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2024-12-31
Respondent / Jason
Amended Petition
Page 1
PLEADING_START_FILE_MARKED
NOTICE OF HEARING_621CC227.pdf
12/31/2024 3:40 PM DALLAS CO., TEXAS NO- THE MARRIAGE 0F § § AND § NOTICE OF COURT PROCEEDING — REQUEST FOR TEMPORARY ORDERS Pursuant to the Texas Family Code, notice is given to Gwendolyn Ulijasz-McKemie that the court proceeding on Jason McKemie’s request for temporary orders contained in his First Amended Counterpetition for Divorce in the above-entitled numbered cause will be held before (600 Commerce Street, 4th Floor, Dallas, Texas 75202) on January 7, 2025, at 2:30 p.m. The Court’s contact information is: Court clerk: 214-653-6741 Court coordinato...
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2024-12-31
Respondent / Jason
Amended Petition
Page 2
CERTIFICATE_OF_SERVICE
NOTICE OF HEARING_621CC227.pdf
By )9 Brant M. WebbWM State Bar No. 24076764 finn@webbfamilvlaw.com Attorney for Jason McKemie Texas Rules of Civil Procedure on the following on December 31, 2024: Donna Tomlinson by electronic filing manager. 1. BW Brant M. Webb Attorney for Jason McKemie NOTICE OF COURT PROCEEDING- REQUEST FOR TEMPORARY ORDERS PAGE 2 0F 2 Copy from re:SearchTX
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2024-12-31
Respondent / Jason
Amended Petition
Page 3
FILING_STAMP_OR_ESERVICE
NOTICE OF HEARING_621CC227.pdf
...us as of 1/2/2025 9:21 AM CST Associated Case Party: GWENDOLYN ULIJASZ MCKEMIE Name BarNumber Email TimestampSubmitted Status Donna Tomlinson donna@jhfamilylaw.com 12/31/2024 3:40:50 PM SENT Crystal Martinez crystal@jhfamilylaw.com 12/31/2024 3:40:50 PM SENT Associated Case Party: JASON MCKEMIE Name BarNumber Email TimestampSubmitted Status Betty Villarreal betty@webbfamilylaw.com 12/31/2024 3:40:50 PM SENT Copy from re:SearchTX
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 1
PLEADING_START_FILE_MARKED
FIRST AMEND CONTERPETITION_3F9FE753.pdf
12/31/2024 3:40 PM DALLAS CO., TEXAS NOTICE: THIS DOCUMENT NO. DF-24-18010 THE MARRIAGE OF § FIRST AMENDED COUNTERPETITION FOR DIVORCE I. 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 an...
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 2
PLEADING_BODY
FIRST AMEND CONTERPETITION_3F9FE753.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 ofMarriage 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. Groundsfor Divorce Counterrespondent has committed adultery. Counterrespondent is guilty of cruel treatment toward Counter...
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 3
PLEADING_BODY
FIRST AMEND CONTERPETITION_3F9FE753.pdf
10. Division ofCommunity 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 partie...
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 4
PLEADING_BODY
FIRST AMEND CONTERPETITION_3F9FE753.pdf
of the panics, 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 fiinds or assets, and a failure...
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 5
EXHIBIT_START
FIRST AMEND CONTERPETITION_3F9FE753.pdf
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. Requestfor Temporary Orders and Injunction Counterpetitioner 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. Co...
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 6
EXHIBIT_CONTINUATION
FIRST AMEND CONTERPETITION_3F9FE753.pdf
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 control and enjoining Counterrespondent from entering, operating, or exercising control over it. d. Ordering Counterrespondent to pay reasonable interim attorney’s fees and expenses, including but not limited to fees for appraisals, accountants, actuaries, and s...
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 7
CERTIFICATE_OF_SERVICE
FIRST AMEND CONTERPETITION_3F9FE753.pdf
Counterpetitioner's attorney; or, in the alternative, Counterpetitioner requests that reasonable attorney's fees, expenses, and costs through trial and appeal be taxed as costs and be ordered paid directly to Counterpetitioner's attorney, who may enforce the order in the attorney‘s own name. Counterpetitioner requests postjudgment interest as allowed by law. I 7. Prayer Counterpetitioner prays that citation and notice issue as required by law and that the Court grant a divorce and all other relief requested in this petition. Counterpetitioner prays for a...
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 8
EXHIBIT_CONTINUATION
FIRST AMEND CONTERPETITION_3F9FE753.pdf
31, 2024: Donna R. Tomlinson by electronic filing manager. Brant M. Webb Attorney for Jason McKemie — FIRST AMENDED COUNTERPETITION FOR DIVORCE-MCKEMIE PAGE 8 OF 8 Copy from re:SearchTX
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 9
EXHIBIT_START
FIRST AMEND CONTERPETITION_3F9FE753.pdf
EXHIBIT F2023/08 (REVISED JAN UARY 4, 2023) CHILDREN, PETS, PROPERTY AND CONDUCT or 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 is pending before the » lawsuit court Therefore, it is ORDERED: 1. NO DISRUPTION 0F CHILDREN. All parties a-re ORDERED to refrain from doing the following acts concerning any children who are subjects of this...
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 10
EXHIBIT_CONTINUATION
FIRST AMEND CONTERPETITION_3F9FE753.pdf
3.2 Threatening -the other party in person or in any other manner, including, by- telephone or another electronic voice transmission, Video chat, sociai media, or in Writing, or .electronic messaging, to take unlawful action against any intending by this action. to person, annoy or alarm the other party . 3.3 Placing 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 r anonymously with the intentto alarm or annoy .the other party. 3.4 Illegally in...
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 11
EXHIBIT_CONTINUATION
FIRST AMEND CONTERPETITION_3F9FE753.pdf
. negotiable'instrument payable to the otherV party without the 'personal signature of the other ‘ . , . 1 party. , i 4.12 Destroying, disposing > of, or altering, any financial records of the parties, including canceled checks, deposit slips, and other records from a financial institution, a record of credit purchases or cash 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 informa...
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 12
EXHIBIT_CONTINUATION
FIRST AMEND CONTERPETITION_3F9FE753.pdf
6.1 Withdrawing or borrowing in any manner ail or any pa'rt of the cash surrender' value of lifeInsurance policies on the life of either pai'ty, 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 insurance policies insuring the pa'rties' property or- persons including the pa'rties' minor children. 7. I SPECIFIC AUTHORIZATIONS IN D...
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 13
EXHIBIT_CONTINUATION
FIRST AMEND CONTERPETITION_3F9FE753.pdf
' PARTIES BECOME EFFECTIVE ON JANUARY 4, 2023. SHALL ' Hon. Kim Hon'. Mary Brow‘U_ Judge, 254th District Court Judge, 301$t8“)waCourtDistr Hon. o\/rrda'Bailey ' Hon7Sandra '- ' W/M Judge, 255th District Court Judge, 302nd)flsontrict Court Hon. Sandre Streete Ho%. LaDeitr\a/Adkins Mgrfi Judge, 256th DIStl‘lCt Court Judge,- 303rd District Court Hon. Andrea D. ' Plumlee Judge, 330th District Court V ‘ " Copy from re:SearchTX
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 14
EXHIBIT_START
FIRST AMEND CONTERPETITION_3F9FE753.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 ofDomestic Partnership Form, attached as “Exhibit B-l”) 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 — “never...
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 15
EXHIBIT_CONTINUATION
FIRST AMEND CONTERPETITION_3F9FE753.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 conmerstone of Gwen’s sobriety. About a week later, Gwen confessed t...
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 16
EXHIBIT_CONTINUATION
FIRST AMEND CONTERPETITION_3F9FE753.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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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 17
EXHIBIT_CONTINUATION
FIRST AMEND CONTERPETITION_3F9FE753.pdf
vengeful and hateful in her words. Gwen could take accountability for nothing whatsoever; she was always a victim and there was always someone else to blame. If there wasn’t anything to be mad at, she would actively create something fictional just to have an excuse to attack me and constantly berate me with insults and incessant nagging, prodding and she would continue doing it for hours. There were countless nights I would try to go to sleep and she would just make comments, reinventing the events of the day into something unrecognizable so that she coul...
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 18
EXHIBIT_CONTINUATION
FIRST AMEND CONTERPETITION_3F9FE753.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 ofthe hell I was living in. Ifthe mornings were not bad enough, the evenings got terrible also. We wou...
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 19
EXHIBIT_CONTINUATION
FIRST AMEND CONTERPETITION_3F9FE753.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 ofthis 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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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 20
EXHIBIT_CONTINUATION
FIRST AMEND CONTERPETITION_3F9FE753.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 behav...
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 21
EXHIBIT_CONTINUATION
FIRST AMEND CONTERPETITION_3F9FE753.pdf
...been 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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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 22
EXHIBIT_CONTINUATION
FIRST AMEND CONTERPETITION_3F9FE753.pdf
...I hope Gwen gets the help she needs. However, at this point, my first priority is defending myself against allegations that Gwen has made against me. Jas McKemie (Dec 20,2024 13:25 CST) 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. McKemie (Dec 20, 2024 13:25 CST) Jason McKemie, Declarant — UNSWORN DECLARATION OF JASON MCKEMIE PAGE 9 OF 9 Copy from re:SearchTX
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 23
EXHIBIT_CONTINUATION
FIRST AMEND CONTERPETITION_3F9FE753.pdf
Unsworn Declaration 2024-12-20 clean Final Audit Report 2024—12-20 Created: 2024—12-20 By: Brant Webb (brant@webbfamilylaw.oom) Status: Signed Transacfion ID: CBJCHBCAABAA1JorJf66wahUsz—C6DPbY41 koHgyyT_T "Unsworn Declaration 2024-12-20 clean" History a Document created by Brant Webb (brant@webbfamilylaw.com) 2024-12-20 - 7:17:11 PM GMT Document emailed to Jason McKemie (jmckemie@mckemie.net) for signature a 2024-12-20 - 7:17:32 PM GMT B Email viewed by Jason McKemie (jmckemie@mckemie.net) 2024-12-20 - 7:24:23 PM GMT fie Document e-signed by Jason McKemie...
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 24
EXHIBIT_START
FIRST AMEND CONTERPETITION_3F9FE753.pdf
EXHIBIT B-1 , cognizant Declaration of Domestic Form Partnership QWJNDel/‘fpf LAlel {looms Assorfiate Name Associate it) mam 325%, McKgml-E —323 Domestic Partner Name Social Security Number I certify that we meet the following criteria as domestic partners for the purpose of being eligible for medical/prescription, dental, vision, and certain voluntary coverage facilitated by Cognizant Technology Solutions US Corp (the “Company”}: We have an exclusive mutual commitment similar to that of marriage; We are each other‘s sole domestic partner and intend to re...
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 25
EXHIBIT_CONTINUATION
FIRST AMEND CONTERPETITION_3F9FE753.pdf
Please Check Applicable Boxes I wish to email: I My partner in the Company's medical, dental. and/or vision caverages U My pafiner and the dependent chifdren ofmy partner in the modicaL deniafk andfor vision coverage. The person(s) t wish to enroii quafify as my tax dependent(s) under the lniemai Revenue Code. D Yes 3. No I affirm the statements made above are true and complete tn the best of my knowiedge and understand that fafse statements analor the failure to notify the Cempany of any changes in status can result in £095 of coverage, and disciplinary ac...
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 26
EXHIBIT_CONTINUATION
FIRST AMEND CONTERPETITION_3F9FE753.pdf
CHASE cl July 31. 2023 through August 21, 2023 JPMorgan Chase Bank, N.A. Account Number: P O Box 182051 —893 Columbus, OH 43218 - 2051 CUSTOMER SERVICE INFORMATION Web site: Chase.com Service Center: 1-888-262-4273 00008607 DRE 201 141 23423 NNNNNNNNNNN T 1 00000000015 0000 Para Espanol: 1-888-262-4278 GWENDOLYN L ULIJASZ International Calls: 1-713-262-1679 OR JASON E MCKEMIE We aooept operator relay calls 4223 TRAVIS ST DALLAS TX 75205-4449 nnnnnnn’H n4 nan-Ind nnn CHECKING SUMMARY Chase Sapphire Checking AMOUNT Beginning Balance Deposits and Additions...
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 27
EXHIBIT_CONTINUATION
FIRST AMEND CONTERPETITION_3F9FE753.pdf
CHASE cl December 22, 2023 through January 23, 2024 JPMorgan Chase Bank, N.A. Account Number: P O Box 182051 _893 Columbus, OH 43218 - 2051 CUSTOMER SERVICE INFORMATION Web site: Chase.com Service Center: 1-888-262-4273 00140423 DRE 201 219 02424 NNNNNNNNNNN 1 000000000 15 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 nnnnnnn’H n4 AnA’lQrH n4 CHECKING SUMMARY Chase Sapphire Checking AMOUNT Beginning Balance Deposits and Additi...
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 28
EXHIBIT_CONTINUATION
FIRST AMEND CONTERPETITION_3F9FE753.pdf
...I ‘3‘ Q' < SAPPHIRE CH...K|NG (...6893) Available balance Account details Available balance Present balance Account number 93 Routing number 14 Interest rate Interest in 2024 Last statement date Jan 23, 2024 Hide details A I E) Pay Transfer More Copy from re:SearchTX
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 29
EXHIBIT_CONTINUATION
FIRST AMEND CONTERPETITION_3F9FE753.pdf
...VER LICENSE , > - erector: ,W10 4: I444, DR Ld‘ LICENSE ra 4d. DL: 84 9.Class: C I 4b DOB: Iss: - i 1 MCKEMIE 3;; 1 ' WW" 9 WQWJL 9H \3’ 8. 4223TRI-WI5STE I BALM xx 7520 12. Rest: NGNE 9:58;! End:NONE 5 16 Hgt:.-15$ex:.M 18..Eyes:HAZ s 77%"; - on— W CLASS: C-SingIé or comb veh wl GVWR 5 26.000 lbs which transports placarded HAZMAT or a 16 pass. Including driver REST: NONE END: NONE REV: 07/16/2021 Directive to physician has been filed at Tel 1: Emergency Contact# Allergic reaction to drugs: TEXAS ROADS DE ASSISTANCE: 1-800-525-5555 Copy from re:SearchTX
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 30
EXHIBIT_CONTINUATION
FIRST AMEND CONTERPETITION_3F9FE753.pdf
4;- . ' _ ' ‘ BBNHO BSNBOH §SBXBTL1 napalm ”M a Q «Ea; ‘ a . zsvrnn w 3 ~vunvztmmuamz nmzvu 10 2 91 ‘ssad fingpmaug mup -\ 111.938 WM Ydfiémtmmwoa Q %g?’ _ f Q Q\ xi‘éjké. . I“ w - v win , M ‘=aN3 ENON IQ" 303/9 .7Lug-HAHN V Manna o; “Magsltqd seq uaaq pom “One Kauamalua “canon agmanv names: -as. :slimp svx3 BOISOVOH L§ISSV =3N «9930:whoon ‘~‘\'."§-F::fi w.‘ '4‘. | ~ = \\ \\-\\\Xlk\x‘s‘ \fi\ K»\\\.\\\ Copy from re:SearchTX
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#025
2024-12-31
Petitioner / Gwendolyn
Amended Petition
Page 31
FILING_STAMP_OR_ESERVICE
FIRST AMEND CONTERPETITION_3F9FE753.pdf
...as of 1/2/2025 9:21 AM CST Associated Case Party: GWENDOLYN ULIJASZ MCKEMIE Name BarNumber Email TimestampSubmitted Status Crystal Martinez crystal@jhfamilylaw.com 12/31/2024 3:40:50 PM SENT Donna Tomlinson donna@jhfamilylaw.com 12/31/2024 3:40:50 PM SENT Associated Case Party: JASON MCKEMIE Name BarNumber Email TimestampSubmitted Status Betty Villarreal betty@webbfamilylaw.com 12/31/2024 3:40:50 PM SENT Copy from re:SearchTX
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2024-12-31
Respondent / Jason
Amended Petition
Page 1
PLEADING_START_FILE_MARKED
18. 2024-12-31 Notice of Court Proceeding- Request for Temporary Orders.pdf
12/31/2024 3:40 PM DALLAS CO., TEXAS NO. DF-24-18010 THE MARRIAGE OF § § AND § NOTICE OF COURT PROCEEDING – REQUEST FOR TEMPORARY ORDERS Pursuant to the Texas Family Code, notice is given to Gwendolyn Ulijasz-McKemie that the court proceeding on Jason McKemie’s request for temporary orders contained in his First Amended Counterpetition for Divorce in the above-entitled numbered cause will be held before (600 Commerce Street, 4th Floor, Dallas, Texas 75202) on January 7, 2025, at 2:30 p.m. The Court’s contact information is: Court clerk: 214-653-6741 Cour...
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2024-12-31
Respondent / Jason
Amended Petition
Page 2
CERTIFICATE_OF_SERVICE
18. 2024-12-31 Notice of Court Proceeding- Request for Temporary Orders.pdf
By: Brant M. Webb State Bar No. 24076764 firm@webbfamilylaw.com Attorney for Jason McKemie Texas Rules of Civil Procedure on the following on December 31, 2024: Donna Tomlinson by electronic filing manager. Brant M. Webb Attorney for Jason McKemie NOTICE OF COURT PROCEEDING- REQUEST FOR TEMPORARY ORDERS PAGE 2 OF 2
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2024-12-31
Respondent / Jason
Amended Petition
Page 3
FILING_STAMP_OR_ESERVICE
18. 2024-12-31 Notice of Court Proceeding- Request for Temporary Orders.pdf
...us as of 1/2/2025 9:21 AM CST Associated Case Party: GWENDOLYN ULIJASZ MCKEMIE Name BarNumber Email TimestampSubmitted Status Donna Tomlinson donna@jhfamilylaw.com 12/31/2024 3:40:50 PM SENT Crystal Martinez crystal@jhfamilylaw.com 12/31/2024 3:40:50 PM SENT Associated Case Party: JASON MCKEMIE Name BarNumber Email TimestampSubmitted Status Betty Villarreal betty@webbfamilylaw.com 12/31/2024 3:40:50 PM SENT
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2024-12-31
Respondent / Jason
Amended Petition
Page 1
PLEADING_START_FILE_MARKED
17. 2024-12-31 First Amended Counterpetition for Divorce.pdf
12/31/2024 3:40 PM DALLAS CO., TEXAS NOTICE: THIS DOCUMENT NO. DF-24-18010 THE MARRIAGE OF § § AND § FIRST AMENDED 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 co...
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2024-12-31
Respondent / Jason
Amended Petition
Page 2
PLEADING_BODY
17. 2024-12-31 First Amended Counterpetition for Divorce.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 has committed adultery. Counterrespondent is guilty of cruel treatment toward Count...
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2024-12-31
Respondent / Jason
Amended Petition
Page 3
PLEADING_BODY
17. 2024-12-31 First Amended Counterpetition for Divorce.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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2024-12-31
Respondent / Jason
Amended Petition
Page 4
PLEADING_BODY
17. 2024-12-31 First Amended Counterpetition for Divorce.pdf
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 funds or assets, and a fai...
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2024-12-31
Respondent / Jason
Amended Petition
Page 5
EXHIBIT_START
17. 2024-12-31 First Amended Counterpetition for Divorce.pdf
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 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. C...
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2024-12-31
Respondent / Jason
Amended Petition
Page 6
EXHIBIT_CONTINUATION
17. 2024-12-31 First Amended Counterpetition for Divorce.pdf
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 control and enjoining Counterrespondent from entering, operating, or exercising control over it. d. Ordering Counterrespondent to pay reasonable interim attorney’s fees and expenses, including but not limited to fees for appraisals, accountants, actuaries, and s...
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2024-12-31
Respondent / Jason
Amended Petition
Page 7
CERTIFICATE_OF_SERVICE
17. 2024-12-31 First Amended Counterpetition for Divorce.pdf
Counterpetitioner's attorney; or, in the alternative, Counterpetitioner requests that reasonable attorney's fees, expenses, and costs through trial and appeal be taxed as costs and be ordered paid directly to Counterpetitioner's attorney, who may enforce the order in the attorney's own name. Counterpetitioner requests postjudgment interest as allowed by law. 17. Prayer Counterpetitioner prays that citation and notice issue as required by law and that the Court grant a divorce and all other relief requested in this petition. Counterpetitioner prays for at...
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2024-12-31
Respondent / Jason
Amended Petition
Page 8
EXHIBIT_CONTINUATION
17. 2024-12-31 First Amended Counterpetition for Divorce.pdf
31, 2024: Donna R. Tomlinson by electronic filing manager. Brant M. Webb Attorney for Jason McKemie FIRST AMENDED COUNTERPETITION FOR DIVORCE-MCKEMIE PAGE 8 OF 8
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2024-12-31
Respondent / Jason
Amended Petition
Page 9
EXHIBIT_START
17. 2024-12-31 First Amended Counterpetition for Divorce.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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2024-12-31
Respondent / Jason
Amended Petition
Page 10
EXHIBIT_CONTINUATION
17. 2024-12-31 First Amended Counterpetition for Divorce.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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2024-12-31
Respondent / Jason
Amended Petition
Page 11
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17. 2024-12-31 First Amended Counterpetition for Divorce.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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2024-12-31
Respondent / Jason
Amended Petition
Page 12
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17. 2024-12-31 First Amended Counterpetition for Divorce.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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2024-12-31
Respondent / Jason
Amended Petition
Page 13
EXHIBIT_CONTINUATION
17. 2024-12-31 First Amended Counterpetition for Divorce.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
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2024-12-31
Respondent / Jason
Amended Petition
Page 14
EXHIBIT_START
17. 2024-12-31 First Amended Counterpetition for Divorce.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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2024-12-31
Respondent / Jason
Amended Petition
Page 15
EXHIBIT_CONTINUATION
17. 2024-12-31 First Amended Counterpetition for Divorce.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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2024-12-31
Respondent / Jason
Amended Petition
Page 16
EXHIBIT_CONTINUATION
17. 2024-12-31 First Amended Counterpetition for Divorce.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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2024-12-31
Respondent / Jason
Amended Petition
Page 17
EXHIBIT_CONTINUATION
17. 2024-12-31 First Amended Counterpetition for Divorce.pdf
vengeful and hateful in her words. Gwen could take accountability for nothing whatsoever; she was always a victim and there was always someone else to blame. If there wasn't anything to be mad at, she would actively create something fictional just to have an excuse to attack me and constantly berate me with insults and incessant nagging, prodding and she would continue doing it for hours. There were countless nights I would try to go to sleep and she would just make comments, reinventing the events of the day into something unrecognizable so that she cou...
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2024-12-31
Respondent / Jason
Amended Petition
Page 18
EXHIBIT_CONTINUATION
17. 2024-12-31 First Amended Counterpetition for Divorce.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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2024-12-31
Respondent / Jason
Amended Petition
Page 19
EXHIBIT_CONTINUATION
17. 2024-12-31 First Amended Counterpetition for Divorce.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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2024-12-31
Respondent / Jason
Amended Petition
Page 20
EXHIBIT_CONTINUATION
17. 2024-12-31 First Amended Counterpetition for Divorce.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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2024-12-31
Respondent / Jason
Amended Petition
Page 21
EXHIBIT_CONTINUATION
17. 2024-12-31 First Amended Counterpetition for Divorce.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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2024-12-31
Respondent / Jason
Amended Petition
Page 22
EXHIBIT_CONTINUATION
17. 2024-12-31 First Amended Counterpetition for Divorce.pdf
opened (specifically in the Files app) without any interaction from me; and (3) I have found an Apple AirTag in my vehicle. Upon further investigation, I found that the last 4 digits of Gwen's phone number were registered to the device. Gwen has pursued litigation against her last three (3) relationships (2 boyfriends & 1 husband) which all included orders of protection alleging abuse. She is not only currently in litigation against her prior employer for abuse, but had litigated and received a settlement from a previous employer as well. And when a floo...
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2024-12-31
Respondent / Jason
Amended Petition
Page 23
EXHIBIT_CONTINUATION
17. 2024-12-31 First Amended Counterpetition for Divorce.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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2024-12-31
Respondent / Jason
Amended Petition
Page 24
EXHIBIT_START
17. 2024-12-31 First Amended Counterpetition for Divorce.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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2024-12-31
Respondent / Jason
Amended Petition
Page 25
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17. 2024-12-31 First Amended Counterpetition for Divorce.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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2024-12-31
Respondent / Jason
Amended Petition
Page 26
EXHIBIT_CONTINUATION
17. 2024-12-31 First Amended Counterpetition for Divorce.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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2024-12-31
Respondent / Jason
Amended Petition
Page 27
EXHIBIT_CONTINUATION
17. 2024-12-31 First Amended Counterpetition for Divorce.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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2024-12-31
Respondent / Jason
Amended Petition
Page 28
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17. 2024-12-31 First Amended Counterpetition for Divorce.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
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2024-12-31
Respondent / Jason
Amended Petition
Page 29
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17. 2024-12-31 First Amended Counterpetition for Divorce.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
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2024-12-31
Respondent / Jason
Amended Petition
Page 30
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17. 2024-12-31 First Amended Counterpetition for Divorce.pdf
DRIVES LICENSEsi 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
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2024-12-31
Respondent / Jason
Amended Petition
Page 31
FILING_STAMP_OR_ESERVICE
17. 2024-12-31 First Amended Counterpetition for Divorce.pdf
...as of 1/2/2025 9:21 AM CST Associated Case Party: GWENDOLYN ULIJASZ MCKEMIE Name BarNumber Email TimestampSubmitted Status Crystal Martinez crystal@jhfamilylaw.com 12/31/2024 3:40:50 PM SENT Donna Tomlinson donna@jhfamilylaw.com 12/31/2024 3:40:50 PM SENT Associated Case Party: JASON MCKEMIE Name BarNumber Email TimestampSubmitted Status Betty Villarreal betty@webbfamilylaw.com 12/31/2024 3:40:50 PM SENT
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2024-12-31
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16. 2024-12-31 Order Modifying and Extending Temporary Restraining Order and Order Setting Hearing for Temporary Orders signed.pdf
...rders of petitioner, Gwendolyn Ulijasz-McKemie, and finds that good cause exists to exlend the Ex parte Ternporary Restraining Order signed by this Court on December i8, 2024, due to an inability to obtain thl evidence and witnesses required, within the fourteen-day period. The Court examined the pleadings of Petitioner and finds that Petitioner is entitled to an extension of the ternporary restraining order rendered by this Court on December 18, 2024. IT IS THEREFORE ORDERED that the clerk of this Court issue a temporary restraining order restraining Re...
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16. 2024-12-31 Order Modifying and Extending Temporary Restraining Order and Order Setting Hearing for Temporary Orders signed.pdf
7 Intentionally falsifying a writing or record, including an electronic record, relating to the property of either parly. 8 Intentionally misrepresenting or refusing to disclose to Petitioner or to the Court, on proper request, the existence, atnount, or location of any tangible or intellectual property of one or both of the parties, including electronically stored or recorded information. 9 intention'ally or knowingly damaging or destroying the tangible or intellecfual property of one or both of the parties, including electronically stored or recorded i...
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16. 2024-12-31 Order Modifying and Extending Temporary Restraining Order and Order Setting Hearing for Temporary Orders signed.pdf
endorsing Petitioner's name on any negotiable instrument' check' or 22. Signing or draft, incluaing u tai refund, insurance payment, and dividend, or attempting to "negotiable instrument payable to Petitioner without the personal negotiate any signature of Petitioner. tenninate or limit credit or charge cards in the name of 23. Taking any action to Petitioner. the withholding for federal income taxes from either 24. Discontinuing or reducing party's wages or salary. or altering any financial records of the parties, including 25. besiroying, disposingof,...
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2024-12-31
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16. 2024-12-31 Order Modifying and Extending Temporary Restraining Order and Order Setting Hearing for Temporary Orders signed.pdf
IT IS FURTHER ORDERED that this restraining order is effective imrnediately and shall continue in force and effect until further order of this Court or until it expires by operation of law. This order shall be binding on Respondent; on Respondent's agents, servants, and ernployees; and on those persons in active concert or participation with thern who receive actual notice of this order by personal service or otherwise. The requirement of a bond is waived. IT IS FURTHER ORDERED that the clerk shall issue notice appear, and Jason McK'emie is hereby ordere...
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2024-12-31
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16. 2024-12-31 Order Modifying and Extending Temporary Restraining Order and Order Setting Hearing for Temporary Orders signed.pdf
...real property, or intellectual property, and whether separate or community property, except as specifically authorized by order of this Court. with this suit, except as 12. Incurring any debt, other than legal expenses in connection specifically authorized by order of this Coutl. financial 13. Withdrawing money from any checking or savings account in any institution for any purpose, except as specifically authorized by order of this Court. 14. Spending any money in either party's possesbion or subject to either party's control for any purpose, except as...
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2024-12-31
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16. 2024-12-31 Order Modifying and Extending Temporary Restraining Order and Order Setting Hearing for Temporary Orders signed.pdf
...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 vehicle in the possession of a party, without that party's effective consent, including by- a, using a tracking...
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16. 2024-12-31 Order Modifying and Extending Temporary Restraining Order and Order Setting Hearing for Temporary Orders signed.pdf
ffi ln my ifY hIANDAI.ID GIVEN UNDER eaid at in Texas, of AD., PITRE, DISTRICTCI.ERK DALtAp TA06
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