#118
2025-10-22
Respondent / Jason
Motion - Miscellaneous
Page 1
PLEADING_START_FILE_MARKED
REQUEST_A3C03ED0.pdf
10/22/2025 4:50 PM DALLAS CO., TEXAS THE MARRIAGE OF § § & § MOTION FOR REINSTATEMENT OF WRONGFULLY REPORTED & WITHHELD MARITAL FUNDS, AND DIRECTIVE FOR IMPENDING BONUS PAYMENT TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW Jason McKemie, Respondent, and files this Motion for Reinstatement of Wrongfully Reported and Withheld Marital Funds, and Directive for Impending Bonus Payment, and in support thereof respectfully shows the Court as follows: I. CRITICAL BACKGROUND, MALICIOUS LITIGATION, AND RETALIATORY CONDUCT 1. Medical Crisis. On December 10, 2024,...
#118
2025-10-22
Respondent / Jason
Motion - Miscellaneous
Page 2
PLEADING_BODY
REQUEST_A3C03ED0.pdf
...5,000 annually in offensive legal expenditures against former partners, employers, neighbors, landlords, and associates, often via misuse of protective-order mechanisms. 10. Prior Witness-Tampering Example. In a prior matter involving former spouse Christopher McNally, Petitioner obtained an extension of a protective order under irregular circumstances after Mr. McNally-scheduled to testify regarding Petitioner's misuse of protective orders- was arrested the day before the hearing and could not appear. The extension was granted by default with added rest...
#118
2025-10-22
Respondent / Jason
Motion - Miscellaneous
Page 3
PLEADING_BODY
REQUEST_A3C03ED0.pdf
...ealment deprived him of his share and constitutes financial misconduct. 14. Impending Bonus. Petitioner is scheduled to receive a $150,000 bonus on or about November 15, 2025. At mediation, the parties acknowledged $75,000 remained owed to Respondent and that $50,000 of a subsequent bonus would be applied toward that obligation; Respondent received neither. The impending bonus should be awarded to Respondent to satisfy obligations incurred in his name due to Petitioner's conduct or, alternatively, secured in escrow under Court supervision. Fraud upon the...
#118
2025-10-22
Respondent / Jason
Motion - Miscellaneous
Page 4
PLEADING_BODY
REQUEST_A3C03ED0.pdf
...RATELY 16. Respondent places the Court on notice that a separate motion will address damages arising from Petitioner's false declaration of destitution at the January 7, 2025 hearing. As a direct result, while recovering from spinal surgery, Respondent assumed approximately $25,000 per month in marital-residence expenses. To meet those obligations, Respondent's father loaned him $50,000, diverting funds intended for his entry into a memory-care facility. Respondent will seek reimbursement of that sum and related sanctions by separate motion. 17. Accordin...
#118
2025-10-22
Respondent / Jason
Motion - Miscellaneous
Page 5
PLEADING_BODY
REQUEST_A3C03ED0.pdf
...nce with subparagraph (b); if the original proceeds have been moved or dissipated, require satisfaction from Petitioner's current assets, bonuses (including the November 2025 bonus), or other funds under her control. d. Direct that the forthcoming $150,000 bonus due on or about November 15, 2025 be immediately awarded and disbursed to Respondent to satisfy marital debts and obligations incurred in his name as a result of Petitioner's conduct; alternatively, if immediate disbursement is not feasible, order that the entire amount be deposited within two (2...
#118
2025-10-22
Respondent / Jason
Motion - Miscellaneous
Page 6
FILING_STAMP_OR_ESERVICE
REQUEST_A3C03ED0.pdf
...rsons listed below. The rules governing Envelope ID: 107180410 Filing Code Description: Motion - Miscellaneous Filing Description: WAITING FOR $80.00- Status as of 10/27/2025 11:52AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Kim Jones kjones@sullivancook.com 10/22/2025 4:50:55 PM SENT Jeffrey ECook jcook@sullivancook.com 10/22/2025 4:50:55 PM SENT Tiffany Castenada tcastenada@sullivancook.com 10/22/2025 4:50:55 PM SENT William CCook wcook@sullivancook.com 10/22/2025 4:50:55 PM SENT Ethan Scroggins escroggins@sullivancook.com 10/22/...