#068
2025-06-27
Respondent / Jason
Objections - Misc
Page 1
PLEADING_START_FILE_MARKED
NOTICE OF OBJECTION TO PROCEDURAL REENTRY AND MOTION FILING BY RESPONDENT'S COUNSEL_3E973D6B.pdf
6/27/2025 12:32 PM DALLAS CO., TEXAS DF-24-18010 NO. IN THE MATTER OF § IN THE DISTRICT COURT THE MARRIAGE OF § § & § NOTICE OF OBJECTION TO PROCEDURAL REENTRY AND MOTION FILING BY RESPONDENT'S COUNSEL TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Jason McKemie, Petitioner, and respectfully files this Notice of Objection to Respondent's procedural reentry and contemporaneous filing of substantive motions. In support thereof, Petitioner would show the Court as follows: | . BACKGROUND 1. Respondent's prior counsel withdrew from this matter by court orde...
#068
2025-06-27
Respondent / Jason
Objections - Misc
Page 2
PLEADING_BODY
NOTICE OF OBJECTION TO PROCEDURAL REENTRY AND MOTION FILING BY RESPONDENT'S COUNSEL_3E973D6B.pdf
...er respectfully requests that the Court: e Strike or stay any substantive filings submitted contemporaneously with Respondent's Notice of Appearance on or about June 23, 2025; e Require Respondent's counsel to obtain formal judicial acknowledgment of reentry before any additional motions are considered; e And grant such other relief as justice and equity may require. IV. NOTICE OF SUPPLEMENTAL FILING 1. Petitioner also respectfully informs the Court that an evidentiary supplement will be is forthcoming in support of Petitioner's prior Emergency Motion fo...
#068
2025-06-27
Respondent / Jason
Objections - Misc
Page 3
PLEADING_BODY
NOTICE OF OBJECTION TO PROCEDURAL REENTRY AND MOTION FILING BY RESPONDENT'S COUNSEL_3E973D6B.pdf
further grounds for immediate intervention. 2. Petitioner intends to submit additional filings in the coming days, including further evidence related to: - Perjury by Respondent and third-party witnesses; - Financial misrepresentation and concealment; - And violations of standing orders and procedural norms. 3. These materials are being submitted in good faith to ensure the Court has access to a full and accurate record prior to any substantive ruling. Respecttfully submitted, Jason McKemie Pro Se Petitioner 5607 La Foy Blvd Dallas, TX 75209 (214) 868-49...
#068
2025-06-27
Respondent / Jason
Objections - Misc
Page 4
FILING_STAMP_OR_ESERVICE
NOTICE OF OBJECTION TO PROCEDURAL REENTRY AND MOTION FILING BY RESPONDENT'S COUNSEL_3E973D6B.pdf
...5854 Filing Code Description: Objections - Misc Filing Description: NOTICE OF OBJECTION TO PROCEDURAL REENTRY AND MOTION FILING BY RESPONDENT'S COUNSEL Status as of 6/30/2025 9:54 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Kim Jones kjones@sullivancook.com 6/27/2025 12:32:45 PM SENT Jeffrey ECook jcook@sullivancook.com 6/27/2025 12:32:45 PM SENT Tiffany Castenada tcastenada@sullivancook.com 6/27/2025 12:32:45 PM SENT William CCook wcook@sullivancook.com 6/27/2025 12:32:45 PM SENT Ethan Scroggins escroggins@sullivancook.com 6/27/2...
#067
2025-06-27
Respondent / Jason
Motion - Miscellaneous
Page 1
PLEADING_START_FILE_MARKED
MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPELL DISCOVERY RESPONSES_A3036D4D.pdf
6/27/2025 12:27 PM DALLAS CO., TEXAS DF-24-18010 NO. THE MARRIAGE OF § § § MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPELL DISCOVERY RESPONSES TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW, Jason McKemie, Respondent in the above-entitled cause, and files this Notice of Preservation of Discovery Rights and Compel Discovery Responses, and in support thereof respectfully shows the Court: 1. Respondent served formal discovery on May 27, 2025, well within the discovery period defined by Texas Rule of Civil Procedure 190.3(b). At the time of service, Petitio...
#067
2025-06-27
Respondent / Jason
Motion - Miscellaneous
Page 2
PLEADING_BODY
MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPELL DISCOVERY RESPONSES_A3036D4D.pdf
...FOR RELIEF Respondent prays that the Court: e Formally preserve and enforce Respondent's right to conduct and compel discovery, including the discovery served on May 27, 2025, which was timely and properly served in good faith; e Compel Petitioner to provide full, unredacted responses to all outstanding discovery requests without further procedural delay or objection; « Acknowledge that Respondent has been stripped of access to all marital assets, despite being legally married to Petitioner since August 2023, and has been financially disabled by Petition...
#067
2025-06-27
Respondent / Jason
Motion - Miscellaneous
Page 3
PLEADING_BODY
MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPELL DISCOVERY RESPONSES_A3036D4D.pdf
e Grant all other relief, at law or in equity, to which Respondent may be justly entitled. Respectfully submitted, Jason McKemie Pro Se Respondent 539 W Commnerce St #2010 Dallas, TX 75208 (214) 868-4901 Jason@callvital.com 3 of 3 Copy from re:SearchTX
#067
2025-06-27
Respondent / Jason
Motion - Miscellaneous
Page 4
FILING_STAMP_OR_ESERVICE
MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPELL DISCOVERY RESPONSES_A3036D4D.pdf
...e ID: 102525532 Filing Code Description: Motion - Miscellaneous Filing Description: MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPELL DISCOVERY RESPONSES Status as of 6/30/2025 10:06 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Kim Jones kjones@sullivancook.com 6/27/2025 12:27:41 PM SENT Jeffrey ECook jcook@sullivancook.com 6/27/2025 12:27:41 PM SENT Tiffany Castenada tcastenada@sullivancook.com 6/27/2025 12:27:41 PM SENT William CCook wcook@sullivancook.com 6/27/2025 12:27:41 PM SENT Ethan Scroggins escroggins@sullivancook.com 6/27/...