#094
2025-07-23
Respondent / Jason
Motion - Recuse
Page 1
PLEADING_START_FILE_MARKED
RESPONDENT VERIFIED M_RECUSE_84729A4F.pdf
7/23/2025 11:02 AM DALLAS CO., TEXAS DF-24-18010 NO. MARRIAGE OF RESPONDENT'S VERIFIED MOTION TO RECUSE JUDGE KIMBERLY BROWN UNDER TEX. R. CIV. P. 18a This document contains sensitive medical, financial, and evidentiary content. Respondent respectfully requests this document be maintained under seal untiljudicial review. Respondent reserves the right to request unsealing as appropriate for legal protection or evidentiary exposure. - Reservation of Rights to Unseal Confidential Filing and safety-related information from unnecessary public exposure. Respon...
#094
2025-07-23
Respondent / Jason
Motion - Recuse
Page 2
PLEADING_BODY
RESPONDENT VERIFIED M_RECUSE_84729A4F.pdf
TO THE HONORABLE PRESIDING JUDGE: COMES NOW Jason McKemie, Respondent in the above-captioned matter, and files this Verified respectfully states: I. RELIEF REQUESTED Respondent respectfully moves this Court to recuse JJudge Kimberly Brown from presiding over this case, and requests reassignment of this matter to a new judge for all further proceedings. IL. JUDGE TO BE RECUSED This motion is directed to JJudge Kimberly Brown, currently presiding over the 254th District Court Il. FACTUAL AND LEGAL BASIS FOR RECUSAL Respondent asserts that Judge Brown's con...
#094
2025-07-23
Respondent / Jason
Motion - Recuse
Page 3
PLEADING_BODY
RESPONDENT VERIFIED M_RECUSE_84729A4F.pdf
...penalty of perjury that the facts stated in the foregoing Motion to Recuse are true and correct to the best of my knowledge and belief. Executed on this 23 day of July, 2025. Signature: Jason McKemie 3 Copy from re:SearchTX
#094
2025-07-23
Respondent / Jason
Motion - Recuse
Page 4
PLEADING_BODY
RESPONDENT VERIFIED M_RECUSE_84729A4F.pdf
DF-24-18010 NO. MARRIAGE OF SUPPLEMENTAL NOTICE OF INTENT TO SUBMIT EXHIBITS IN SUPPORT OF RULE 18a MOTION This document contains sensitive medical, financial, and evidentiary content. Respondent respectfully requests this document be maintained under seal untiljudicial review. Respondent reserves the right to request unsealing as appropriate for legal protection or evidentiary exposure. - Reservation of Rights to Unseal Confidential Filing and safety-related information from unnecessary public exposure. Respondent explicitly reserves the right to reques...
#094
2025-07-23
Respondent / Jason
Motion - Recuse
Page 5
PLEADING_BODY
RESPONDENT VERIFIED M_RECUSE_84729A4F.pdf
TO THE HONORABLE PRESIDING JUDGE: Statement from Jason McKemie Supplemental Respondent (In support ofRule 18a Motion to Recuse) Respondent's health has been in steady decline for weeks. He has been in and out of emergency care, facing compounding medical hardship, with no access to spousal support, medical benefits, or marital resources. Opposing counsel has been consistently notified of this, yet continues to push forward aggressively while refusing to produce discovery, correct misrepresentations, or meaningfully participate in resolution. court or att...
#094
2025-07-23
Respondent / Jason
Motion - Recuse
Page 6
PLEADING_BODY
RESPONDENT VERIFIED M_RECUSE_84729A4F.pdf
using the HSA card. The remainder required special ordering and was scheduled for pickup the following day. When Respondent returned, the card had been disabled. This was not accidental. When Petitioner saw that Respondent had regained access to the HAS Benefits card, she revoked it fully aware that Respondent had just been released from a six-day hospitalization and remained at serious medical risk. This act of calculated cruelty left Respondent without the life-sustaining medications required to treat his infection. At the time of this filing, Responde...
#094
2025-07-23
Respondent / Jason
Motion - Recuse
Page 7
PLEADING_BODY
RESPONDENT VERIFIED M_RECUSE_84729A4F.pdf
...penalty of perjury that the facts stated in the foregoing Motion to Recuse are true and correct to the best of my knowledge and belief. Executed on this 23 dgy of July, 2025. Signature: Jason McKemie 7 Copy from re:SearchTX
#094
2025-07-23
Respondent / Jason
Motion - Recuse
Page 8
FILING_STAMP_OR_ESERVICE
RESPONDENT VERIFIED M_RECUSE_84729A4F.pdf
...sons listed below. The rules governing Envelope ID: 103479348 Filing Code Description: Motion - Recuse Filing Description: RESPONDENT VERIFIED M/RECUSE Status as of 7/24/2025 8:46 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Kim Jones kjones@sullivancook.com 7/23/2025 11:02:09AM SENT Jeffrey ECook jcook@sullivancook.com 7/23/2025 11:02:09AM SENT Tiffany Castenada tcastenada@sullivancook.com 7/23/2025 11:02:09AM SENT William CCook wcook@sullivancook.com 7/23/2025 11:02:09AM SENT Ethan Scroggins escroggins@sullivancook.com 7/23/2025...
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2025-07-23
Respondent / Jason
Motion - Recuse
Page 1
PLEADING_START_FILE_MARKED
RESPONDENT VERIFIED MRECUSE_84729A4F.pdf
7/23/2025 11:02 AM DALLAS CO., TEXAS DF-24-18010 NO. MARRIAGE OF RESPONDENT'S VERIFIED MOTION TO RECUSE JUDGE KIMBERLY BROWN UNDER TEX. R. CIV. P. 18a This document contains sensitive medical, financial, and evidentiary content. Respondent respectfully requests this document be maintained under seal untiljudicial review. Respondent reserves the right to request unsealing as appropriate for legal protection or evidentiary exposure. - Reservation of Rights to Unseal Confidential Filing and safety-related information from unnecessary public exposure. Respon...
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2025-07-23
Respondent / Jason
Motion - Recuse
Page 2
PLEADING_BODY
RESPONDENT VERIFIED MRECUSE_84729A4F.pdf
TO THE HONORABLE PRESIDING JUDGE: COMES NOW Jason McKemie, Respondent in the above-captioned matter, and files this Verified respectfully states: I. RELIEF REQUESTED Respondent respectfully moves this Court to recuse JJudge Kimberly Brown from presiding over this case, and requests reassignment of this matter to a new judge for all further proceedings. IL. JUDGE TO BE RECUSED This motion is directed to JJudge Kimberly Brown, currently presiding over the 254th District Court Il. FACTUAL AND LEGAL BASIS FOR RECUSAL Respondent asserts that Judge Brown's con...
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2025-07-23
Respondent / Jason
Motion - Recuse
Page 3
PLEADING_BODY
RESPONDENT VERIFIED MRECUSE_84729A4F.pdf
...penalty of perjury that the facts stated in the foregoing Motion to Recuse are true and correct to the best of my knowledge and belief. Executed on this 23 day of July, 2025. Signature: Jason McKemie 3 Copy from re:SearchTX
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2025-07-23
Respondent / Jason
Motion - Recuse
Page 4
PLEADING_BODY
RESPONDENT VERIFIED MRECUSE_84729A4F.pdf
DF-24-18010 NO. MARRIAGE OF SUPPLEMENTAL NOTICE OF INTENT TO SUBMIT EXHIBITS IN SUPPORT OF RULE 18a MOTION This document contains sensitive medical, financial, and evidentiary content. Respondent respectfully requests this document be maintained under seal untiljudicial review. Respondent reserves the right to request unsealing as appropriate for legal protection or evidentiary exposure. - Reservation of Rights to Unseal Confidential Filing and safety-related information from unnecessary public exposure. Respondent explicitly reserves the right to reques...
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2025-07-23
Respondent / Jason
Motion - Recuse
Page 5
PLEADING_BODY
RESPONDENT VERIFIED MRECUSE_84729A4F.pdf
TO THE HONORABLE PRESIDING JUDGE: Statement from Jason McKemie Supplemental Respondent (In support ofRule 18a Motion to Recuse) Respondent's health has been in steady decline for weeks. He has been in and out of emergency care, facing compounding medical hardship, with no access to spousal support, medical benefits, or marital resources. Opposing counsel has been consistently notified of this, yet continues to push forward aggressively while refusing to produce discovery, correct misrepresentations, or meaningfully participate in resolution. court or att...
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#
2025-07-23
Respondent / Jason
Motion - Recuse
Page 6
PLEADING_BODY
RESPONDENT VERIFIED MRECUSE_84729A4F.pdf
using the HSA card. The remainder required special ordering and was scheduled for pickup the following day. When Respondent returned, the card had been disabled. This was not accidental. When Petitioner saw that Respondent had regained access to the HAS Benefits card, she revoked it fully aware that Respondent had just been released from a six-day hospitalization and remained at serious medical risk. This act of calculated cruelty left Respondent without the life-sustaining medications required to treat his infection. At the time of this filing, Responde...
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#
2025-07-23
Respondent / Jason
Motion - Recuse
Page 7
PLEADING_BODY
RESPONDENT VERIFIED MRECUSE_84729A4F.pdf
...penalty of perjury that the facts stated in the foregoing Motion to Recuse are true and correct to the best of my knowledge and belief. Executed on this 23 dgy of July, 2025. Signature: Jason McKemie 7 Copy from re:SearchTX
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2025-07-23
Respondent / Jason
Motion - Recuse
Page 8
FILING_STAMP_OR_ESERVICE
RESPONDENT VERIFIED MRECUSE_84729A4F.pdf
...sons listed below. The rules governing Envelope ID: 103479348 Filing Code Description: Motion - Recuse Filing Description: RESPONDENT VERIFIED M/RECUSE Status as of 7/24/2025 8:46 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Kim Jones kjones@sullivancook.com 7/23/2025 11:02:09AM SENT Jeffrey ECook jcook@sullivancook.com 7/23/2025 11:02:09AM SENT Tiffany Castenada tcastenada@sullivancook.com 7/23/2025 11:02:09AM SENT William CCook wcook@sullivancook.com 7/23/2025 11:02:09AM SENT Ethan Scroggins escroggins@sullivancook.com 7/23/2025...
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