DF-24-18010 Litigation Record Search

11/4/2025 8:30 AM DALLAS CO., TEXAS DF-24-18010 NO. THE MARRIAGE OF § § & § EMERGENCY OBJECTION TO MOTION TO WITHDRAWAL OF COUNSEL AND FOR EXPEDITED HEARING REQUEST TO THE HONORABLE JUDGE SANDRA JACKSON: Respondent Jason McKemie objects to Petitioner's counsel's latest Motion to Withdraw and moves for an immediate hearing. The record now shows a repeated, calculated pattern of withdrawing the last possible moment with blanket objections and no production. Respondent warned both this Court and Associate Judge Abendroth that this tactic would be repeated;...

Jun 23 2025 @ 11:08 simultaneous "'service-only" responses to discovery fifteen minutes before p.m. . the close of discovery compliance. This pattern demonstrates deliberate evasion of discovery obligations through withdrawal and late- night re-appearance. The record itself (filing timestamps and certificates of service) confirms these facts. Il. CONSEQUENCES OF THE WITHDRAWAL CYCLE 1. Discovery Skipped Entirely. Petitioner has never produced financial records, lease buyout agreements, or account statements. At the pre-trial hearing before Judge Jackson,...

...pped discovery and were using procedural maneuvers to avoid compliance. Judge Jackson acknowledged those concerns, confirmed that discovery remained open through June 23 2025, and stated that any non- production could be addressed through post-hearing enforcement. Respondent expressed hope that the Court's directive would compel genuine participation in discovery, but also conveyed that based on the firm's prior pattern of withdrawal and late-night re-entries he had little confidence they would comply without direct judicial oversight. intent to pursue s...

2. False Victimhood Narrative and Manufactured Police Reports Petitioner and her witnesses created a false "surveillance-victim" narrative that reversed the truth. In reality, Respondent has been the subject of over a dozen false police reports, 6 unfounded investigations, and was read his miranda rights 3 times all for allegations which were later shown to be false. Additionally, there have been 3 tracking-device recovered from his belongings and vehicle events confirming that the allegations against Respondent were the inverse of reality. 3. Improper E...

2. Set an immediate expedited hearing to confirm production and representation status, and to ensure a complete evidentiary record before any order is signed. 3. Grant any further relief in law or equity to which Respondent is entitled. Respectfully submitted, : : ason MeKemie, Pro-Se-Respondent 539 W Commerce St, Suite 2010 | Dallas, TX 75208 jmckemie@mckemie.net | (214) 868-4901 EMERGENCY OBJECTION TO WITHDRAWAL OF COUNSEL & REQUEST FOR 5of5 EXPEDITED HEARING Copy from re:SearchTX

DF-24-18010 NO. THE MARRIAGE OF § § § ORDER ON OBJECTION TO WITHDRAWAL OF PETTITIONER'S COUNSEL On this day, the Court considered Respondent's Emergency Objection to Motion to Withdrawal as Counsel and Request for Expedited Hearing. After reviewing the motion, the record, and applicable law, the Court makes the following findings and orders: IT IS ORDERED THAT: THE ALTERNATIVE, CONDITIONALLY GRANTED subject to full compliance with the terms below. 2. Discovery Compliance Requirement. Petitioner and her current counsel, Sullivan & Cook, LLC, shall produce...

...rt's inherent authority for discovery abuse and bad-faith conduct by Petitioner and her counsel, Sullivan & Cook, LLC, during their representation. SIGNED on this day of 2025. THE HONORABLE JUDGE OF THE 302"° DISTRICT COURT ORDER ON RESPONDENTS' OBJECTION OF WITHDRAWAL OF COUNSEL 2 of 2 Copy from re:SearchTX

...Objections - Misc Filing Description: EMERGENCY OBJECTION TO MOTION TO WITHDRAW AS COUNSEL AND REQUEST FOR EXPEDITED HEARING (INCLUDES PROPOSED ORDER) Status as of 11/5/2025 10:40 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status William CCook wcook@sullivancook.com 11/4/2025 8:30:55 AM SENT Ethan Scroggins escroggins@sullivancook.com 11/4/2025 8:30:55 AM SENT Jason McKemie jmckemie@mckemie.net 11/4/2025 8:30:55 AM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 11/4/2025 8:30:55 AM SENT JASON EMORYMCKEMIE jason@callvital.com 11/4/20...