DF-24-18010 Litigation Record Search

6/24/2025 4:11 PM DALLAS CO., TEXAS DF-24-18010 NO. THE MARRIAGE OF § § § EMERGENCY MOTION FOR TEMPORARY FINANCIAL RELIEF DUE TO IMMINENT HOUSING LOSS, MEDICAL HARDSHIP, AND REPEATED PATTERNS OF PROCEDURAL ABUSE AND NOTICE OF DISCOVERY SERVICE OBSTRUCTION TO THE HONORABLE JUDGE OF SAID COURT: Respondent, Jason McKemie, files this Emergency Motion requesting immediate temporary financial relief due to an imminent housing crisis and ongoing recovery from multiple medical emergencies. In support thereof, Respondent respectfully shows the Court: GROUNDS FOR...

This condition has escalated over the past 40 days and has significantly impaired Respondent's ability to prepare legal filings, attend to medical needs, and manage basic daily functions. 3. Petitioner has, once again, actively obstructed Respondent's access to medical care most notably by disabling the parties' shared HSA card, which Respondent spent over six months attempting to regain access to. This most recent filing by Petitioner appears deliberately timed to strike while Respondent is at his most medically and financially vulnerable. 4. Petitioner...

not only to further obstruct discovery, but to launch an all-out personal and legal assault through civil filings, criminal accusations, and strategic defamation. Respondent has personally spoken to four different detectives, has had his Miranda rights read on three separate occasions, and continues to defend himself from ongoing false criminal allegations on a near-weekly basis. In every instance, the underlying evidence has pointed back to Petitioner. Respondent will be submitting a recorded call with the acting detective stating quite plainly that not...

...itnesses Financial concealment and misrepresentation Violations of standing orders and post-surgical obstruction Fraudulent allegations embedded in Petitioner's June 23, 2025, amended filing Discovery Service Obstruction and Procedural Gamesmanship Respondent also notes that Petitioner is attempting to exploit procedural ambiguity to avoid valid discovery obligations. Respondent timely served formal discovery requests on May 27, 2025-well before the Rule 190.3(b) deadline of June 23, 2025-and promptly time. It was only after the 30-day discovery window c...

At the time of service, Petitioner had not formally declared herself as pro se, nor had all quietly removed without notice of substitution or withdrawal. Petitioner failed to system still reflects her as pro se. To ensure proper notice, Respondent served discovery on all known counsel, Petitioner benefitted from it. Respondent respectfully requests that the Court reject Petitioner's procedural objection and confirm that service was timely and proper. Allowing parties to obscure representation status, delay objections, and then weaponize technical deadlin...

acknowledges representation; e Consider sanctions against Sullivan & Cook, LLC under Texas Rule of Civil Procedure 215 and the Court's inherent authority to deter deliberate gamesmanship; e Make a finding of bad faith, as this conduct has materially prejudiced Respondent's right to timely discovery, procedural clarity, and access to the Court. If there has ever been a violation of Rule 8 worthy of Court intervention, this is that case. It is clear to Respondent that Petitioner has found legal counsel as ruthless and unrestrained as she is. The firm of Su...

4. Set an expedited hearing to address not only this motion for emergency relief, but to allow sufficient time for argument on the following matters in full: 1. Retroactive spousal support and legal fee reconsideration 2. Enforcement of financial disclosures and compelled discovery 3. Ongoing obstruction and compliance with Texas Rules of Civil Procedure 5. Issue sanctions against Sullivan & Cook, LLC for bad-faith litigation conduct, including concealment of counsel, procedural manipulation, and obstruction of discovery, pursuant to Texas Rule of Civil...

...Description: Motion - Miscellaneous Filing Description: EMERGENCY MOTION FOR TEMPORARY FINANCIAL RELIEF DUE TO IMMINENT HOUSING LOSS, MEDICAL HARDSHIP Status as of 6/25/2025 2:35 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Kim Jones kjones@sullivancook.com 6/24/2025 4:11:12 PM SENT Jeffrey ECook jcook@sullivancook.com 6/24/2025 4:11:12 PM SENT Tiffany Castenada tcastenada@sullivancook.com 6/24/2025 4:11:12 PM SENT William CCook wcook@sullivancook.com 6/24/2025 4:11:12 PM SENT Ethan Scroggins escroggins@sullivancook.com 6/24/2025...

6/24/2025 4:11 PM DALLAS CO., TEXAS DF-24-18010 NO. THE MARRIAGE OF § § § EMERGENCY MOTION FOR TEMPORARY FINANCIAL RELIEF DUE TO IMMINENT HOUSING LOSS, MEDICAL HARDSHIP, AND REPEATED PATTERNS OF PROCEDURAL ABUSE AND NOTICE OF DISCOVERY SERVICE OBSTRUCTION TO THE HONORABLE JUDGE OF SAID COURT: Respondent, Jason McKemie, files this Emergency Motion requesting immediate temporary financial relief due to an imminent housing crisis and ongoing recovery from multiple medical emergencies. In support thereof, Respondent respectfully shows the Court: GROUNDS FOR...

This condition has escalated over the past 40 days and has significantly impaired Respondent's ability to prepare legal filings, attend to medical needs, and manage basic daily functions. 3. Petitioner has, once again, actively obstructed Respondent's access to medical care most notably by disabling the parties' shared HSA card, which Respondent spent over six months attempting to regain access to. This most recent filing by Petitioner appears deliberately timed to strike while Respondent is at his most medically and financially vulnerable. 4. Petitioner...

not only to further obstruct discovery, but to launch an all-out personal and legal assault through civil filings, criminal accusations, and strategic defamation. Respondent has personally spoken to four different detectives, has had his Miranda rights read on three separate occasions, and continues to defend himself from ongoing false criminal allegations on a near-weekly basis. In every instance, the underlying evidence has pointed back to Petitioner. Respondent will be submitting a recorded call with the acting detective stating quite plainly that not...

...itnesses Financial concealment and misrepresentation Violations of standing orders and post-surgical obstruction Fraudulent allegations embedded in Petitioner's June 23, 2025, amended filing Discovery Service Obstruction and Procedural Gamesmanship Respondent also notes that Petitioner is attempting to exploit procedural ambiguity to avoid valid discovery obligations. Respondent timely served formal discovery requests on May 27, 2025-well before the Rule 190.3(b) deadline of June 23, 2025-and promptly time. It was only after the 30-day discovery window c...

At the time of service, Petitioner had not formally declared herself as pro se, nor had all quietly removed without notice of substitution or withdrawal. Petitioner failed to system still reflects her as pro se. To ensure proper notice, Respondent served discovery on all known counsel, Petitioner benefitted from it. Respondent respectfully requests that the Court reject Petitioner's procedural objection and confirm that service was timely and proper. Allowing parties to obscure representation status, delay objections, and then weaponize technical deadlin...

acknowledges representation; e Consider sanctions against Sullivan & Cook, LLC under Texas Rule of Civil Procedure 215 and the Court's inherent authority to deter deliberate gamesmanship; e Make a finding of bad faith, as this conduct has materially prejudiced Respondent's right to timely discovery, procedural clarity, and access to the Court. If there has ever been a violation of Rule 8 worthy of Court intervention, this is that case. It is clear to Respondent that Petitioner has found legal counsel as ruthless and unrestrained as she is. The firm of Su...

4. Set an expedited hearing to address not only this motion for emergency relief, but to allow sufficient time for argument on the following matters in full: 1. Retroactive spousal support and legal fee reconsideration 2. Enforcement of financial disclosures and compelled discovery 3. Ongoing obstruction and compliance with Texas Rules of Civil Procedure 5. Issue sanctions against Sullivan & Cook, LLC for bad-faith litigation conduct, including concealment of counsel, procedural manipulation, and obstruction of discovery, pursuant to Texas Rule of Civil...

...Description: Motion - Miscellaneous Filing Description: EMERGENCY MOTION FOR TEMPORARY FINANCIAL RELIEF DUE TO IMMINENT HOUSING LOSS, MEDICAL HARDSHIP Status as of 6/25/2025 2:35 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Kim Jones kjones@sullivancook.com 6/24/2025 4:11:12 PM SENT Jeffrey ECook jcook@sullivancook.com 6/24/2025 4:11:12 PM SENT Tiffany Castenada tcastenada@sullivancook.com 6/24/2025 4:11:12 PM SENT William CCook wcook@sullivancook.com 6/24/2025 4:11:12 PM SENT Ethan Scroggins escroggins@sullivancook.com 6/24/2025...