DF-24-18010 Litigation Record Search

/Users/jason/Documents/DIVORCE/DV_Pleadings/PLEADINGS_OCR/df24_litigation_search/data/df24_litigation_search.sqlite

SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL (REQUEST FOR CUSTODIAN CONTINUITY RECORDS / SUBP

#152 2025-12-29 Respondent / Jason Notice Of Filing IN SUPPORT OF Page 1 PLEADING_START_FILE_MARKED
SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL_B8C5DC1A.pdf
ConfirmedDiscovery ViolationsDue Process FailuresAttorney Gamesmanship
StatusEmergency motion / stabilization required
12/29/2025 12:00 AM DALLAS CO., TEXAS DF-24-18010 NO. MARRIAGE OF § § & § SUPPLEMENT TO MOTION TO COMPEL FINANCIAL DISCOVERY COMPLIANCE NOTICE AND REQUEST FOR LEAVE TO SERVE TARGETED CUSTODIAN SUBPOENAS Appearing Pro Se, Respondent, Jason McKemie files this Motion for Leave pursuant to Texas Rule of Civil Procedure 205.3, respectfully requesting the Court's permission to serve a narrowly tailored subpoena outside the closed discovery window to obtain concealed financial records critical to the equitable resolution of this case. I. DISCOVERY COLLAPSE AND...
Open PDFDownload PDF

SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL (REQUEST FOR CUSTODIAN CONTINUITY RECORDS / SUBP

#152 2025-12-29 Respondent / Jason Notice Of Filing IN SUPPORT OF Page 2 PLEADING_BODY
SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL_B8C5DC1A.pdf
ConfirmedDiscovery ViolationsDue Process FailuresAttorney Gamesmanship
StatusEmergency motion / stabilization required
...of account diversity while obscuring actual financial activity. Chronological Tampering of Statements: Statements are presented out of sequence-bouncing between 2023 and 2025, across multiple card numbers, months, and even document types making it impossible to reconstruct timelines, trace transfers, or audit rental reimbursement flows. Suspected Rental Reimbursement Diversion: Petitioner informed Respondent that her rent is reimbursed by her employer, yet we have not been able to identify but a few ACH credit which would apply. Proper identification and...
Open PDFDownload PDF

SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL (REQUEST FOR CUSTODIAN CONTINUITY RECORDS / SUBP

#152 2025-12-29 Respondent / Jason Notice Of Filing IN SUPPORT OF Page 3 PLEADING_BODY
SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL_B8C5DC1A.pdf
ConfirmedDiscovery ViolationsDue Process FailuresAttorney Gamesmanship
StatusEmergency motion / stabilization required
...discovery at approximately 11:45 p.m. Petitioner's counsel disclosures. These materials had clearly been prepared in advance while counsel was operating unofficially. By 12:00 a.m., counsel declared discovery closed and refused to participate further. No meaningful responses were ever submitted. Coordinated Obstruction Undermined the Entire Process: Respondent asserts that the above actions were not coincidental or procedural missteps, but a calculated strategy to avoid the discovery process entirely through delay, concealment, and exploitation of proced...
Open PDFDownload PDF

SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL (REQUEST FOR CUSTODIAN CONTINUITY RECORDS / SUBP

#152 2025-12-29 Respondent / Jason Notice Of Filing IN SUPPORT OF Page 4 PLEADING_BODY
SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL_B8C5DC1A.pdf
ConfirmedDiscovery ViolationsDue Process FailuresAttorney Gamesmanship
StatusEmergency motion / stabilization required
e Subpoena Relief Justified by Ongoing Obstruction Whether this failure stems from an inability to understand the difference between a static year-end balance and actual account movement or from a willful effort to conceal financial misconduct the result is the same: key financial data remains hidden, and the discovery record is materially compromised. e Scope of This Motion Is Narrow-But Discovery Remains Unresolved: Respondent is seeking limited account information here because it relates directly to a live claim of procedural fraud involving rental pa...
Open PDFDownload PDF

SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL (REQUEST FOR CUSTODIAN CONTINUITY RECORDS / SUBP

#152 2025-12-29 Respondent / Jason Notice Of Filing IN SUPPORT OF Page 5 PLEADING_BODY
SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL_B8C5DC1A.pdf
ConfirmedDiscovery ViolationsDue Process FailuresAttorney Gamesmanship
StatusEmergency motion / stabilization required
o Explicit continuity mapping of any accounts that evolved via number reassignment, balance rollover, or relabeling 3. Transaction-Level Data For all accounts identified: o CSVor Excel format preferred o Dates, descriptions, balances, memos o Source/destination data for ACH, Zelle, wire transfers, check deposits 4. Peer-to-Peer Payments & Digital Wallets o Alltransactions through Venmo, Zelle, Apple Pay, PayPal, Cash App, or other P2P platforms linked to accounts above 5. Credit Card Specifics o All credit card accounts (Chase , Amex, Capital One, Etc.)...
Open PDFDownload PDF

SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL (REQUEST FOR CUSTODIAN CONTINUITY RECORDS / SUBP

#152 2025-12-29 Respondent / Jason Notice Of Filing IN SUPPORT OF Page 6 PLEADING_BODY
SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL_B8C5DC1A.pdf
ConfirmedDiscovery ViolationsDue Process FailuresAttorney Gamesmanship
StatusEmergency motion / stabilization required
o Transaction dates, descriptions, amounts, balances o Source/destination metadata for all ACH, Zelle, wire transfers o Any memo fields or classification codes available 3. Reconstruct account lineage, where applicable, by identifying: o Whether newer account numbers are continuations or replacements of older accounts o Dates of account openings, closures, or transfers o Any internal records showing movement of balances between accounts under different identifiers 4. Produce records related to any cash advances, credit card balance transfers, or signific...
Open PDFDownload PDF

SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL (REQUEST FOR CUSTODIAN CONTINUITY RECORDS / SUBP

#152 2025-12-29 Respondent / Jason Notice Of Filing IN SUPPORT OF Page 7 PLEADING_BODY
SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL_B8C5DC1A.pdf
ConfirmedDiscovery ViolationsDue Process FailuresAttorney Gamesmanship
StatusEmergency motion / stabilization required
...cted bank statements - omitting over $420,000 in marital income earned in the months preceding the hearing. Respondent paid $5,000/month in rent from January through May 2025. However, due to recurring hospitalization from a staph infection and physical collapse, he was unable to pay June, July, or August. An initial eviction attempt failed due to improper service. Respondent now faces asecond eviction and this time, Petitioner's name has been removed from the notice, despite being the only financial guarantor on the lease. Respondent believes this was i...
Open PDFDownload PDF

SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL (REQUEST FOR CUSTODIAN CONTINUITY RECORDS / SUBP

#152 2025-12-29 Respondent / Jason Notice Of Filing IN SUPPORT OF Page 8 PLEADING_BODY
SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL_B8C5DC1A.pdf
ConfirmedDiscovery ViolationsDue Process FailuresAttorney Gamesmanship
StatusEmergency motion / stabilization required
...ed from active eviction proceedings despite being the sole financial guarantor on the lease for the Dallas marital residence e Petitioner's sworn testimony on January 7, 2025, that she could not afford more than $3,800/month in rent at her San Antonio residence, despite a verified compensation package exceeding $1.46 million annually e Her concealed $10,000/month contributions to the Accenture Voluntary Equity Investment Program (VEIP), which began after the standing and temporary orders were in effect e Her failure to disclose that her San Antonio housi...
Open PDFDownload PDF

SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL (REQUEST FOR CUSTODIAN CONTINUITY RECORDS / SUBP

#152 2025-12-29 Respondent / Jason Notice Of Filing IN SUPPORT OF Page 9 PLEADING_BODY
SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL_B8C5DC1A.pdf
ConfirmedDiscovery ViolationsDue Process FailuresAttorney Gamesmanship
StatusEmergency motion / stabilization required
e Obstruct Respondent's access to the court, e And skew the final division of marital property in Petitioner's favor. Respondent was previously served with an eviction notice, which was dismissed due to improper service. However, a second notice was issued with Petitioner's name intentionally omitted, despite her being the sole financial guarantor on the lease. No lease amendment has concealing the obligated party from the proceeding-a tactic that may result in double payment and permanent displacement of Respondent. This eviction scheme is not an isolat...
Open PDFDownload PDF

SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL (REQUEST FOR CUSTODIAN CONTINUITY RECORDS / SUBP

#152 2025-12-29 Respondent / Jason Notice Of Filing IN SUPPORT OF Page 10 PLEADING_BODY
SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL_B8C5DC1A.pdf
ConfirmedDiscovery ViolationsDue Process FailuresAttorney Gamesmanship
StatusEmergency motion / stabilization required
Xl. REPEATED AND PREDICTABLE PATTERN OF ABUSE This pattern is not unique to the current case. Petitioner has Cca documented history of similar conduct across three prior marriages, each of which resulted in severe financial and psychological harm to her partners. Her most recent common-law relationship also included protective orders, stalking claims, and forced eviction mirroring the same tactics now being deployed in this case. XII. THE PROCEDURAL TRAP DOOR This case has become a procedural trap. Because Petitioner embedded criminal allegations in her...
Open PDFDownload PDF

SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL (REQUEST FOR CUSTODIAN CONTINUITY RECORDS / SUBP

#152 2025-12-29 Respondent / Jason Notice Of Filing IN SUPPORT OF Page 11 PLEADING_BODY
SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL_B8C5DC1A.pdf
ConfirmedDiscovery ViolationsDue Process FailuresAttorney Gamesmanship
StatusEmergency motion / stabilization required
Respondent further reserves all rights to seek full and fair remedy through all available procedural, evidentiary, and equitable means, including the right to reopen discovery, pursue sanctions, or initiate separate legal action based on any misconduct uncovered through this subpoena or previously concealed by Petitioner. V. PRAYER Respondent respectfully prays that the Court grant this Motion for Leave and permit the issuance of third-party subpoenas to JPMorgan Chase Bank, N.A. and Venmo, Inc. for the above-described financial account records. Responde...
Open PDFDownload PDF

SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL (REQUEST FOR CUSTODIAN CONTINUITY RECORDS / SUBP

#152 2025-12-29 Respondent / Jason Notice Of Filing IN SUPPORT OF Page 12 PLEADING_BODY
SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL_B8C5DC1A.pdf
ConfirmedDiscovery ViolationsDue Process FailuresAttorney Gamesmanship
StatusEmergency motion / stabilization required
...less of the name utilized. Respectfully submitted, a Jason McKemie Pro Se Respondent 539 W Commerce St, Suite #2010 Dallas, TX 75208 (214) 868-4901 jJmckemie@mckemie.net 12 of 11 Copy from re:SearchTX
Open PDFDownload PDF

SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL (REQUEST FOR CUSTODIAN CONTINUITY RECORDS / SUBP

#152 2025-12-29 Respondent / Jason Notice Of Filing IN SUPPORT OF Page 13 FILING_STAMP_OR_ESERVICE
SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL_B8C5DC1A.pdf
ConfirmedDiscovery ViolationsDue Process FailuresAttorney Gamesmanship
StatusEmergency motion / stabilization required
...otice Of Filing IN SUPPORT OF Filing Description: SUPPLEMENTAL SUBMISSION MOTION TO COMPEL (REQUEST FOR CUSTODIAN CONTINUITY RECORDS / SUBPOENA LEAVE) Status as of 12/29/2025 11:12 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 12/26/2025 11:48:54 PM SENT Gwendolyn Ulijasz gulijasz@gmail.com 12/26/2025 11:48:54 PM SENT JASON EMORYMCKEMIE jason@callvital.com 12/26/2025 11:48:54 PM SENT Copy from re:SearchTX
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 1 PLEADING_START_FILE_MARKED
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
12/29/2025 12:00 AM DALLAS CO., TEXAS DF-24-18010 RULES OF CIVIL PROCEDURE AND NO. COURTS INHERENT AUTHORITY THE MARRIAGE OF & SEALED SUBMISSION FOR IN CAMERA REVIEW URGENT: TIME SENSITIVE MOTION Submitted to: The Honorable Sandra Jackson Jason McKemie, Respondent (Pro Se) $39 W Commerce St., STE. # 2010 Dallas, TX 75208 jmckemie@mckemie.net | (214) 868-4901 - SEALED SUBMISSION IN CAMERA REVIEW ONLY DO NOT DOCKET FOR PUBLIC VIEW OR RELEASE TO OTHER PARTIES ABSENT COURT ORDER. Sealed submission; request in camera review prior to any disclosure; do not rel...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 2 PLEADING_BODY
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
DF-24-18010 RULES OF CIVIL PROCEDURE AND NO. COURTS INHERENT AUTHORITY THE MARRIAGE OF § § & § SEALED SUBMISSION FOR IN CAMERA REVIEW - SEALED SUBMISSION REQUEST FOR IN CAMERA REVIEW PRIOR TO ANY DISCLOSURE Respondent submits this packet for in camera review and requests it be handled as sealed and not made available on the public docket or to any other party absent Court order. This request is made pursuant to Tex. R. Civ. P. 76a (Sealing Court Records), including Tex. R. Civ. P. 76a(2)(a)(1) (in-camera filings solely to obtain a ruling on discoverabili...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 3 PLEADING_BODY
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
DF-24-18010 RULES OF CIVIL PROCEDURE AND NO. COURTS INHERENT AUTHORITY THE MARRIAGE OF § § & § MOTION FOR PSYCHIATRIC EXAMINATION OF PETITIONER MOTION FOR PSYCHIATRIC EVALUATION OF PETITIONER Contains confidential psychiatric, mental health, and privileged material submitted for in camera judicial review only. Not for public docket or disclosure to opposing counsel absent Court order. TO THE HONORABLE JUDGE OF THE 302ND DISTRICT COURT: Respondent, Jason McKemie, appearing pro se, respectfully files this submission under seal for in camera review. This mo...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 4 PLEADING_BODY
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
DF-24-18010 RULES OF CIVIL PROCEDURE ANO NO COURTS INHERENT AUTHORITY IN THE MATTER OF IN THE OISTRICT COURT THE GWENDOLYN ULUASZMCKE MIE 302™sUDICIAL DISTRICT a MOTION FOR PSYCOLOGICAL EXAMINATION FOR IN CAMERA REVIEW STATEMENT OF CIRCUMSTANCES Petitioner has placed her mental and emotional condition directly in controversy by asserting a $50,000 claim for Intentional Infliction of Emotional Distress ("IIED") against Respondent. Independent, third-party records - including two life insurance denials from The Hartford and MetLife citing an undisclosed DS...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 5 EXHIBIT_START
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
This motion is narrowly tailored to the IIED claim and the credibility issues it raises. It is submitted under seal and in camera to avoid unnecessary prejudice. Respondent requests that the costs be paid from marital estate funds under Petitioner's control. Respondent does not believe a reciprocal evaluation is necessary but will comply under identical conditions should the Court require it, with all costs likewise paid from the marital estate. Marriage Timeline & Documentary Proof Respondent and Petitioner were married in September 2023. On October 23,...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 6 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
| began noticing subtle but consistent changes in Petitioner's demeanor - In July 2024, she was less open, quicker to irritation, and more sensitive in general. One significant change stood out: she no longer appeared to need the prescription stimulant she had regularly taken for over a year to address reported daytime fatigue. Previously, Petitioner represented to both me and our family physician that she was taking only two antidepressants, concealing the fact that she had been prescribed a total of six psychiatric medications as of June 2024 - includi...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 7 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
spent months planning - was extraordinary. Friends and family described it as magical, and | felt the same. | In July 2024, began noticing subtle but troubling changes. Petitioner seemed more distant, less engaged, and her usual confidence gave way to insecurity. She sought validation but was also more volatile, her moods shifting unpredictably. In August, when she discontinued her prescribed psychiatric medications, the change was immediate and unmistakable. Her demeanor shifted sharply - emotional instability deepened into retaliatory behavior, and mom...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 8 EXHIBIT_START
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
Constant perception management: Obsessively shaping how others viewed her, with fixation on money, status, and ego. Fear of escalation to physical harm: Respondent began ensuring home cameras were functional at all times, fearing Petitioner might fabricate or stage a violent incident to frame him. Death declarations, interference with therapy, and denial of medical care: Over several months, Petitioner repeatedly told Respondent he was "going to die soon," claiming both his mother and his therapist (David) had said so. When Respondent's mother denied it,...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 9 EXHIBIT_START
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
...cealment of substantial marital funds. - Exhibit 10 Accenture Payroll Deduction for VEIP - Exhibit 11- Sullivan Cook Certified Financials "Extra Tax Withholding" Exhibit 12 - VEIP Program Summary - VEIP Balance Exhibit 13 4. False Police Reports & Misuse of Law Enforcement (December 11-14, 2024) Timeline of Events December 11, 2024 - Respondent called 911 and informed the operator that he was retaining an attorney for divorce and believed his wife was preparing to file a fraudulent protective order and false police reports. He expressly stated that he wa...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 10 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
medication - installed a keylogger on the shared Mac. The software was openly visible on the desktop and remained for only four days. Respondent's sole intent was defensive: to verify whether civil or criminal processes were being weaponized against him and whether police might come to the house armed. The captured information confirmed his fears - Petitioner was actively coordinating an offensive legal campaign against him. Once this was clear, he shut the program down. December 13, 2024 - Petitioner fully cut off Respondent from all marital funds, canc...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 11 EXHIBIT_START
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
Exhibit 14 - Dallas PD False Report Records & Investigative Findings - Exhibit 15 San Antonio PD False Report Records & Investigative Findings 5. Pattern of Weaponizing Protective Orders & Witness Tampering - it is a repeated Petitioner's misuse of protective orders is not limited to Respondent pattern extending to prior relationships. Her former husband has alleged that Petitioner: e Caused him to be terminated from his job. e Left him destitute and evicted him from his home. e Caused his children to be removed from his custody through false allegations...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 12 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
...espondent's autonomy, while simultaneously portraying herself as financially burdened, is consistent with behavioral patterns that merit a full psychological evaluation. 12 of 203 Copy from re:SearchTX
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 13 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
...e of her actions. e Canceled Respondent's last active card without replacement, ensuring he had no means to access marital funds. The following recorded call on December 12 shows the duplicity in real time: Petitioner promised six months of COBRA coverage, offered to pay rent "in advance," and assured Respondent he could remain in the marital home "for months." Moments later, she reversed her posture, claimed her "hands were tied" because he "didn't tell [her] in advance" about the attorney, and hung up. - it was a coordinated ambush. Petitioner knew Thi...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 14 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
e Filing for a protective order and annulment the following Monday, e Embedding false abuse and stalking allegations into the annulment petition, e Creating a procedural trap door so that contesting spousal support or legal fees would reopen those fabricated claims and allow her to introduce new "evidence" later. Petitioner has a documented history of securing confidential settlements from prior employers and is an experienced, well-resourced litigant spending over $100,000 per year on legal matters. She understands the value of embedding perjury into th...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 15 EXHIBIT_START
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
...ttorney and fears Petitioner will file false police reports and a fraudulent protective order; confirms to operator he is not armed so it is recorded. (Exhibit 17) e Dec 12 - Respondent pays divorce retainer, transfers $30,000 survival funds (per attorney advice), purchases post-surgery rehab equipment, and buys a Christmas gift for Petitioner's sister-in-law at her request. o Petitioner sees these charges, calls/texts Respondent, who confirms legitimacy. (Exhibit 18) o Petitioner reports all major charges as fraud, canceling the retainer, equipment, and...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 16 EXHIBIT_START
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
- Exhibit 17 - 911 Call Logs - - Dec 12th Retainer Cancellation Exhibit 18 Strategic Maneuvers: Canceled Respondent's representation, rushed her attorneys to file for a protective order and annulment on Monday, securing petitioner status first. Embedded abuse/stalking allegations into her annulment petition to create a procedural trap door if spousal support or legal fees were contested. Litigation as a Business Model - Petitioner has turned litigation into a revenue strategy, having secured confidential settlements from her last three employers - a fact...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 17 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
That there were new cameras installed at the marital residence that were "in every room", "so intimidating". That there were "listening devices all over the house." "I would say there were dozens." That a listening device was found in a plant" Spousal Support and Legal Fees were Denied. Petitioner then stated that she had given Respondent $8,400 in the prior month and provided Judge Brown a bank statement showing a $3,400 transfer. She stated this money was provided on top of paying his legal retainer of $5,000 and that she is not a piggy bank for his sp...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 18 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
e ~$500,000 in pre-hearing transfers to undisclosed accounts. e $94,000 luxury vehicle under warranty while claiming no functional automobile. « Employer-reimbursed San Antonio rent. e $10,000/month VEIP contributions mislabeled as "extra tax withholding." e Cosmetic procedures & luxury lodging while denying Respondent antibiotics, heart medication, and basic living resources. e Current status: Respondent facing imminent eviction, negative accounts, maxed credit cards since Dec, unable to afford prescriptions - separate relief request forthcoming. Petiti...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 19 EXHIBIT_START
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
...ing undisclosed transfers & mislabeled VEIP contributions 9. Photographic/documentary evidence of cosmetic procedures & luxury lodging 10. Recorded call transcripts (Dec 12, 2024) 11. Evidence 19 of 203 Copy from re:SearchTX
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 20 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
0 CHARACTER REFERENCE COURT IN THE MATTER OF THE MARRIAGE OF AND DECLARATION OF CHRISTINA SEGURA IN SUPPORT OF JASON MCKEMIE My name is Christina Segura, and my date ofbirth is December 24, 1974. I am over the age of 18 and competent to make this declaration. I have personal knowledge of the facts stated herein, and they are true and correct to the best of my knowledge. I've known Jason McKemie for nearly ten years we met as neighbors in Victory Park, and years later when a townhome opened up next door to us, we became neighbors for a second time. He's b...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 21 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
0 What she's doing is not reactive-it's intentional. It is cruel. It is wrong on a scale that is hard to convey. And the only conclusion left is the one no one wants to say out loud: she appears to enjoy causing harm. There is no other explanation that fits what we're witnessing. I saw the toll this took on Jason in late 2024. He told me Gwen had stopped her psychiatric medications before their Costa Rica trip but promised to resume after. She didn't. On November 16, we were supposed to attend a concert together. Gwen didn't come. Jason arrived alone. He...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 22 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
...IZANT TECHNOLOGY SOLUTIONS US CORPORATION Applicant: Guendotvn Uligas All Coverageis) Requested: Voluntary Lafa $900 000 Palicy Nemberts;: Gl 715217 5 THE HARTFORD March 12, 2024 Gwendolyn Ulises 521 Travis St Dallas. TX 75205 Deat Gwendolyn, Wo fas 85 received your request for res aluation of our decision tn group US CORPORATION coverag for thrush OGNIZANT TECHNOLOGY SOLUTIONS When our file review has been completed, we will contact you wth our decison. at If vou have any general questions, please cal! our Customer Service Representatives Our oars toxur...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 23 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
1 Applicant: t ligase Uaderwriting ID: SOLUTIONS CORPORATION THe HARTFORD LIFE AND ACCIDENT INSURANCE COMPANY Onc Hartford Plaza Hartford CT 3741665 PSYCHOLOGICAL QUESTIONNAIRE PAG medical history, we Oy sourself a spas of family membct) 1 Phare indicate all poychiattc'psecbotopcal diagnosis (cv) (dv) aad/ot presenume condtbonte far treament (rs) berets on hdeden No In Mold _-+ Ya NO M : LL Severe Yes ba NO 2 Mild Moderate Mild C Movierac Severe Yes (No C Yes 5 No Date 2 Are you the prewrihen treating provider for above > Istherea history of substance ab...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 24 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
1 Applicant: Guendolyn Ulips Underwriting ID: 8901172G Policyholder ( OCNIZANT TECHNOLOGY SOLUTIONS U 8. CORPORATION Poticy Number(s): 0GL7 15217 D Hospitalizauion partial E Other - ~~ Details > Le there any Instory of condition related work Iss? : Yor] No % Plcase provide most recent sinprom-based puchological rating scale results of cornpleted Intcepretaton Tool Dane Aidmumeacred Score PHO Heamtton Depression Rating Scule tHAM-D) Bock _-- 4 If above rating scale not completed please dest ibe sy ot Lass Gist 10 Airy function or wenition? C1 Yes © No Det...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 25 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
1d 12:24 4 wa > < (3) Re: UW ID 5901172-G/additional info and appeal (KMM46196673V67940LOKM) » inbox Medical Underwr... 32) GC) - tome Good Afternoon Gwen, Thank you for contacting the Medical Underwriting Depastment at The Hurtfurd regarding Underwriting ID: 59011 2. Huppy to assist! This ts to confirm that your appeal has heen received and as a result. a Paychological questionnaire was mailed to your home address on 3 12 14. For additional assistance, please reply to this email or contact our service center at 1-424 (M-F: ¥:00um- 8.00pm Fastern Time)....
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 26 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
1h ret reese whereeeTAMER WH ¢ 18S PEOCEMarne OT Oper need he Your P; Aap {Te be normpisied the ian proved-ng Weviment for Me cone an) a ets ener are ee be manny 4 a be ay to06 bh A ha te Matty Coneteity yo ern recone Condition Your Patient» tur wyyy) Wael recent tere cf Pestrerd Waa) coe bre Sete wr wnats0 canee of yar BORON BUNSEN USech naey (3 wey tang C Pregrety [Tipe ar th - Check ons below! U 8 Cerected convey date wae G Caserwen C) Nance Brim C) Liat any other physicionn ot yrs veterred you wr: Seecaty {Prene names Firat name bast name C wa fe yor...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 27 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
2 fetLife > Cage 784 rhdame Middle Name Last Meme Clan nptomns your patient reported to you pour findings and reports (Please inctude ofresults when you return thisform to the pian you tor W surgery as been performed cv antcoated. provide' CP14 procedure code Oram [pete any Mediceton name About Your |Patients Resvictions and Limitations Your domment hand «Check Ones: How "arty hours a workdsy Cen your cetert Copy from re:SearchTX
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 28 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
2 "4p MetLife gee Page Wide Renee Laet Nerne Caanlas ey MOUS IN @ Cer 9 oF carry. (0 8) tw 20 21 10 50 61 to 100 be Over 100 a D How mary hours in a workday can you patent pul 10 ma o o Frequency 19 we 20 fos. 0 2100 50 Be $1 0 a Over "00 ibs Can your patent operate @ Ove D to ORG t7 DO yeg CO Please make any About Your Patient's Progucsis Have you patent when they can te word? C Ves 0Cheech ail thuc apply) On date (mn/dd/ways O & ey O duty 0 No (Please explain) Ust ary restnctions to work activity (Please be sparta us possible) Copy from re:SearchTX
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 29 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
2 Beth SECTION 1: Cisim Yo by the person submitting the claim, or if received by the physician y Clarnart Feet Name Last Name Oate of Cstore' Nara \Ocsuoe*on 0527:1978 COGZA TECHNOLOGY LOLIMONS Ut CORPORATION Firat Nane Last Name (oh bee? Cum IE Authorization For Physician to Share My Medical information 1 Mone my phys-cran to reiease Meth4a 0 awally any ntormaton collected in te course of oF me aca catett Claman Signature 1 APS-STOLTD5320 Copy from re:SearchTX
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 30 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
...is Form Please ab of pagas of ths each Du form and ary 052062716 Ine number to the top of page. to Matis oy Mall: Fax: MetLife PO Box 14590 4-600-230-9531 Leangton KY 40512-4580 Copy from re:SearchTX
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 31 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
3 LHABK U 31, 21, Chase Bank, NA. Box Acount Number: 8893 182051 PO Box Columbus, CUSTOMER SERVICE INFORMATION Web site Chase.com Service Center: 1-888-262-4273 00008607 DRE 201 141 23423 NNNNNNNNNNN T 1000000000 15 0000 Para Espanol: 1-888-262-4273 GWENDOLYN L ULIJASZ International Calls: 1-713-262-1679 OR JASON E MCKEMIE Wo accept operator relay calls 4223 TRAVIS ST DALLAS TX 75205-4449 CHECKING SUMMARY Chase Saphire Checking AMOUNT Beginning Balance $0.00 Deposits and Additions 200.00 Ending Balance $200.00 Annual Percentage Yield Eamed This Period 0....
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 32 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
...rest 27, & GROUP ofyour ID: 2023 GWENDOLYN income withdrawais GWENDOLYN to Financial 1438 Ameriprise& LAURA 4097 LAURA Ameriprise 3 investment 001 ULUASZ December ULUASZ 29, CLIENT This AND ID: 2023 $0.00 $0.00 $0.00 $0.00 $0.00 period accounts 2700 JASON statement 3848 2 EMORY 001 MCKEMIE This $0.00 $0.00 $0.00 $0.00 $0.00 year te @ e@ e A In to the "=> (-=,) Did Your What 5960 the Thank Tools Need Andee by track Get Secure you here private accounts confidert to Fora to Once when than edelivery. You'll you you statement TX all you've discussion receive...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 33 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
¢ LORE f pg 2-10 Las; i! Copy from re:SearchTX
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 34 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
5 Affidavit of Witness Statement Elizabeth Bender To the Court: My name is Elizabeth Bender, and I served as the officiant in the wedding of Jason McKemie and Gwendolyn Ulijasz-McKemie. I've known Jason personally for nearly a decade, and during their relationship, I spent regular time with both him and Gwen as a friend, a confidant, and someone they trusted. Jason has always been someone who takes personal responsibility seriously. He's hardworking, honest, and deeply self-reflective. He owns his mistakes, gives more than he receives, and puts others be...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 35 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
...ed in the partnership. Later, when I learned that Gwen had characterized the marriage as a six-month - I was genuinely marriage - as she reportedly did in the January 7, 2025, hearing | witnessed. Their relationship and shocked. That statement doesn't reflect the reality commitment stretched far beyond that, and | was present for meaningful milestones I have no idea who that version of Gwen is who long before that six-month window. | would deny what clearly saw. In my view, Jason made his decisions in good faith, based on what Gwen was | saw that trust e...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 36 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
Total cognizant Rewards. U.S. Benefits Declaration of Domestic Partnership Form ULrTAe= 930342. Gratepoy LAweA Aas cine Name JASON Emory McKemre Name Social Securtty Number | cartify we ame! the criterts es dometic fer the purpose of being for and certain vetuntary coverege fac stated by Cognizent Technolgy Corp (the Werevet 11k rem ermeriog "nen ior Vee wes © Rms ath PN ba m1 Wee Ver cee? aC Ti easof eg ome aw Ae os toy: Her heey Qed MTA 8 Wee Sten A Wereaslee be jatet domee i ir 2 ews of cog ON Big Cay me] ons eh, fhe oul trey. oat pont + 4 atest be Me...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 37 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
09E'1S ome . {€689°") wer woe ee}sean se nes es mene ew oan rap eae tee we seem Be _ TF: -_ : : : : : : 1: : : : : : : : : IE:: Zé £02JO Copy from re:SearchTX
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 38 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
if it t it i t eben 0 Rin hove powun, Wy it agent oS E bare he if 89 t e f 38 of 203 Copy from re:SearchTX
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 39 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
@ 1) a th] orth (9) bs CG) @ @) WW) wm w Ca] m™m CR 'Chan Co] gout' the os Adestary dp ven ast ds ot (ho ant midtnivn, end Gn any ech aaah ened, enue ety Gv Dees Creme Rating cast petnaiyal nevept pew loyally prmenpel eames ene cayamandy. of ches baw Cnqusted poopanty ond yuu: the of tar confiate of and by The ofl adi sued gently Dumbte septhk Redence so the the the Maen) cash Aguats of Dat 2 an of recente o cigning by Os entharty charates thn butanging pragurty Power @ endh mabeies enti yeu hand 2 eanets weskd spore of a wd receyt, (Vou ee Oe over princ...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 40 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
e ij {? Lt uf t | 28 if ii yf if 85 tr ij t 7es f! 11aa il 5 f ? 40 of 203 Copy from re:SearchTX
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 41 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
3 3 $73 85 ts j! ft f j 1 f jjl i! if ea it]! 41 of 203 Copy from re:SearchTX
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 42 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
Ameriprise& Financial 701 Ameriorise Financial | Menneepolis, MN 55474 March 4, 2024 Client ID Number 2700 3857 3 001 JASON E MCKEMIE 4223 TRAVIS ST DALLAS TX 752015 4449 Dear Jason, We're wnting to confirm the most recent beneficiary designation for the aaccount(s) listed below as of the date of this letter. Any changes processed after that date will be confirmed in an additional letter. PRIMARY BENEFICIARY. GHENDOLYN LAURA ULIJASZ SPOUSE 100, 00% SECONDARY BENEFICIARY LIVING, LAWFUL CHILDREN IN EQUAL SHARES 10.00% Thts desiqnation is in effect for the...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 43 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
10a David, | was wrong to tell Jason that you said he was going to die [prematurely]. Whatever | thought was agreement from you after made that comment... now understand and accept it was misunderstood or misremembered by me. | then used that incorrect understanding as leverage in an argument with Jason. My intent was to manipulate him into showing me that he shared the same gravity of concern for his health as | do, and to more easily have him agree to a treatment plan in Houston instead of in Dallas. This was an attempt to help me feel in control of a...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 44 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
10b about my PTSD is lying by omission. | am | tapered off SSRIs last month, under psychiatrist and therapist 2x weekly supervision. experiencing withdrawal symptoms of heightened anxiety (ebbs and flows) and headaches at night. I'm angry, untrusting, and hurt. Heightened irritability and anxiety that inevitably comes | know it must be - is not well- with SSRI tapering - in whatever measure it's showing up and | timed given the circumstances. | am still learning about how it is showing up for me, and what can do to make life more tolerable for me and my...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 45 EXHIBIT_START
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
...coparenting my natural children under his 50% custody parenting plan at the time of abuse: Garrett S McNally 14 years old at time of abusive eviction. Gweneth S McNally 12 years old at time of abusive eviction. Sloane L McNally 12 years old at time of abusive eviction. 3. Ms Ulijasz and | were being treated for alcoholism, which Is in long term remission for both (uninterrupted sobriety/abstinence). 4. 1am sober, practices the 12 steps of AA with his sponsor and follows medical advice and work is a technology salesperson specializing in insurance since...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 46 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
...plants off of her forth story balcony on the 1900 block of Chicago Avenue down at people on the sidewalk and back parking lot in an attempt to harm. On or about November 29" 2022 Ms Ulijasz violently and suddenty without cause or any balanced procedure abusively evicted kids and me via text (Exhibit__), and manipulated me out of their shared co- habitation, which she called our home. Moments prior Ms Ubjasz spent the day naked, helping one another get ready for a work trip and house projects, induding 48 hours prior Ms Ulijasz writing in response to my d...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 47 EXHIBIT_START
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
...Ms Ulijasz having unvetted day labor mishandle and relocate firearms from a locked area inside to an unlocked garage while she was unreachable visiting the Middle East. 12. Ms Ulijasz repeated her pattern of harassing her target in the commercial marketplace and support network by texting wild untruths about Mr McNally in an attempt to discredit him and cause harm. 13. On or about November 29" 2022 Ms Ulijasz proactively sent knowingly false defamations of Mr McNally to Or George Caleel (business partner), Carolynn McNally (children's grandmother and in...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 48 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
it could jeopardize her new realtor license, and her managing broker's license. Further, | notified Merritt of serious conditions to the property that would need to be disclosed by law to potential buyers such as the illegal electrical, plumbing and structural compromises to the building, as well as mold and broken sewer line. Ms McClayton pretended to be naive. She was aware of Ms Ulijasz written kick back document to the short sale seller, but went along with the incredulous explanation that it was for subzero refrigerator that was never in the house,...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 49 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
and proper to correct the matter with Mr Varanasi. And as a shareholder in Cognizant (exhibit ), lam also entitled/obligated to notify Mr Varanasi, a executive director of the company, factual concerns that | have with Ms Ulijasz's purported $100,000,000.00 signing authority, considering she has proven to corrupt federally regulated bidding processes (short sale kickback scheme). Similar to the ARDC convincing me to cooperate in a case against my old lawyer who embezzled, their words rang true "she will do this again, and there will be more victims". It...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 50 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
...n's school or athletic events. 28. My children and my emotional, mental, and physical well-being is clearly at risk based upon the facts and situations contained herein. 29. Ms Ulijasz has no relevance in my family, she is a danger and a threat to our wellness, and we all wish her to leave us alone. 30. If called upon to testify to the facts set fourth herein, | am competent to do so by my own personal knowledge, except for those facts state to be upon information and belief. FURTHER AFFIANT SAYETH NAUGHT DATED: Christopher McNally 57of 203 Copy from re:...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 51 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
...McNaly 20230P7 1958 Calendar, 72 Cross case 20230P73364 23472630 McNally vs Ulijasz Contains series of texts between Ulijasz and McNally the day ofher mental breakdown 1127 and recidivism back into false accusation of abuse, days and months later: Ms Ulijasz starts the fateful day of Sunday 11/27/22 early by asking for special family outing to get Christmas Tree, and to forgo tradition because it "really means a lot to me" to make a big production out of it and go far away to cut a tree down or some such. Withing a short time Ulijasz experiences a radic...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 52 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
20230P71958 investigated the incident and 100% supports McNally and denounces Ulijasz's "weaponization of the Department [DCFS]", and Ulijasz name has been flagged as a warning for future claims she may report. DCFS investigators called Ulijasz behavior proverbial 'yelling fire in a crowded theater' and "dangerous". Ulijasz apologized for improper hugging and poor parenting at time of incident. Mr McNally was most disgusted with Ulijasz weaponizing of the agency DCFS in the incident, violently screaming the new acronym in McNally's face scaring him and s...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 53 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
...dchoming Mr McNally, and conducted a fraudulent short sale kickback scheme together (Ms McNally aka Orr). Ms Ulijasz had an OP against her selfby her entire HOA on the 1512 W Chicago Ave, and she had OPs against them as well too... She also reports feeling "ASSAULTED in my performance review", as well as client video conferences and even subordinates on video conference; reinforcing her cognitive dissonance challenges that shared group-therapists have pointed out to her in my presence as a condition she suffers. Sometimes Gwen reports this phenomenon in...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 54 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
...supported Mr his court ordered parenting time in exchange for her fraudulent short sale kickback cooperation. Ms Ulijasz had an OP against her by her entire HOA on the 1512 W Chicago Ave, and she had Ops against them as well... The attached exhibits include fabricated claims against her awarded industry leader, Tim DiSette was falsely accused by Gwen at Aig when she felt negative performance reviews oncoming for performance, and not acting in the company's best interest during her day-to-day responsibilitics as an account representative. She also reports...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 55 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
Gwen Exhibits eee Ulijasz Gwen has written and spoken record undermining Chris interests with known untruths. A significant example is scaring away his employer's investors through direct communication of known falsehoods for the purpose of causing harm. This resulted in loss of the company's funding. This also undermines Chris' ability to pay her fees, fund her unnecessary EOP, and whistle-blower bullying/intimidation/silencing through litigious harassment. TIEx.insetvent.navroll missed.a3.2023 Download ov oh © 2023 Gwen Ulijasz Exhibits 62 of 203 Copy...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 56 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
future Qa. 1 & 7 Eric Hillerbrand Qo a To Chris McNally Tue 9/19/2023 8 18 AM Ave anche wis fund an the 15" bua ostaad As now tha 30" That tam Gown tc pennies and won! be makin oayrol this Friday OLDE with some Liowngss on the part VC4 means we are effectively dead in the water with Arjun Pau and aii the other opportunities. Tnal means nese dears wi blow up the moan restructuring the focus and bus.ness. We Can discuss hater tras aflemoon as | work through the pian Best. Mierbrand, Ph.D. ceo y The Intelligence Exchange OT mh hd the Bate Build a more resil...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 57 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
280 a Loney 5 29 THLAI 112.9019 19109 40 HOOD NITI'AINIOD opdeng we ws ye Pree pm pes beyrmrtoy, ae) 'Onsavri 41080 40 WOLLIZLOWd 9d AUVRT14 UY ie Dateien AMMITIOM 00 ON LIRIOG OO Bd WOLTERSMN BD UCEEREEY 88 1S5ACERLF WEEE ANA PLWEARS 40 Se Ess Gat Fe mes 4 eee ah Theat eee 199 AAV Tk 82 tine 6 AO dpe) : G) wDare om nome WEE sen new duy sOpsr pe we © > (sme OPUS jecanara ees oD Pacha somal ase 14 re oto Va od Opec) Ris UUM ROAGYR) 1 GPRS 10.00 6 WS 0 pen om ol OF 4 loa erence a6) 355 00.01 2 Copy from re:SearchTX 9uece
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 58 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
...sputes between them. IT IS HEREBY AGREED by and between EMPLOYEE and EMPLOYER as follows: If EMPLOYEE and does revoke this Agrecment (in accordance with Paragraphs ? and 12, below), aad otherwise coraptics with the provisions ofthie Agreement, then, EMPLOYER, for and in nonsiderstioa nf the forth and referenced herein, and intending 10 be legally bound, agrees pay EMPLOYEE a lump of hundred fifty six thousand forty five dollars ($156,045), lem applicable taxes and deductions, allocaicd as follows: (a) $104,000 to EMPLOYEE, paid via check, and mailed to E...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 59 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
and expenses. The afsrementioned payments will no later then (7) days following the expiration ofthe revncatian perind in Section 12(d) below af 2. EMPI OYFF experesty arknomledges and agres that FMPIOYEF has least 21 days consider this Agreement. If FMPIOYEFF dors act sign this Agreement by May receive the ennsideration described in Paragraph 1. $ ms then EMPLOYER ell aot 3. EMPLOYEE expressly agrees that, other then the payments described herein, EMPLOYEE has been paid all owed to EMPLOYEE as a result of EMPLOYEE's employment with EMPLOYER, or the term...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 60 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
...the extent such vested benefits may exist); the Fair Labor Standards Act CFLSA"), the Worker Adjustment and Retraining Notification Act, the Sarbance- NI Stet Ann § 10:5-12a seq. ; 407 Againat Diecrimimation, Onley Act of 204077 the New Jorecy I NJ. Admin. Code § 12:67-1.3.; the New Jersey Civil Rights Act, NJ. Stat. Aan. § 10:6-2; the New Jersey Family Leave Act, NJ. Stat. Ann. § 34: 11B-9; the New Jerecy State Wage and Hour Lew, NJ. Stat. Ann. § 34: 11-5S6a ef seq.; the New Jersey Conscientious Employee Protection Act, NJ. Stat. Ann. § 34:19-1-34: 19-8...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 61 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
hereafter recognized, tn far damages stteneys* fees, expenses and costs. (1) Nu thie Agpnement chink] be read 4. prevent EMPL OYEF fin 10 cite ising any vested lights EMPLOYEE has under the terme nf thie Agrnement; (2) retaining ely Gngployus DuncGt, Gyuily plan of CME LOWER (ihe plan uf wha and ERISA will continue to govern); (3) filing claims arising for the first time after EMPLOYEE Agreement. In nothing in this is intended to interfere. TMPLAVEN Gling = «fein with federal, state, or local government peewent qy agen y thet is rrepousible for enfucving...
Open PDFDownload PDF

MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL)

#151 2025-12-29 Respondent / Jason Motion - Seal - SEALED SUBMISSION FOR IN CAMERA Page 62 EXHIBIT_CONTINUATION
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
ConfirmedDiscovery ViolationsFinancial ReliefFalse NarrativesMedical RiskAttorney GamesmanshipDanger / High Risk
StatusRespondent pleading: no ruling made / no hearing
and state fu beds & ti thei: sttieney, & court, 5 government official in certain confidential circumstances that set forth in the Defend Trade Secrets Act at 18 U.S.C. §§ 1833(b\1) and 1833(b)(2), related tu the bills & lawsdl fur fox reporting& suspected violation of the law. 5. EMPLOYEF represents thas! ae ale dose hews any lawsuils, claims, or cheages pending agaimet any the RFIEASFFS, EMPLOYEE further acknowledges that EMPLOYEE hes not made any claims allegations related to sexual harsssrnent or sexual abuse and ofthe psyments forth in this Agrecrmem...
Open PDFDownload PDF