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2025-06-23
Filer unknown
Notice Of Appearance
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NOTICE OF APPEARANCE_C1C47035.pdf
6/23/2025 11:08 PM DALLAS CO., TEXAS THE MARRIAGE OF § § AND § NOTICE OF APPEARANCE TO THE HONORABLE COURT: NOW COMES, Ethan Scroggins of the law firm of Sullivan & Cook, LLC, and respectfully submits this Notice of Appearance as follows: I Ethan Scroggins of the law firm of Sullivan & Cook, LLC, hereby makes his appearance in this case as lead counsel and attorney in charge for Gwendolyn Ulijasz-McKemie. Respectfully submitted, SULLIVAN & COOK, LLC /s/ Ethan Scroggins Jeff Cook State Bar No.: 04734495 jcook@sullivancook.com William Cook State Bar No.: 2...
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2025-06-23
Filer unknown
Notice Of Appearance
Page 2
CERTIFICATE_OF_SERVICE
NOTICE OF APPEARANCE_C1C47035.pdf
Telephone: (214) 520-7494 Facsimile: (214) 528-6925 ATTORNEYS FOR PETITIONER, GWENDOLYN ULIJASZ-McKEMIE This is to certify that on this 23rd day of June, 2025, a true and correct copy of the foregoing record. /s/ Ethan Scroggins Ethan Scroggins 2 of 2 Notice of Appearance Page Copy from re:SearchTX
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2025-06-23
Filer unknown
Notice Of Appearance
Page 3
FILING_STAMP_OR_ESERVICE
NOTICE OF APPEARANCE_C1C47035.pdf
...the date and to the persons listed below. The rules governing Envelope ID: 102331361 Filing Code Description: Notice Of Appearance Filing Description: Status as of 6/25/2025 9:59 AM CST Associated Case Party: GWENDOLYN ULIJASZ MCKEMIE Name BarNumber Email TimestampSubmitted Status Kim Jones kjones@sullivancook.com 6/23/2025 11:08:41 PM SENT Jeffrey ECook jcook@sullivancook.com 6/23/2025 11:08:41 PM SENT Tiffany Castenada tcastenada@sullivancook.com 6/23/2025 11:08:41 PM SENT William CCook wcook@sullivancook.com 6/23/2025 11:08:41 PM SENT Ethan Scroggins...
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2025-06-23
Respondent / Jason
Notice Of Appearance
Page 1
PLEADING_START_FILE_MARKED
FIRST AMENDED PETITION FOR DIVORCE_D3FD3678.pdf
6/23/2025 11:08 PM DALLAS CO., TEXAS NOTICE: THIS DOCUMENT THE MARRIAGE OF § § AND § FIRST AMENDED PETITION 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 ofEvidence: Respondent 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 Respondent's possession or subject to Respondent's control and electronic documents, files, or oth...
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2025-06-23
Respondent / Jason
Notice Of Appearance
Page 2
PLEADING_BODY
FIRST AMENDED PETITION FOR DIVORCE_D3FD3678.pdf
Respondent has been a domiciliary of Texas for the preceding six-month period and a resident of this county for the preceding ninety-day period. J. Service Process should be served on Respondent at 539 Commerce Street, PMC 2010, Dallas, Texas 75208. 6. Protective Order Statement No protective order under title 4 of the Texas Family Code, protective order under subchapter A of chapter 7B of the Texas Code of Criminal Procedure, or order for emergency protection under article 17.292 of the Texas Code of Criminal Procedure is in effect in regard to a party...
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2025-06-23
Respondent / Jason
Notice Of Appearance
Page 3
PLEADING_BODY
FIRST AMENDED PETITION FOR DIVORCE_D3FD3678.pdf
12. Separate Property Petitioner owns certain separate property that is not part of the community estate of the parties, and Petitioner requests the Court to confirm that separate property as Petitioner's separate property and estate. 13. Reimbursement Petitioner requests the Court to reimburse Petitioner's separate estate for property used by Petitioner's separate estate to confer a benefit on the community estate that, if not repaid or reimbursed, would result in unjust enrichment to the community estate. The property of Petitioner's separate estate wa...
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2025-06-23
Respondent / Jason
Notice Of Appearance
Page 4
PLEADING_BODY
FIRST AMENDED PETITION FOR DIVORCE_D3FD3678.pdf
...Ulijasz-McKemie for her actual damages, mental anguish and suffering, punitive damages and costs. 18. Texas Wiretapping Statute Texas Civil Practice and Remedies Code § 123.002 provides a cause of action against a person who intercepts, attempts to intercept or employs another to intercept or attempt to intercept a communication. Jason McKemie violated that statute by putting tracking devices in every aspect of Gwendolyn Ulijasz-McKemie's life and by installing software on Gwendolyn Ulijasz-McKemie's devices meant to copy and intercept communications and...
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2025-06-23
Respondent / Jason
Notice Of Appearance
Page 5
PLEADING_BODY
FIRST AMENDED PETITION FOR DIVORCE_D3FD3678.pdf
...and be ordered paid directly to Petitioner's attorney, who may enforce the order in the attorney's own name. Petitioner requests postjudgment interest as allowed by law. 23. Prayer Petitioner 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. Petitioner prays that Petitioner's name be changed as requested above. Petitioner prays for attorney's fees, expenses, costs, and interest as requested above. Petitioner prays for general relief and all other relief to which she...
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2025-06-23
Respondent / Jason
Notice Of Appearance
Page 6
CERTIFICATE_OF_SERVICE
FIRST AMENDED PETITION FOR DIVORCE_D3FD3678.pdf
This is to certify that on this 23rd day of June, 2025, a true and correct copy of the foregoing record. /s/ Ethan Scroggins Ethan Scroggins First Amended Petition for Divorce Page 6 of 6 Copy from re:SearchTX
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2025-06-23
Respondent / Jason
Notice Of Appearance
Page 7
FILING_STAMP_OR_ESERVICE
FIRST AMENDED PETITION FOR DIVORCE_D3FD3678.pdf
...the date and to the persons listed below. The rules governing Envelope ID: 102331361 Filing Code Description: Notice Of Appearance Filing Description: Status as of 6/25/2025 9:59 AM CST Associated Case Party: GWENDOLYN ULIJASZ MCKEMIE Name BarNumber Email TimestampSubmitted Status Jeffrey ECook jcook@sullivancook.com 6/23/2025 11:08:41 PM SENT Tiffany Castenada tcastenada@sullivancook.com 6/23/2025 11:08:41 PM SENT William CCook wcook@sullivancook.com 6/23/2025 11:08:41 PM SENT Ethan Scroggins escroggins@sullivancook.com 6/23/2025 11:08:41 PM SENT Chand...
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2025-06-23
Respondent / Jason
Response
Page 1
PLEADING_START
2025-06-23 els Response to Request for Production.pdf
THE MARRIAGE OF § § AND § PETITIONER’S RESPONSE TO RESPONDENT’S REQUESTS FOR PRODUCTION TO: Respondent Jason McKemie, pro se, via e-service. COMES NOW Gwendolyn Ulijasz-McKemie, Petitioner in the above-entitled and numbered cause, and serves her Response to Respondent’s Requests for Production. Respectfully submitted, SULLIVAN & COOK, LLC ____/s/ Ethan Scroggins_________ Jeff Cook State Bar No.: 04734495 jcook@sullivancook.com William Cook State Bar No.: 24125182 wcook@sullivancook.com Ethan Scroggins State Bar No. 24137185 escroggins@sullivancook.com 60...
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2025-06-23
Respondent / Jason
Response
Page 2
CERTIFICATE_OF_SERVICE
2025-06-23 els Response to Request for Production.pdf
This is to certify that on this 23rd day of June, 2025, a true and correct copy of the foregoing record. /s/ Ethan Scroggins Ethan Scroggins PETITIONER’S RESPONSE TO RESPONDENT’S REQUESTS FOR PRODUCTION – PAGE 2
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2025-06-23
Respondent / Jason
Response
Page 3
PLEADING_BODY
2025-06-23 els Response to Request for Production.pdf
...r objects to the entirety of Respondent’s Requests for Production (incorrectly titled “Petitioner’s First Requests for Production”) because it was not timely. on May 27, 2025, which is outside the applicable discovery period for this case. The Pretrial Scheduling Order in this case states that discovery deadlines will be pursuant to the Texas Rules of Civil Procedure. Texas Rule of Civil Procedure 190.3(b) states that “In a suit governed by the Family Code, all discovery must be conducted during the discovery period, which begins when May 23, 2025, to se...
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2025-06-23
Respondent / Jason
Response
Page 4
EXHIBIT_START
2025-06-23 els Response to Request for Production.pdf
OBJECTION: Petitioner objects on the ground that the burden or expense of the proposed discovery outweighs its likely benefit, taking into account the needs of the case, the amount in controversy, the parties' resources, the importance of the issues at stake in the litigation, and the importance of the proposed discovery in resolving the issues. TEX. R. Civ. P. 192.4(b). ANSWER: Subject to and without waiving the foregoing objections, see Exhibit A. 3. All documentation relating to stock option grants, restricted stock units (RSUs), or VEIP/bonus equity...
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2025-06-23
Respondent / Jason
Response
Page 5
EXHIBIT_START
2025-06-23 els Response to Request for Production.pdf
“fishing expedition” in contravention of the Texas Rules of Civil Procedure. Tex. R. Civ. P/ 192.4; Bryan v. General Electric Credit Corp., 553 S.W.2d 415, (Tex. Civ. App. – Houston [1st Dist.] 1977, no writ); Loftin v. Martin, 776 S.W.2d 145 (Tex. 1989). OBJECTION: Petitioner objects on the ground that the burden or expense of the proposed discovery outweighs its likely benefit, taking into account the needs of the case, the amount in controversy, the parties' resources, the importance of the issues at stake in the litigation, and the importance of the...
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2025-06-23
Respondent / Jason
Response
Page 6
EXHIBIT_CONTINUATION
2025-06-23 els Response to Request for Production.pdf
OBJECTION: Petitioner objects to this request on the ground that it is overly broad, unduly burdensome, insufficiently limited in time and scope, and continues as impermissible “fishing expedition” in contravention of the Texas Rules of Civil Procedure. Tex. R. Civ. P/ 192.4; Bryan v. General Electric Credit Corp., 553 S.W.2d 415, (Tex. Civ. App. – Houston [1st Dist.] 1977, no writ); Loftin v. Martin, 776 S.W.2d 145 (Tex. 1989). OBJECTION: Petitioner objects to this interrogatory on the ground that it seeks information that is not relevant, admissible, o...
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2025-06-23
Respondent / Jason
Response
Page 7
EXHIBIT_START
2025-06-23 els Response to Request for Production.pdf
OBJECTION: Petitioner objects on the ground that the burden or expense of the proposed discovery outweighs its likely benefit, taking into account the needs of the case, the amount in controversy, the parties' resources, the importance of the issues at stake in the litigation, and the importance of the proposed discovery in resolving the issues. TEX. R. Civ. P. 192.4(b). ANSWER: Subject to and without waiving the foregoing objections, see Exhibit A. 11. All communications or notes discussing Jason McKemie, including journal entries or messages shared wit...
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2025-06-23
Respondent / Jason
Response
Page 8
EXHIBIT_CONTINUATION
2025-06-23 els Response to Request for Production.pdf
OBJECTION: Petitioner objects to this request on the ground that it is overly broad, unduly burdensome, insufficiently limited in time and scope, and continues as impermissible “fishing expedition” in contravention of the Texas Rules of Civil Procedure. Tex. R. Civ. P/ 192.4; Bryan v. General Electric Credit Corp., 553 S.W.2d 415, (Tex. Civ. App. – Houston [1st Dist.] 1977, no writ); Loftin v. Martin, 776 S.W.2d 145 (Tex. 1989). OBJECTION: Petitioner objects on the ground that the burden or expense of the proposed discovery outweighs its likely benefit,...
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2025-06-23
Respondent / Jason
Response
Page 1
PLEADING_START
2025-06-23 els Response to Request for Disclosure.pdf
THE MARRIAGE OF § § AND § PETITIONER’S RESPONSE TO RESPONDENT’S REQUESTS FOR DISCLOSURE TO: Respondent Jason McKemie, pro se, via e-service. COMES NOW Gwendolyn Ulijasz-McKemie, Petitioner in the above-entitled and numbered cause, and serves her Response to Respondent’s Requests for Disclosure. Respectfully submitted, SULLIVAN & COOK, LLC ____/s/ Ethan Scroggins_________ Jeff Cook State Bar No.: 04734495 jcook@sullivancook.com William Cook State Bar No.: 24125182 wcook@sullivancook.com Ethan Scroggins State Bar No. 24137185 escroggins@sullivancook.com 60...
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2025-06-23
Respondent / Jason
Response
Page 2
CERTIFICATE_OF_SERVICE
2025-06-23 els Response to Request for Disclosure.pdf
This is to certify that on this 23rd day of June, 2025, a true and correct copy of the foregoing record. /s/ Ethan Scroggins Ethan Scroggins PETITIONER’S RESPONSE TO RESPONDENT’S REQUESTS FOR DISCLOSURE – PAGE 2
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2025-06-23
Respondent / Jason
Response
Page 3
PLEADING_BODY
2025-06-23 els Response to Request for Disclosure.pdf
REQUESTS FOR DISCLOSURE 1. State the correct names of the parties to the lawsuit. RESPONSE: Gwendolyn Ulijasz-McKemie, Petitioner Jason McKemie, Respondent 2. State the name, address, and telephone number of any potential parties. RESPONSE: None known at this time. 3. State the legal theories and, in general, the factual bases for the claims or defenses of Petitioner. RESPONSE: The legal theories and factual bases of Petitioner’s claims are as contained in Gwendolyn as well as any amended or supplemental pleadings and motions Gwendolyn Ulijasz- McKemie m...
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2025-06-23
Respondent / Jason
Response
Page 4
PLEADING_BODY
2025-06-23 els Response to Request for Disclosure.pdf
...cKemie is liable to Gwendolyn Ulijasz-McKemie for her actual damages, mental anguish and suffering, punitive damages and costs. Texas Civil Practice and Remedies Code § 123.002 provides a cause of action against a person who intercepts, attempts to intercept or employs another to intercept or attempt to intercept a communication. Jason McKemie violated that statute by putting tracking devices in every aspect of Gwendolyn Ulijasz-McKemie’s life and by installing software on Gwendolyn PETITIONER’S RESPONSE TO RESPONDENT’S REQUESTS FOR DISCLOSURE – PAGE 4
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2025-06-23
Respondent / Jason
Response
Page 5
PLEADING_BODY
2025-06-23 els Response to Request for Disclosure.pdf
Ulijasz-McKemie’s devices meant to copy and intercept communications and actions. Jason McKemie is liable to Gwendolyn Ulijasz-McKemie for statutory damages under $123.004 in the amount of $10,000 for each occurrence, actual damages, punitive damages, and reasonable attorney’s fees and costs. By putting tracking devices in every aspect of Gwendolyn Ulijasz-McKemie’s life and intentionally obstructing and eliminating access to financial accounts and various other personal matters, and through the routine hacking and unauthorized access to Gwendolyn Ulijas...
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2025-06-23
Respondent / Jason
Response
Page 6
PLEADING_BODY
2025-06-23 els Response to Request for Disclosure.pdf
Ethan Scroggins William Cook Sullivan & Cook, LLC 600 E. Las Colinas Blvd. Ste. 1300 Irving, Texas 75039 Tel: (214) 520-7494 Counsel for Petitioner Jason McKemie Respondent Edward M. Gardner CPA 2519 South Boulevard Suite 100, Houston, Texas 77098 Telephone: (713) 942-1040 Petitioner’s CPA 6. Produce a copy or description of all documents, electronically stored information, and tangible things that Petitioner has in her possession, custody, or control and may use to support her claims or defenses. RESPONSE: See the documents produced in response to Respo...
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2025-06-23
Respondent / Jason
Response
Page 1
PLEADING_START
2025-06-23 els Response to Interrogatories.pdf
THE MARRIAGE OF § § AND § PETITIONER’S RESPONSE TO RESPONDENT’S WRITTEN INTERROGATORIES TO: Respondent Jason McKemie, pro se, via e-service. COMES NOW Gwendolyn Ulijasz-McKemie, Petitioner in the above-entitled and numbered cause, and serves her Response to Respondent’s Written Interrogatories. Respectfully submitted, SULLIVAN & COOK, LLC ____/s/ Ethan Scroggins_________ Jeff Cook State Bar No.: 04734495 jcook@sullivancook.com William Cook State Bar No.: 24125182 wcook@sullivancook.com Ethan Scroggins State Bar No. 24137185 escroggins@sullivancook.com 60...
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2025-06-23
Respondent / Jason
Response
Page 2
CERTIFICATE_OF_SERVICE
2025-06-23 els Response to Interrogatories.pdf
This is to certify that on this 23rd day of June, 2025, a true and correct copy of the foregoing record. /s/ Ethan Scroggins Ethan Scroggins PETITIONER’S RESPONSE TO RESPONDENT’S WRITTEN INTERROGATORIES – PAGE 2
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2025-06-23
Respondent / Jason
Response
Page 3
PLEADING_BODY
2025-06-23 els Response to Interrogatories.pdf
...jects to the entirety of Respondent’s Request for Interrogatories (incorrectly titled “Petitioner’s First Set of Interrogatories”) because it was not service) on May 27, 2025, which is outside the applicable discovery period for this case. The Pretrial Scheduling Order in this case states that discovery deadlines will be pursuant to the Texas Rules of Civil Procedure. Texas Rule of Civil Procedure 190.3(b) states that “In a suit governed by the Family Code, all discovery must be conducted during the discovery period, Respondent had until May 23, 2025, to...
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2025-06-23
Respondent / Jason
Response
Page 4
PLEADING_BODY
2025-06-23 els Response to Interrogatories.pdf
and belief, there have been no other transfers, payments, or conveyances of any form of value exceeding $999 between August 15, 2023, and the date of your response not disclosed herein or in prior financial discovery. This includes any transaction: • Conducted on your behalf or for your benefit by another person or entity • Paid in part or whole with marital funds, business funds, or funds reimbursed later • Processed through any alternate name, email, account, crypto wallet, business, or third Party Your response must: • List each transaction individual...
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2025-06-23
Respondent / Jason
Response
Page 5
PLEADING_BODY
2025-06-23 els Response to Interrogatories.pdf
unduly burdensome, insufficiently limited in time and scope, and continues as impermissible “fishing expedition” in contravention of the Texas Rules of Civil Procedure. Tex. R. Civ. P/ 192.4; Bryan v. General Electric Credit Corp., 553 S.W.2d 415, (Tex. Civ. App. – Houston [1st Dist.] 1977, no writ); Loftin v. Martin, 776 S.W.2d 145 (Tex. 1989). OBJECTION: Petitioner objects on the ground that the burden or expense of the proposed discovery outweighs its likely benefit, taking into account the needs of the case, the amount in controversy, the parties' re...
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2025-06-23
Respondent / Jason
Response
Page 6
PLEADING_BODY
2025-06-23 els Response to Interrogatories.pdf
OBJECTION: Petitioner objects to this request on the ground that it is overly broad, unduly burdensome, insufficiently limited in time and scope, and continues as impermissible “fishing expedition” in contravention of the Texas Rules of Civil Procedure. Tex. R. Civ. P/ 192.4; Bryan v. General Electric Credit Corp., 553 S.W.2d 415, (Tex. Civ. App. – Houston [1st Dist.] 1977, no writ); Loftin v. Martin, 776 S.W.2d 145 (Tex. 1989). OBJECTION: Petitioner objects on the ground that the burden or expense of the proposed discovery outweighs its likely benefit,...
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2025-06-23
Respondent / Jason
Response
Page 7
PLEADING_BODY
2025-06-23 els Response to Interrogatories.pdf
OBJECTION: Petitioner objects to this interrogatory on the ground that it seeks information that is not relevant, admissible, or reasonably calculated to lead to the discovery of admissible evidence, and, is therefore, outside the scope of permissible discovery as provided by the Texas Rules of Civil Procedure. Tex. R. Civ. P. 192.3(a) and cmt. 1; Tex. R. Civ. Evid. 401,402. OBJECTION: Petitioner objects to this request on the ground that it is overly broad, unduly burdensome, insufficiently limited in time and scope, and continues as impermissible “fish...
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2025-06-23
Respondent / Jason
Response
Page 8
PLEADING_BODY
2025-06-23 els Response to Interrogatories.pdf
...egoing objections, I faced attorney was Lindsey Grunert at Kotchen & Low LLP. The settlement was based on conduct from prior to the marriage. I received the funds in May 2025. See the settlement agreement produced in Exhibit A. Lindsey took a portion of the money as a contingency fee. INTERROGATORY NO. 6: Life Insurance and Related Policies Identify and fully describe any and all life insurance policies, accidental death and dismemberment (AD&D) policies, disability insurance policies, or similar instruments for which you have ever been the beneficiary,...
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2025-06-23
Respondent / Jason
Response
Page 9
PLEADING_BODY
2025-06-23 els Response to Interrogatories.pdf
...for unlawful installation of tracking devices. I also spoke with Detective Scott at 210-207- 7680 • Case No. SAPD25002158 – Contacted Officer Villegas #83 on January 4, 2025 for harassment • Case No. SAPD25009850 – Contacted Officer Fowler #1408 on January 15, 2025 for harassment There are likely additional reports made but I do not currently have the reports or any information regarding the reports. They also were with the San Antonio Police Department. I have not followed up on the reports, but I believe they were investigated. I was called in to iden...
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2025-06-23
Respondent / Jason
Response
Page 10
PLEADING_BODY
2025-06-23 els Response to Interrogatories.pdf
...ER: Subject to and without waiving the foregoing objections, Officer Vick #1762 on December 12, 2024, Detective Scott at 210-207-7680, Officer Villegas #83 on January 4, 2025, Officer Fowler #1408 on January 15, 2025 all at San Antonio Police Department. INTERROGATORY #9: Security Services, Surveillance, Bug Detection, & Security Sweep Services PETITIONER’S RESPONSE TO RESPONDENT’S WRITTEN INTERROGATORIES – PAGE 10
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2025-06-23
Respondent / Jason
Response
Page 11
PLEADING_BODY
2025-06-23 els Response to Interrogatories.pdf
...ices described by the request. INTERROGATORY #10: Travel For all travel or trips where you stayed overnight somewhere other than 12802 Kings Forest St, San Antonio, TX 78230 between October 1, 2024, and the present, identify and itemize all related expenses, including: • Airfare • Lodging or accommodations • Meals and restaurants • Entertainment (e.g., concerts, theater, events) • Personal services (e.g., massage, spa) • Coffee shops, cafes, and other travel-related purchases PETITIONER’S RESPONSE TO RESPONDENT’S WRITTEN INTERROGATORIES – PAGE 11
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2025-06-23
Respondent / Jason
Response
Page 12
PLEADING_BODY
2025-06-23 els Response to Interrogatories.pdf
...very in resolving the issues. TEX. R. Civ. P. 192.4(b). Interrogatory No. 11: Local Rentals, Hotel Stays, and Private Accommodations Identify each occasion between May 2023, and the present in which you rented, stayed at, or were hosted at any hotel, short-term rental, or private accommodation within the Dallas-Fort Worth metropolitan area, including but not limited to properties arranged through Airbnb, VRBO, hotel chains, or private individuals. For each occasion, provide the following: • The exact date(s) and address or location of the stay • The plat...
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2025-06-23
Respondent / Jason
Response
Page 13
PLEADING_BODY
2025-06-23 els Response to Interrogatories.pdf
OBJECTION: Petitioner objects to this interrogatory on the ground that it seeks information that is not relevant, admissible, or reasonably calculated to lead to the discovery of admissible evidence, and, is therefore, outside the scope of permissible discovery as provided by the Texas Rules of Civil Procedure. Tex. R. Civ. P. 192.3(a) and cmt. 1; Tex. R. Civ. Evid. 401,402. OBJECTION: Petitioner objects to this request on the ground that it is overly broad, unduly burdensome, insufficiently limited in time and scope, and continues as impermissible “fish...
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2025-06-23
Respondent / Jason
Response
Page 14
PLEADING_BODY
2025-06-23 els Response to Interrogatories.pdf
...sues. TEX. R. Civ. P. 192.4(b). ANSWER: Subject to and without waiving the foregoing objections, I obtained a protective order against Christopher McNally on March 10, 2023 in Cook County, Illinois. Law enforcement was involved. There was also a petition to modify the protective order to further prevent danger posed by Christopher McNally, including having him surrender his firearms. Identify and fully describe each and every formal or informal report, complaint, or communication you have made to any law enforcement agency, emergency services agency, gov...
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2025-06-23
Respondent / Jason
Response
Page 15
PLEADING_BODY
2025-06-23 els Response to Interrogatories.pdf
OBJECTION: Petitioner objects to this request on the ground that it is overly broad, unduly burdensome, insufficiently limited in time and scope, and continues as impermissible “fishing expedition” in contravention of the Texas Rules of Civil Procedure. Tex. R. Civ. P/ 192.4; Bryan v. General Electric Credit Corp., 553 S.W.2d 415, (Tex. Civ. App. – Houston [1st Dist.] 1977, no writ); Loftin v. Martin, 776 S.W.2d 145 (Tex. 1989). OBJECTION: Petitioner objects on the ground that the burden or expense of the proposed discovery outweighs its likely benefit,...
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2025-06-23
Respondent / Jason
Filing
Page 1
PLEADING_START
2025-06-23 els Pretrial Disclosures.pdf
THE MARRIAGE OF § § AND § PETITIONER’S PRETRIAL DISCLOSURES TO: Respondent Jason McKemie, pro se, via e-service. COMES NOW Gwendolyn Ulijasz-McKemie, Petitioner in the above-entitled and numbered cause, and files and serves her Pretrial Disclosures. Respectfully submitted, SULLIVAN & COOK, LLC ____/s/ Ethan Scroggins_________ Jeff Cook State Bar No.: 04734495 jcook@sullivancook.com William Cook State Bar No.: 24125182 wcook@sullivancook.com Ethan Scroggins State Bar No. 24137185 escroggins@sullivancook.com 600 E. Las Colinas Blvd., Suite 1300 Irving, Tex...
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2025-06-23
Respondent / Jason
Filing
Page 2
CERTIFICATE_OF_SERVICE
2025-06-23 els Pretrial Disclosures.pdf
This is to certify that on this 23rd day of June, 2025, a true and correct copy of the foregoing record. /s/ Ethan Scroggins Ethan Scroggins PETITIONER’S PRETRIAL DISCLOSURES – PAGE 2
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2025-06-23
Respondent / Jason
Filing
Page 3
PLEADING_BODY
2025-06-23 els Pretrial Disclosures.pdf
Required Pretrial Disclosures 1. The name and, if not previously provided, the address and telephone number of each witness Petitioner expects to present at trial. RESPONSE: Gwendolyn Ulijasz-McKemie c/o Ethan Scroggins Sullivan & Cook, LLC 600 E. Las Colinas Blvd. Ste. 1300 Irving, Texas 75039 Tel: (214) 520-7494 Petitioner Ethan Scroggins William Cook Sullivan & Cook, LLC 600 E. Las Colinas Blvd. Ste. 1300 Irving, Texas 75039 Tel: (214) 520-7494 Counsel for Petitioner Jason McKemie Respondent Edward M. Gardner CPA 2519 South Boulevard Suite 100, Housto...
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2025-06-23
Respondent / Jason
Filing
Page 4
PLEADING_BODY
2025-06-23 els Pretrial Disclosures.pdf
produced; Sullivan & Cook, LLC Redacted Billing; Any exhibits offered by Respondent; Any communications between the parties; and Any communications between the parties’ attorneys. 4. Each document or other exhibit, including summaries of other evidence, Petitioner may offer at trial if the need arises. RESPONSE: Any and all documents produced by Petitioner and Respondent in discovery or disclosures. PETITIONER’S PRETRIAL DISCLOSURES – PAGE 4
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2025-06-23
Filer unknown
Notice
Page 1
PLEADING_START
2025-06-23 els Notice of Appearance.pdf
THE MARRIAGE OF § § AND § NOTICE OF APPEARANCE TO THE HONORABLE COURT: NOW COMES, Ethan Scroggins of the law firm of Sullivan & Cook, LLC, and respectfully submits this Notice of Appearance as follows: I. Ethan Scroggins of the law firm of Sullivan & Cook, LLC, hereby makes his appearance in this case as lead counsel and attorney in charge for Gwendolyn Ulijasz-McKemie. Respectfully submitted, SULLIVAN & COOK, LLC ____/s/ Ethan Scroggins_________ Jeff Cook State Bar No.: 04734495 jcook@sullivancook.com William Cook State Bar No.: 24125182 wcook@sullivanc...
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2025-06-23
Filer unknown
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CERTIFICATE_OF_SERVICE
2025-06-23 els Notice of Appearance.pdf
Telephone: (214) 520-7494 Facsimile: (214) 528-6925 ATTORNEYS FOR PETITIONER, GWENDOLYN ULIJASZ-MCKEMIE This is to certify that on this 23rd day of June, 2025, a true and correct copy of the foregoing record. /s/ Ethan Scroggins Ethan Scroggins Notice of Appearance Page 2 of 2
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2025-06-23
Respondent / Jason
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PLEADING_START
2025-06-23 els First Amended Petition for Divorce.pdf
NOTICE: THIS DOCUMENT THE MARRIAGE OF § § AND § FIRST AMENDED PETITION 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: Respondent 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 Respondent’s possession or subject to Respondent’s control and electronic documents, files, or other data generated by or stored on Re...
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2025-06-23
Respondent / Jason
Notice
Page 2
PLEADING_BODY
2025-06-23 els First Amended Petition for Divorce.pdf
Respondent has been a domiciliary of Texas for the preceding six-month period and a resident of this county for the preceding ninety-day period. 5. Service Process should be served on Respondent at 539 Commerce Street, PMC 2010, Dallas, Texas 75208. 6. Protective Order Statement No protective order under title 4 of the Texas Family Code, protective order under subchapter A of chapter 7B of the Texas Code of Criminal Procedure, or order for emergency protection under article 17.292 of the Texas Code of Criminal Procedure is in effect in regard to a party...
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2025-06-23
Respondent / Jason
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Page 3
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2025-06-23 els First Amended Petition for Divorce.pdf
12. Separate Property Petitioner owns certain separate property that is not part of the community estate of the parties, and Petitioner requests the Court to confirm that separate property as Petitioner’s separate property and estate. 13. Reimbursement Petitioner requests the Court to reimburse Petitioner’s separate estate for property used by Petitioner’s separate estate to confer a benefit on the community estate that, if not repaid or reimbursed, would result in unjust enrichment to the community estate. The property of Petitioner’s separate estate wa...
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2025-06-23
Respondent / Jason
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Page 4
PLEADING_BODY
2025-06-23 els First Amended Petition for Divorce.pdf
...Ulijasz-McKemie for her actual damages, mental anguish and suffering, punitive damages and costs. 18. Texas Wiretapping Statute Texas Civil Practice and Remedies Code § 123.002 provides a cause of action against a person who intercepts, attempts to intercept or employs another to intercept or attempt to intercept a communication. Jason McKemie violated that statute by putting tracking devices in every aspect of Gwendolyn Ulijasz-McKemie’s life and by installing software on Gwendolyn Ulijasz-McKemie’s devices meant to copy and intercept communications and...
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2025-06-23
Respondent / Jason
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Page 5
PLEADING_BODY
2025-06-23 els First Amended Petition for Divorce.pdf
...and be ordered paid directly to Petitioner’s attorney, who may enforce the order in the attorney’s own name. Petitioner requests postjudgment interest as allowed by law. 23. Prayer Petitioner 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. Petitioner prays that Petitioner’s name be changed as requested above. Petitioner prays for attorney’s fees, expenses, costs, and interest as requested above. Petitioner prays for general relief and all other relief to which she...
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2025-06-23
Respondent / Jason
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Page 6
CERTIFICATE_OF_SERVICE
2025-06-23 els First Amended Petition for Divorce.pdf
This is to certify that on this 23rd day of June, 2025, a true and correct copy of the foregoing record. /s/ Ethan Scroggins Ethan Scroggins First Amended Petition for Divorce Page 6 of 6
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