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EMERGENCY MOTION TO VACATE SETTING BEFORE ASSOCIATE JUDGE AND RESET ENFORCEMENT_EEC608CB.pdf
11/19/2025 10:18 AM DALLAS CO., TEXAS NOTICE: DOCUMENT CONTAINS DF-24-18010 NO. SENSITIVE INFORMATION. MARRIAGE OF § § & § EMERGENCY MOTION TO VACATE SETTING BEFORE ASSOCIATE JUDGE AND RESET ENFORCEMENT BEFORE ISSUING JUDGE SANDRA JACKSON TO THE HONORABLE JUDGE OF THE 302ND DISTRICT COURT: Respondent, Jason McKemie, moves to vacate the current setting before Associate Judge Tamika Abendroth and reset enforcement and interpretation of Judge Sandra Jackson's September 9, 2025 on-the-record financial-disclosure directive before Judge Jackson, the issuing ju...
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...and must comply with Rule 10's notice/safeguard requirements; until an order signs, counsel remains attorney of record. Tex. R. Civ. P. 10 (Tex. Sup. Ct. order, Aug. 31, 2025). D. A court reporter is mandatory on request. e "On request, an official court reporter shall... attend all sessions of the court" and take the record and furnish a transcript. Tex. Gov't Code § 52.046(a)(1)-(5). See also In re Beverly Kotsanis, No. 22-0420 (Tex. Nov. 17, 2023) (Blacklock, J., concurring) (mandating a reporter on request). Il. APPLICATION A. On September 9, 2025, J...
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...ent respectfully requests that the Court: A. VACATE the current setting before Associate Judge Abendroth and RESET all enforcement and interpretation of the September 9, 2025 directive before Judge Sandra Jackson, the issuing judge. See Tex. Fam. Code §§ 201.315-.316; Leal, 892 S.W.2d at 857. 3 of 5 Copy from re:SearchTX
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B. ORDER the official court reporter to attend and record the reset hearing and all future substantive hearings upon request. See Tex. Gov't Code § 52.046(a). C. ENFORCE the September 9 directive by compelling immediate custodian-certified, complete, sequential monthly statements (bank/broker/credit) June 2023-present, with continuity and missing-page cures by a date certain, and by setting sanctions for any non-compliance shown. D. COMPEL production of the lease-buyout agreement and landlord ledger/communications; set sanctions if nondisclosure is confi...
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11/19/2025 Jason McKemie Date 539 W. Commerce St., Suite 2010, Dallas, TX 75208 (214) 868-4901 jmckemie@mckemie.net Jason McKemie 5of5 Copy from re:SearchTX
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NOTICE: DOCUMENT CONTAINS DF-24-18010 NO. SENSITIVE INFORMATION. MARRIAGE OF § & § DECLARATION OF JASON MCKEMIE - Exhibit A Financial Ambush, Lease Buyout, and Cumulative Harm STATE OF TEXAS § COUNTY OF DALLAS BEFORE ME, the undersigned authority, on this day personally appeared Jason McKemie, who, after being duly sworn, stated as follows: 1. "My name is Jason McKemie. I am over the age of 18, of sound mind, and capable of making this affidavit. The facts stated herein are within my personal knowledge and are true and correct." Between June and December...
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...guarantor for the marital residence lease, she secretly negotiated a lease buyout without informing me. I did not learn that a buyout had occurred until the October 31, 2025 hearing. By concealing the buyout, Petitioner placed me at risk of eviction while positioning herself to take possession of the residence and its contents. I contacted Petitioner and her counselor for assistance to avoid homelessness during the pending eviction proceedings; neither responded. 7 that she could not through the end of the lease term. It appears she simultaneously testi...
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...tunities, medical risk, and continuous pressure of imminent homelessness. Verification "T declare under penalty of perjury that the foregoing is true and correct." 11/19/2025 W Far Jaso cKemie Date 3 of 4 Copy from re:SearchTX
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Jason McKemie 4%539 W. Commerce St., Suite 2010 Dallas, TX 75208 jmckemie@mckemie.net 214-868-4901 4 of 4 Copy from re:SearchTX
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...g judge on the financial-disclosure directive) is necessary to restore continuity. I declare under penalty of perjury that the foregoing is true and correct. Date: 11.19.2025 Jason McKemie 1 of 1 Copy from re:SearchTX
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...& § DECLARATION OF JASON MCKEMIE - Exhibit C October 31 Hearing, Reporter Denial, and "Recording-Threat" Narrative I requested that the official court 1. On October 31, 2025, before Associate Judge Abendroth, | was told that no record would be made unless | privately prepaid for reporter take the record. a non-court reporter. The microphones were disabled. Under Tex. Gov't Code § 52.046(a), the official reporter "shall attend court sessions when requested." That did not occur. | was ordered to remove my iPhone from my pocket, power it off, 2. During thi...
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5. | was opposing seven attorneys, that Petitioner had | informed Judge Abendroth that along with nineteen false police reports conduct consistent with her documented pattern of malicious litigation against former partners, employers, spouses of former spouses, | further explained that this matter arrived in the 302nd neighbors, and even a landlord. District Court only after months of systemic obstruction, undisclosed accounts, and financial misconduct. Despite this, it appeared that chambers gave substantial weight to an off-record narrative advanced by...
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...that | had a history of "recording threats." This is false. have never been sanctioned, reprimanded, or held in contempt for recording | ever made was at the January 7, 2025 hearing, openly, any proceeding. The only recording before | understood the rule. That recording captured materially false testimony and has been central to explaining the procedural collapse that followed. No improper recording has occurred at any time since. 12. This off-record accusation appears to have been repeated across multiple courts, including assertions that | had been "r...
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...pe ID: 108218940 Filing Code Description: Miscellaneous Event M/ VACATE SETTING BEFORE Filing Description: EMERGENCY ASSOCIATE JUDGE AND RESET ENFORCE Status as of 11/21/2025 7:07 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status William CCook wcook@sullivancook.com 11/19/2025 10:18:13 AM SENT Ethan Scroggins escroggins@sullivancook.com 11/19/2025 10:18:13 AM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 11/19/2025 10:18:13 AM SENT Copy from re:SearchTX