DF-24-18010 Litigation Record Search

4/14/2025 10:59 AM DALLAS CO., TEXAS DF-24-1 801 0 N0. IN THE MATTER OF § IN THE DISTRICT COURT THE MARRIAGE 0F § § GWENDOLYN ULIIAsz-MCKEMIE § 254th1UDIc1AL DISTRICT AND § THE HON. IUDGE BROWN, PRESIDING MOTION T0 STRIKE IMPROPER EXPERT DESIGNATIONS AND T0 LIMIT TESTIMONY OF OPPOSING COUNSEL TO THE HONORABLE IUDGE BROWN: COMES NOW, Jason McKemie, Respondent and pro se party to this action, and respectfully moves this Court to strike the designations of Ieff Cook, William Cook, and Ethan Scroggins—attorneys for Petitioner—as testifying expert witnesses a...

Petitioner's designations omit critical disclosures that are expressly required under Texas Rules of Civil Procedure 194.2(0 and 192.3(g), including curriculum vitae (CVs), prior testimony history, expert reports, and substantive summaries of the basis for their opinions. These omissions are not merely technical—they are procedural violations that deprive Respondent of the opportunity to assess the qualifications and credibility of the purported experts. B. Deficient and Conclusory Designations The disclosures submitted consist solely of generic, boilerpl...

Petitioner's counsel cannot simultaneously serve as both advocates and expert witnesses without compromising the fairness of these proceedings. The disclosures offer no independent analysis, no supporting documentation, and no foundation typically required for expert testimony—only self-validating opinions about their own work. This is not expert testimony as contemplated by the Rules; it is a procedural artifice designed to insulate their own conduct from scrutiny. o Texas courts have recognized that “[a]n attorney serving simultaneously as advocate and...

...f the foregoing document has been served upon all counsel of record via electronic service in accordance with the Texas Rules of Civil Procedure on this 14th Day ofApril 2025. Jason McKemie Pro Se Respondent Page 4 of 4 Copy from re:SearchTX

...D: 99620809 - Filing Code Description: Motion Miscellaneous Filing Description: IMPROPER EXPERT DESIGNATIONS AND TO LIMIT TESTIMONY OF OPPOSING COUNSEL Status as of 4/14/2025 3:41 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Kim Jones kjones@sullivancook.com 4/14/2025 10:59:09 AM SENT Jeffrey ECook jcook@sullivancook.com 4/14/2025 10:59:09 AM SENT Tiffany Castenada tcastenada@sullivancook.com 4/14/2025 10:59:09 AM SENT William CCook wcook@su|livancook.com 4/14/2025 10:59:09 AM SENT Ethan Scroggins escroggins@sullivancook.com 4/14/2...