) 420-0100 Fax: (214) 420-0101 By NNA R. TOMLINSON State Bar No. 24046868 donna@jhfamilylaw.com Attorney for Gwendolyn Ulijasz-McKemie AMENDED REQUEST FOR EMERGENCY EX PARTE TEMPORARY RESTRAINING ORDER PAGE 7 of 7 Copy from re:SearchTX
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2024-12-20
Petitioner / Gwendolyn
AMENDED MOTION
Page 8
DECLARATION
PETITIONER'S AMENDED REQUEST FOR EMERGENCY EX PARTE TEMPORARY RESTRAINING ORDER_F77DC859.pdf
...n this case. The facts stated in this Declaration are within my personal knowledge and are true and correct. Jason McKemie is Respondent, and we were married on June 22, 2024. I am in fear of Jason McKemie based on his manic behavior and drug use that have escalated over the past few months. Jason has become more verbally abusive, and his threatening behavior has escalated. As a result, I have left the marital home as I no longer feel safe in the same proximity with him. Unbeknown to me during our courtship, Jason has been a consistent drug user and also...
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2024-12-20
Petitioner / Gwendolyn
AMENDED MOTION
Page 9
PLEADING_BODY
PETITIONER'S AMENDED REQUEST FOR EMERGENCY EX PARTE TEMPORARY RESTRAINING ORDER_F77DC859.pdf
I had no knowledge that Jason was already a daily drug user when our wedding ceremony took place on June 22, 2024. I only saw that his behavior changed in the months leading up to the wedding. I attributed it to a few other significant stressors going on at that time. He had expressed stresses with his job over the 10 months prior to the wedding and he was frustrated. We also had to unexpectedly relocate on short notice (8 weeks notice) before our wedding. This was the result of a broken pipe that flooded that home. He was anxious and irritable, smoking mo...
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2024-12-20
Petitioner / Gwendolyn
AMENDED MOTION
Page 10
PLEADING_BODY
PETITIONER'S AMENDED REQUEST FOR EMERGENCY EX PARTE TEMPORARY RESTRAINING ORDER_F77DC859.pdf
...person can live with and maintain their health and a job. Most recently, Jason’s behavior has now become paranoid as well as threatening. On Thursday night, December 12’ 2024, I returned from a business trip and found Jason angry. It felt different than other times in that he seemed to not be in control of himself. I was in my office sitting on the floor with open file medical files, situated between my desk and the filing cabinet toward the back of the room. My dog Katie was behind me in her bed. Unprovoked, he yelled for what I would estimate 35-40 minutes,...
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2024-12-20
Petitioner / Gwendolyn
AMENDED MOTION
Page 11
PLEADING_BODY
PETITIONER'S AMENDED REQUEST FOR EMERGENCY EX PARTE TEMPORARY RESTRAINING ORDER_F77DC859.pdf
he will continue this behavior. On the evening of December 16’ 2024, Jason sent a text that he would not allow me to have time on my own in the house. He stated that any entrance in our home would be monitored by him and his friends. I am frightened enough that I am living out of a suitcase with nowhere to go. I am afraid and I believe that the escalation in name calling, increasingly aggressive and now threatening talk and stalking behaviors will become violent. I have now realized that Jason has been digitally stalking and tracking me, whether I am in...
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2024-12-20
Petitioner / Gwendolyn
AMENDED MOTION
Page 12
FILING_STAMP_OR_ESERVICE
PETITIONER'S AMENDED REQUEST FOR EMERGENCY EX PARTE TEMPORARY RESTRAINING ORDER_F77DC859.pdf
...ylaw.com Envelope ID: 95552363 Filing Code Description: AMENDED MOTION Filing Description: APPLICATION FOR AMENDED TEMPORARY EX PARTE PROTECTIVE ORDER Status as of 12/20/2024 2:10 PM CST Associated Case Party: GWENDOLYN ULIJASZ MCKEMIE Name BarNumber Email TimestampSubmitted Status Donna Tomlinson donna@jhfamilylaw.com 12/20/2024 12:19:08 PM SENT Crystal Martinez crystal@jhfamilylaw.com 12/20/2024 12:19:08 PM SENT Associated Case Party: JASON MCKEMIE Name BarNumber Email TimestampSubmitted Status Brant M.Webb firm@webbfamilylaw.com 12/20/2024 12:19:08 PM...
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2024-12-20
Respondent / Jason
Counter Claim
Page 1
PLEADING_START_FILE_MARKED
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
12/20/2024 1:36 PM DALLAS CO., TEXAS NOTICE: THIS DOCUMENT NO. DF-24-18010 THE MARRIAGE OF § § AND § ORIGINAL COUNTERPETITION FOR DIVORCE 1. Discovery Discovery in this case is intended to be conducted under level 2 of rule 190 of the Texas Rules of Civil Procedure. Preservation of Evidence: Counterrespondent is put on notice to preserve and not destroy, conceal, or alter any evidence or potential evidence relevant to the issues in this case, including tangible documents or items in Counterrespondent's possession or subject to Counterrespondent's control...
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2024-12-20
Respondent / Jason
Counter Claim
Page 2
PLEADING_BODY
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
...na R. Tomlinson, 4201 Spring Valley Road, Suite 1210, Dallas, Texas 75244. 6. Protective Order Statement A Temporary Ex Parte Protective Order was issued on December 18, 2024. 7. Dates of Marriage and Separation The parties were entered into an informal marriage on or about February 1, 2024. The parties entered into a ceremonial marriage on or about June 22, 2024 and ceased to live together as spouses on or about December 9, 2024. 8. Grounds for Divorce Counterrespondent is guilty of cruel treatment toward Counterpetitioner of a nature that renders furth...
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2024-12-20
Respondent / Jason
Counter Claim
Page 3
PLEADING_BODY
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
10. Division of Community Property Counterpetitioner believes Counterpetitioner and Counterrespondent will enter into an agreement for the division of their estate. If such an agreement is made, Counterpetitioner requests the Court to approve the agreement and divide their estate in a manner consistent with the agreement. If such an agreement is not made, Counterpetitioner requests the Court to divide their estate in a manner that the Court deems just and right, as provided by law. Counterpetitioner should be awarded a disproportionate share of the parti...
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2024-12-20
Respondent / Jason
Counter Claim
Page 4
PLEADING_BODY
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
...t of the community estate of the parties, and Counterpetitioner requests the Court to confirm that separate property as Counterpetitioner's separate property and estate. 12. Reimbursement Counterpetitioner requests the Court to reimburse the community estate for funds or assets expended by the community estate for the benefit of Counterrespondent's separate estate. Those expenditures resulted in a direct benefit to Counterrespondent's separate estate. The community estate has not been adequately compensated for or benefited from the expenditure of those...
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2024-12-20
Respondent / Jason
Counter Claim
Page 5
PLEADING_BODY
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
compensated for or benefited from the expenditure of those funds or assets, and a failure by the Court to allow reimbursement to Counterpetitioner's separate estate will result in an unjust enrichment of Counterrespondent's separate estate at the expense of Counterpetitioner's separate estate. Counterpetitioner further requests that, if the Court determines it to be appropriate, any claims for reimbursement be offset. 13. Request for Temporary Orders and Injunction Counterpetitioner requests the Court, after notice and hearing to dispense with the issuan...
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2024-12-20
Respondent / Jason
Counter Claim
Page 6
PLEADING_BODY
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
currently in place. b. Awarding Counterpetitioner the exclusive use and possession of the marital residence, as well as the furniture, furnishings, and other personal property at the residence, while this case is pending, and enjoining Counterrespondent from entering or remaining on the premises of the residence and exercising possession or control of any of his personal property, except as authorized by order of this Court. c. Awarding Counterpetitioner the exclusive use and control of the motor vehicle currently in Counterpetitioner’s possession or con...
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2024-12-20
Respondent / Jason
Counter Claim
Page 7
PLEADING_BODY
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
...t as allowed by law, for costs of court, and for general relief. Respectfully submitted, THE WEBB FAMILY LAW FIRM, P.C. 325 N. St. Paul Street Suite 3900 Dallas, Texas 75201 Tel: (214) 871-2730 Fax: (214) 871-93396 By: Brant M. Webb State Bar No. 24076764 firm@webbfamilylaw.com Attorney for Counterpetitioner ORIGNAL COUNTERPETITION FOR DIVORCE- PAGE 7 OF 8 MCKEMIE Copy from re:SearchTX
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2024-12-20
Respondent / Jason
Counter Claim
Page 8
CERTIFICATE_OF_SERVICE
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
accordance with rule 21a of the Texas Rules of Civil Procedure on the following on December __,20 2024: Donna R. Tomlinson by electronic filing manager. Brant M. Webb Attorney for Jason McKemie ORIGNAL COUNTERPETITION FOR DIVORCE- PAGE 8 OF 8 MCKEMIE Copy from re:SearchTX
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2024-12-20
Respondent / Jason
Counter Claim
Page 9
EXHIBIT_START
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
EXHIBIT F2023/08 A (REVISED JANUARY 4, 2023) CHILDREN, PETS, PROPERTY AND CONDUCT OF THE PARTIES No party to this lawsuit has requested this order. Rather, this order is a standing order of the family law matters_ have adopted this order because the parties, their children and the family pets should be protected and their property preserved while the laws·uit is pending before the court. I Therefore, it is ORDERED: 1. NO -DISRUPTION OF CHILDREN. All parties -are ORDERED to refrain from doing the following acts co_ncerning any children who a re subjects o...
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2024-12-20
Respondent / Jason
Counter Claim
Page 10
EXHIBIT_CONTINUATION
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
3.2 Threatening -the other party in person or in any other manner, including, by - telephone or another electronic voice transmission, video chat, social me.dia, or in writing, or .electronic messaging, to take unlawful action against any person, intending by this action. to annoy or.alarm the other party. 3:3 Pl.acing one or more telephone calls or text messages, at an unreasonable hour, in an offensive or repetitious manner, without a legitimate purpose of communication, or anonymously with the intent_to alarm or annoy .the other party. 3.4 Illegally i...
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#
2024-12-20
Respondent / Jason
Counter Claim
Page 11
EXHIBIT_CONTINUATION
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
negotiable·instrument payable to the other party without the ·personal signature of the other . party. 4.12 Destroying, disposing of, or altering, any financial records of the parties, including canceled checks, deposit slips, and other records_ fr.om a financial institution,. a record of credit purchases orcash advances, a tax return, and a financial statement. 4.13 Destroying, disposing of, or altering any email, text message, video message, or chat message or social -media message or other electronic data or electronically stored information relevant...
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2024-12-20
Respondent / Jason
Counter Claim
Page 12
EXHIBIT_CONTINUATION
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
6.1 Withdrawing or borrowing in any manner all or any pa'rt of the cash surrender value of life insurance policies on the life of either party, except" as specifically authorized by this order. 6.2. Changing or. in any manner altering the beneficiary designation -on any life insurance on the life of either-party or the parties' children. 6.3 Canceling, altering, or in any manner affecting any casualty, automobile, or health insµrance policies insuri_ng the parties 1 property or persons including the pa'rties 1 minor children. 7. SPECIFIC AUTHORIZATIONS I...
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2024-12-20
Respondent / Jason
Counter Claim
Page 13
EXHIBIT_CONTINUATION
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
PARTIES. SHALL BECOME EFFECTIVE ON JANUARY 4, 2023. ~qn. Kif!) Br9yv~ , Hon. Mary Brow Judge~ 254th District Court Judge, 301st Distr Hon. Vonda· Bailey Judge, 255th District Court Hon. Sandre Streete Hon. LaDeitr Judge, 256th District Court Judge; 303rd District Court Hon. Andrea D. Pluml ee • Judge, 330th District Court .·oallas County Family Courts Standing Order SI Pag e Copy from re:SearchTX
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2024-12-20
Respondent / Jason
Counter Claim
Page 14
EXHIBIT_START
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
...d are true and correct. I am the Counterpetitioner in this case and I am currently married to Gwendolyn "Gwen" Ulijasz-McKemie. We were informally married on February 1, 2024 (see Declaration of Domestic Partnership Form, attached as " Exhibit B-1 ") and ceremonially married on June 22, 2024. I have known my wife for approximately eighteen (18) months. Gwen's Issues with Medication and Drug Use Gwen McKemie has been on a multitude of different selective serotonin reuptake inhibitor ("SSRI") medications for approximately the last eighteen (18) years - "ne...
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2024-12-20
Respondent / Jason
Counter Claim
Page 15
EXHIBIT_CONTINUATION
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
...e, she was completely unmedicated. I am uncertain at what time she stopped taking the other four medications, however I strongly believe this to have occurred in June of 2024 at the time of our marriage as that is when I began to witness significant behavioral and emotional maturity shifts. In October of 2023, there was a piece of paper on an end table with some hand written notes on it that said "If Jason doesn't need AA, then maybe I don't either." This I found troubling, as AA was the conrnerstone of Gwen 's sobriety. About a week late r, Gwen confess...
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#
2024-12-20
Respondent / Jason
Counter Claim
Page 16
EXHIBIT_CONTINUATION
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
On Friday, August 16th 2024, she was officially unmedicated. This is when things began to escalate to a very volatile level. From that point forward I noticed drastic changes in her behavior she was unable to process emotions in a healthy way. She was extremely short tempered, extremely defensive, very combative, and just mad and irrational. She lacked even the most basic level of self-awareness or control of her emotions. Everything was a war, and she was never wrong, and lacked any capacity for ownership of her part in any type of disagreement. It was...
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#
2024-12-20
Respondent / Jason
Counter Claim
Page 17
EXHIBIT_CONTINUATION
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
...years sober. However, she has " stolen " my Adderall prescription on multiple occasions and consumed it without my knowledge or consent. The first time was in October of 2023; she confessed to me after a couple weeks of use. Although she agreed to be open with me about what she was struggling with, she continued to consume my Adderall prescription. Many times she would come to me and ask for just one or two pills because she did not get her meds for another few days. In addition, she has consumed THC gummies nightly for months and psylocibin ("magic mush...
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#
2024-12-20
Respondent / Jason
Counter Claim
Page 18
EXHIBIT_CONTINUATION
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
...which made the encounter even more irrational. I was in absolute shock, and she just stared at me. And then went upon her shower like nothing ever happened. In November 2024, she blew up in the kitchen and began screaming violently in my face appearing to attempt to insight a response from me, I cried begging her to please calm down and she then mocked me for crying. It was at that time I started reaching out to friends for support, only telling pieces of the hell I was living in. If the mornings were not bad enough, the evenings got terrible also. We w...
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#
2024-12-20
Respondent / Jason
Counter Claim
Page 19
EXHIBIT_CONTINUATION
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
of the day that were so far from reality and would just tell me how awful I am, or how much of an embarrassment I was and it would go on and on. I would just try to ignore it but it was impossible. Because of this I started trying to stay up later so that she would be out when I came in. Then after enough fits of"Why don't you ever go to bed with me?" I started doing so again. But it was hard sleeping through this constant prodding; I wanted to fall into a deep sleep as quickly as possible. And her behaviors had all the addictive traits: victim syndrome,...
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#
2024-12-20
Respondent / Jason
Counter Claim
Page 20
EXHIBIT_CONTINUATION
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
...orning would wreck me for half a day as I poured my heart out into letters and to spend hours perfectly crafting every word not to trigger her. On the night of August 3, 2024, she became irritated. She went into our bedroom and grabbed my CPAP machine and smashed it on the floor. Telling me that's where I deserve to sleep - on the floor. She threw clothes and pillows from upstairs while screaming frantically. On another occasion, she took our wedding license out and shredded it in the living room. Gwendolyn admitted later that night that she knew her beh...
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#
2024-12-20
Respondent / Jason
Counter Claim
Page 21
EXHIBIT_CONTINUATION
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
...een locked out of all marital finances, on top of my credit card balances so high, the only card I have access to is a joint Chase card. Gwen informed me on December 18, 2024, that she was shutting off healthcare and all other marital accounts, and I have been left unable to provide for myself at this time. She has deactivated a card tied to our health savings account and I do not have access to the replacement. Since December 12, 2024, the following things have occurred: (1) documents related to this matter have randomly printed from my home printer; (2...
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#
2024-12-20
Respondent / Jason
Counter Claim
Page 22
EXHIBIT_CONTINUATION
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
...has made against me. ______________________________ Jason McKemie My name is Jason McKemie, my date of birth is April 8, 1976, and I reside at 539 W. Commerce St., Suite 2010, Dallas, Texas 75208. I declare under penalty of perjury that the foregoing is true and correct. ______________________________ Jason McKemie, Declarant UNSWORN DECLARATION OF JASON MCKEMIE PAGE 9 OF 9 Copy from re:SearchTX
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2024-12-20
Respondent / Jason
Counter Claim
Page 23
EXHIBIT_CONTINUATION
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
Unsworn Declaration 2024-12-20 clean Final Audit Report 2024-12-20 Created: 2024-12-20 By: Brant Webb (brant@webbfamilylaw.com) Status: Signed Transaction ID: CBJCHBCAABM 1JorJf66wahUsz-C6DPbY41 koHgyyT _T "Unsworn Declaration 2024-12-20 clean" History f:l Document created by Brant Webb (brant@webbfamilylaw.com) 2024-12-20- 7:17:11 PM GMT 12.. Document emailed to Jason McKemie Umckemie@mckemie.net) for signature 2024-12-20- 7:17:32 PM GMT f:l Email viewed by Jason McKemie Umckemie@mckemie.net) 2024-12-20- 7:24:23 PM GMT 0o Document e-signed by Jason McKe...
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#
2024-12-20
Respondent / Jason
Counter Claim
Page 24
EXHIBIT_START
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
EXHIBIT B-1 Ccognizant Declaration of Domestic Partnership Form 111.tN Od,'frf LA LI. fl.A- UL I..J A~ -i:; Q. Associate Name Associate ID JASot'J ~,.,, 0 ~ Y /Vl c J{ £ M. r E g;t3 Domestic Partner Name Social Security Number I Certify that we meet the following criteria as domestic partners for the purpose of being eligible for medlcallprescriptlon, dental, vision, and cemln voluntary coverage fac:llltated by Cognizant Technology Solutions US Corp (the "Company'?: 1. We have an exclusive mutual commitment similar to that of marriage; 2. We are each oth...
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#
2024-12-20
Respondent / Jason
Counter Claim
Page 25
EXHIBIT_CONTINUATION
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
Please Cheek Applicable BOX9$ I wish to enroll: 1! My partner in the Company's medical, dental, and/or vision coverages □ My partner and the dependent children of my partner in the medical, dental, and/or vision coverage. The person(s} I wish to enroll qualify as my tax dependent(s) under the Internal Revenue Code. □ Yes Iii. No I affirm the statements made above are true and complete to the best of my knowledge and understand that false statements and/or the failure to notify the Company of any changes in status can result in loss of coverage and discip...
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#
2024-12-20
Respondent / Jason
Counter Claim
Page 26
EXHIBIT_CONTINUATION
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
CHASEO July 31 , 2023 through August 21 , 2023 JPMorgan Chase Bank, N.A. Account Number: ■■■■■■18·93 PO Box 182051 Columbus, OH 43218-2051 CUSTOMER SERVICE INFORMATION Web site: Chase.com Service Center: 1-888-262-4273 00008607 DRE 201 141 23423 NNNNNNNNNNN T 100000000015 0000 Para Espanol: 1-888-262-4273 GWENDOLYN L ULIJASZ International Calls: 1-713-262-1679 OR JASON E MCKEMIE We accept operator relay calls 4223 TRAVIS ST DALLAS TX 75205-4449 Ic -, ~ ~ Chase Sapphire Checking I CHECKING SUMMARY I AMOUNT Beginning Balance Deposits and Additions Ending B...
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#
2024-12-20
Respondent / Jason
Counter Claim
Page 27
EXHIBIT_CONTINUATION
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
CHASEO December 22, 2023 through January 23, 2024 JPMorgan Chase Bank, N.A. Account Number: ~93 PO Box 182051 Columbus, OH 43218-2051 CUSTOMER SERVICE INFORMATION Web site: Chase.com Service Center: 1-888-262-4273 00140423 DRE 20121902424 NNNNNNNNNNN 100000000015 0000 Para Espanol: 1-888-262-4273 GWENDOLYN L ULIJASZ International Calls: 1-713-262-1679 OR JASON E MCKEMIE We accept operator relay calls 4223 TRAVIS ST DALLAS TX 75205-4449 -,I -, ==== f ~ c I CHECKING SUMMARY I Chase Sapphire Checking AMOUNT Beginning Balance Deposits and Additions Electroni...
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2024-12-20
Respondent / Jason
Counter Claim
Page 28
EXHIBIT_CONTINUATION
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
< SAPPHIRE CH ... KING ( ... 6893) Available balance Account details Available balance Present balance Account number Routing number Interest rate Interest in 2024 Last statement date Jan 23, 2024 1 Hide details A 0 Pay Transfer More Copy from re:SearchTX
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2024-12-20
Respondent / Jason
Counter Claim
Page 29
EXHIBIT_CONTINUATION
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
.../24/2023 TEXAS DRIVER'S LICENSE Texas~ DRIVER LICENSE D Director: __..,,.,._,c_ ~ • J ~tJ,..,,,v-- 4d. DL: 9. Class ~· ·~,'~.-! ~: ....; 4b.:sx:J! 3. DOB: !4a. lss: 8. D 12. R 16. H t,11ie.., 5. D ..,_...., '1c. l CLASS: C-Single or comb veh w/ ~VWR s 26,000 lbs which transports plac rded HAZMAT or:! 16 pass, Including driver REST: NONE REV: 07/16/2021 Directive to physician Emergency Contact# Allergic reaction to drugs: TEXAS ROADSIDE ASSISTANCE: 1-800-525-5555 Copy from re:SearchTX
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2024-12-20
Respondent / Jason
Counter Claim
Page 30
EXHIBIT_CONTINUATION
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
...ENSEsi Dl rector: ~t,4e. -,►1 ~~ CLASS: C-Single or t omb veh w/~ VWR ~ 26,000 I HAZMAT or~ 16 pa~ inelu<ti~1d'iiv REST: A - With corre.c:tlvt: tettir ~ - ~ REV;;87T'I 6/2021 Directive to physrclan ,'Emergency Contact# Allergic reaction to drugs: EXAS ROADSIDE ASSISTANCE: M0Q_~26'~56 Copy from re:SearchTX
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2024-12-20
Respondent / Jason
Counter Claim
Page 31
FILING_STAMP_OR_ESERVICE
ORIGINAL COUNTERPETITION FOR DIVORCE_975DCC91.pdf
...24076764 betty@webbfamilylaw.com Envelope ID: 95557104 Filing Code Description: Counter Claim Filing Description: ORIGINAL COUNTERPETITION FOR DIVORCE Status as of 12/28/2024 7:48 AM CST Associated Case Party: GWENDOLYN ULIJASZ MCKEMIE Name BarNumber Email TimestampSubmitted Status Crystal Martinez crystal@jhfamilylaw.com 12/20/2024 1:36:42 PM SENT Donna Tomlinson donna@jhfamilylaw.com 12/20/2024 1:36:42 PM SENT Associated Case Party: JASON MCKEMIE Name BarNumber Email TimestampSubmitted Status Betty Villarreal betty@webbfamilylaw.com 12/20/2024 1:36:42...
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#020
2024-12-20
Respondent / Jason
AMENDED MOTION
Page 1
PLEADING_START_FILE_MARKED
APPLICATION FOR AMENDED TEMPORARY EX PARTE PROTECTIVE ORDER_76DE11BD.pdf
12/20/2024 12:19 PM SENSITIVE DATA | N TH E 254TH JUDICAL DISTRICT COURT Gwendolyn Ulijasz-McKemie § APPLICANT § vs. § § Jason McKemie § OF Dallas COU NTY, TEXAS RESPON DENT § for Amended EX Parte Protective Order AEElication Temgorarx 1. Parties: Gwendolyn Ulijasz-McKemie Dallas Applicant County of Residence Mark this box ifyou are completing and filing this application on behalf of the Applicant. Donna R. Tomlinson Attorney for Applicant Name of Person Filing the Application Title of Person Filing the Application Jason McKemie Respondent Respondent’s ad...
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#020
2024-12-20
Respondent / Jason
AMENDED MOTION
Page 2
PLEADING_BODY
APPLICATION FOR AMENDED TEMPORARY EX PARTE PROTECTIVE ORDER_76DE11BD.pdf
4. Children Under Age 18 Who Need Protection: Name Is Respondent the parent or guardian a. No D Yes D b. No D Yes D c. No D Yes D d. No D Yes D Mark all that apply: children are listed on a sheet attached to this Application. D Other children are or were members of the Applicant’s family or household. D The children have a court order that affects how and when they can visit their family or sets child support. D The 5. Other Adults: The Applicant requests protection for the following adults who are or were: members of the Applicant’s family or household;...
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#020
2024-12-20
Respondent / Jason
AMENDED MOTION
Page 3
PLEADING_BODY
APPLICATION FOR AMENDED TEMPORARY EX PARTE PROTECTIVE ORDER_76DE11BD.pdf
...place, or school of the: (Mark in this application. Q Applicant D children listed in this application D other Adults listed ReSidenceI 5609 La Foy Blvd., Dallas, Texas 75209 during the time period of December 21 at 9am to December 27 at 9am Workplace: School: Page 3 of 14 Copy from re:SearchTX
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#020
2024-12-20
Respondent / Jason
AMENDED MOTION
Page 4
PLEADING_BODY
APPLICATION FOR AMENDED TEMPORARY EX PARTE PROTECTIVE ORDER_76DE11BD.pdf
...ture harm to the Applicant or any person listed in this application as a person in need of protection. Vacate the residence located at 5609 La Foy B1Vd., Dallas, Texas 75209 during the time period of December 21 at 9am to December 27 at 9am. *NOTE: If the Respondent is a peace officer actively engaged in employment as a sworn, full-time paid employee of a state agency or political subdivision, the court may not suspend the Respondent’s license to carry a handgun or prohibit the Respondent from possessing a firearm. 9. Property Orders: (Complete this sect...
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#020
2024-12-20
Respondent / Jason
AMENDED MOTION
Page 5
PLEADING_BODY
APPLICATION FOR AMENDED TEMPORARY EX PARTE PROTECTIVE ORDER_76DE11BD.pdf
...tion of the Order. exclusive use of the following property that the Applicant and Respondentjointly own or E Applicant requests lease: 5609 La Foy B1vd., Dallas, Texas 75209 during the time period of December 21 at 9am to December 27 at 9am I Order the Respondent not to damage, transfer, encumber, or otherwise dispose of any property jointly E owned or leased by the parties, including removing or disabling any vehicle owned or possessed by the Applicant orjointly owned or possessed by the parties. 10. the box if the Applicant is married to the Respondent...
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#020
2024-12-20
Respondent / Jason
AMENDED MOTION
Page 6
PLEADING_BODY
APPLICATION FOR AMENDED TEMPORARY EX PARTE PROTECTIVE ORDER_76DE11BD.pdf
12. the box if asking for the removal, D Orders Related to Removal, Possession, and Support of Children (Mark possession, or support of the children) The Applicant and the Respondent are the parents or guardians of the following children: The Applicant asks the Court to enter the following orders with respect to the children: (Mark all that app/y): from the Applicant’s possession or from their child-care facility D The Respondent must not remove children or school, except as specifically authorized in a possession schedule or other order entered by the Co...
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#020
2024-12-20
Respondent / Jason
AMENDED MOTION
Page 7
PLEADING_BODY
APPLICATION FOR AMENDED TEMPORARY EX PARTE PROTECTIVE ORDER_76DE11BD.pdf
...Applicant asks the Court to designate the following person to receive on Applicant’s behalf all notices Name: Donna R. Tomlinson Address: 4201 Spring Valley Road, Suite 1210, Dallas, Texas 75244 15. Citations and Notices The Applicant asks the Court to issue all citations and notices required by law for the application and any resultant order. PRAYER WHEREFORE, PREMISES CONSIDERED, the Applicant prays the Court issue the protective order as requested in this Application, and, if applicable, the Applicant further prays the Court issue a Temporary Ex Part...
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#020
2024-12-20
Respondent / Jason
AMENDED MOTION
Page 8
PLEADING_BODY
APPLICATION FOR AMENDED TEMPORARY EX PARTE PROTECTIVE ORDER_76DE11BD.pdf
...ere Applicant or Person filing on behalf of Applicant may be contacted (List another address/telephone ifyou want yours kept confidential): 4201 Spring Valley Road, Suite 1210, Dallas, Texas 75244 214.420.0100 Page 8 of 14 Copy from re:SearchTX
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#020
2024-12-20
Respondent / Jason
AMENDED MOTION
Page 9
PLEADING_BODY
APPLICATION FOR AMENDED TEMPORARY EX PARTE PROTECTIVE ORDER_76DE11BD.pdf
...If yes, what happened? f. Did anyone call the police? D Yes D g. Were you injured? DYes DNo |fyes, describe your injuries: No h. Did you seek medical care? D Yes D Page 12 of 14 Copy from re:SearchTX
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#020
2024-12-20
Respondent / Jason
AMENDED MOTION
Page 10
PLEADING_BODY
APPLICATION FOR AMENDED TEMPORARY EX PARTE PROTECTIVE ORDER_76DE11BD.pdf
Has the Respondent threatened or hurt you before? D Yes D No If so, describe below how the Respondent threatened or hurt you, including date(s) if possible. No If yes, what kind? a. Were weapons ever involved? D Yes D If yes, who? b. Were the children present? DYes DNo No c. Did anyone report the conduct to the police? D Yes D No If yes, describe your injuries: d. Were you injured? D Yes D e. Did you seek medical care? D Yes D No No Has the Respondent ever been convicted of family violence? D Yes D If yes, list when and in which county and state the conv...
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#020
2024-12-20
Respondent / Jason
AMENDED MOTION
Page 11
EXHIBIT_START
APPLICATION FOR AMENDED TEMPORARY EX PARTE PROTECTIVE ORDER_76DE11BD.pdf
...ve possession of a residence and to have the Respondent excluded from the residence? YesD No a. What is the location of the residence? 5609 La Foy Blvd., Dallas, Texas 75209 b. Do you currently reside at the residence or have resided there within the last 30 days? No Yes D C. Please describe the facts and circumstances that require the Respondent to be excluded from the residence: See Petitioner's Supporting Declaration attached as Exhibit A and incorporated herein for all purposes. See Petitioner's Supporting Declaration attached as Exhibit A and incorp...
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#020
2024-12-20
Respondent / Jason
AMENDED MOTION
Page 12
EXHIBIT_CONTINUATION
APPLICATION FOR AMENDED TEMPORARY EX PARTE PROTECTIVE ORDER_76DE11BD.pdf
...n this case. The facts stated in this Declaration are within my personal knowledge and are true and correct. Jason McKemie is Respondent, and we were married on June 22, 2024. I am in fear of Jason McKemie based on his manic behavior and drug use that have escalated over the past few months. Jason has become more verbally abusive, and his threatening behavior has escalated. As a result, I have left the marital home as I no longer feel safe in the same proximity with him. Unbeknown to me during our courtship, Jason has been a consistent drug user and also...
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#020
2024-12-20
Respondent / Jason
AMENDED MOTION
Page 13
EXHIBIT_CONTINUATION
APPLICATION FOR AMENDED TEMPORARY EX PARTE PROTECTIVE ORDER_76DE11BD.pdf
I had no knowledge that Jason was already a daily drug user when our wedding ceremony took place on June 22, 2024. I only saw that his behavior changed in the months leading up to the wedding. I attributed it to a few other significant stressors going on at that time. He had expressed stresses with his job over the 10 months prior to the wedding and he was frustrated. We also had to unexpectedly relocate on short notice (8 weeks notice) before our wedding. This was the result of a broken pipe that flooded that home. He was anxious and irritable, smoking mo...
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#020
2024-12-20
Respondent / Jason
AMENDED MOTION
Page 14
EXHIBIT_CONTINUATION
APPLICATION FOR AMENDED TEMPORARY EX PARTE PROTECTIVE ORDER_76DE11BD.pdf
...person can live with and maintain their health and a job. Most recently, Jason’s behavior has now become paranoid as well as threatening. On Thursday night, December 12’ 2024, I returned from a business trip and found Jason angry. It felt different than other times in that he seemed to not be in control of himself. I was in my office sitting on the floor with open file medical files, situated between my desk and the filing cabinet toward the back of the room. My dog Katie was behind me in her bed. Unprovoked, he yelled for what I would estimate 35-40 minutes,...
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#020
2024-12-20
Respondent / Jason
AMENDED MOTION
Page 15
EXHIBIT_CONTINUATION
APPLICATION FOR AMENDED TEMPORARY EX PARTE PROTECTIVE ORDER_76DE11BD.pdf
he will continue this behavior. On the evening of December 16’ 2024, Jason sent a text that he would not allow me to have time on my own in the house. He stated that any entrance in our home would be monitored by him and his friends. I am frightened enough that I am living out of a suitcase with nowhere to go. I am afraid and I believe that the escalation in name calling, increasingly aggressive and now threatening talk and stalking behaviors will become violent. I have now realized that Jason has been digitally stalking and tracking me, whether I am in...
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