#156
2026-01-05
Respondent / Jason
Motion - Leave
Page 1
PLEADING_START_FILE_MARKED
PETITIOMNER'S MOTION FOR LEAVE TO CONDUCT LIMITED POST-CUTOFF_8CFBE77B.pdf
1/5/2026 12:00 AM DALLAS CO., TEXAS PETITIONER'S MOTION FOR LEAVE TO CONDUCT LIMITED POST-CUTOFF DISCOVERY IN THE MATTER OF THE MARRIAGE OF GWENDOLYN ULIJJASZ, Petitioner and JASON McKEMIE, Respondent TO THE HONORABLE JUDGE OF SAID COURT: Petitioner, Gwendolyn Ulijasz, appearing pro se, respectfully moves the Court for leave to conduct limited, targeted discovery after the discovery cutoff established in the Court's Pre- Trial Order and, in support, states as follows: I. PROCEDURAL BACKGROUND 1. This matter is set for final trial on February 24, 2026. 2....
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#156
2026-01-05
Respondent / Jason
Motion - Leave
Page 2
PLEADING_BODY
PETITIOMNER'S MOTION FOR LEAVE TO CONDUCT LIMITED POST-CUTOFF_8CFBE77B.pdf
...ative electronic format, for mail addressed to Petitioner individually or jointly with Respondent that was received either directly or by "forward" into McKemie Mailbox 1015 during calendar year 2024 and 2025. No opening of mail or content beyond envelope/package exterior is requested. Copy from re:SearchTX
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#156
2026-01-05
Respondent / Jason
Motion - Leave
Page 3
PLEADING_BODY
PETITIOMNER'S MOTION FOR LEAVE TO CONDUCT LIMITED POST-CUTOFF_8CFBE77B.pdf
9. Each proposed subpoena requests production with a custodian of records affidavit to streamline admissibility at trial. IV. GOOD CAUSE FOR LEAVE OF COURT 10. Good cause exists to permit this limited discovery because: a. The records were previously requested but not produced; b. Petitioner was excluded from access to the underlying accounts, records, and residence; c. A substantially similar subpoena covering calendar year 2024 was previously authorized by the 254th Court and complied with by the same mailbox provider; d. The requested discovery is pro...
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#156
2026-01-05
Respondent / Jason
Motion - Leave
Page 4
FILING_STAMP_OR_ESERVICE
PETITIOMNER'S MOTION FOR LEAVE TO CONDUCT LIMITED POST-CUTOFF_8CFBE77B.pdf
on the date and to the persons listed below. The rules governing Envelope ID: 109623023 Filing Code Description: Motion - Leave Filing Description: Status as of 1/5/2026 8:49 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 1/3/2026 9:16:51 AM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 1/3/2026 9:16:51 AM SENT JASON EMORYMCKEMIE jason@callvital.com 1/3/2026 9:16:51 AM SENT Copy from re:SearchTX
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#155
2026-01-05
Respondent / Jason
Notice Of Filing
Page 1
FILING_STAMP_OR_ESERVICE
NOTICE PRIOR COURT REPORTER REQUEST & OBJECTION TO OFF RECORD HEARING_179CB3AF.PDF
1/5/2026 12:00 AM DALLAS CO., TEXAS NO. DF-24-18010 NOTICE: THIS DOCUMENT CONTAINS SENSITIVE MATERIALS THE MARRIAGE OF § 5 & § NOTICE OF PRIOR STANDING FOR REQUEST COURT REPORTER / OFFICIAL RECORD NON-WAIVER AND OBJECTION TO PROCEEDING WITHOUT A VERBATIM RECORD TO THE HONORABLE JUDGE OF SAID COURT: Jason McKemie (Respondent) files this Notice of Prior Standing Request for Court Reporter / Official Record, together with a Non-Waiver and Objection to Proceeding Without a Verbatim Record, and respectfully shows the Court: A I. THIS IS COURTESY REMINDER OF A...
#155
2026-01-05
Respondent / Jason
Notice Of Filing
Page 2
PLEADING_BODY
NOTICE PRIOR COURT REPORTER REQUEST & OBJECTION TO OFF RECORD HEARING_179CB3AF.PDF
...complete, clear, and transcribable recording is made and preserved. 11. Independently and in addition, the Court possesses inherent authority under Tex. Gov't Code § 21.001(a) to do whatever is necessary for the Court to exercise its jurisdiction and enforce its lawful orders, including issuing administrative directives that ensure proceedings are properly recorded so that orders, rulings, and objections can be accurately memorialized and reviewed if necessary. IV. ALTERNATIVE RELIEF IF A COURT REPORTER IS NOT AVAILABLE 12. Ifa stenographic court reporte...
#155
2026-01-05
Respondent / Jason
Notice Of Filing
Page 3
PLEADING_BODY
NOTICE PRIOR COURT REPORTER REQUEST & OBJECTION TO OFF RECORD HEARING_179CB3AF.PDF
...unity funds as requested; and 7. grant such other relief to which McKemie may be justly entitled. NOTICE OF STANDING REQUEST FOR COURT REPORTER / NON-WAIVER 3of4 DF-24-18010 3 of 7 Copy from re:SearchTX
#155
2026-01-05
Respondent / Jason
Notice Of Filing
Page 4
CERTIFICATE_OF_SERVICE
NOTICE PRIOR COURT REPORTER REQUEST & OBJECTION TO OFF RECORD HEARING_179CB3AF.PDF
Respectfully submitted, Jason McKemie Respondent, Pro Se 539 W Commerce St, Ste 2010 Dallas, TX 75208 214-868-4901 jmckemie@mckemie.net on C Jason McKemie EXHIBITS ATTACHED (1 Document / 3 Pages): e EXHIBITA STANDING REQUEST FOR COURT REPORTER FOR OCT 31, 2025, HEARING AND ALL SUBSEQUENT PROCEEDINGS NOTICE OF STANDING REQUEST FOR COURT REPORTER / NON-WAIVER 4of4 DF-24-18010 4 of 7 Copy from re:SearchTX
#155
2026-01-05
Respondent / Jason
Notice Of Filing
Page 5
PLEADING_BODY
NOTICE PRIOR COURT REPORTER REQUEST & OBJECTION TO OFF RECORD HEARING_179CB3AF.PDF
10/29/2025 1:13 PM DALLAS CO., TEXAS NOTICE: DOCUMENT CONTAINS DF-24-18010 NO. SENSITIVE INFORMATION. MARRIAGE OF § § & § STANDING FOR COURT REPORTER FOR REQUEST OCT. 31, 2025 HEARING AND ALL SUBSEQUENT PROCEEDINGS I, Jason McKemie, Respondent, appearing pro se, respectfully request that a licensed court reporter be present to record the following proceeding and all future hearings and trial in this cause pursuant to Texas Rule of Appellate Procedure 13.1(a). Requested Proceeding e Date: Friday, October 31, 2025 e Time: 9:30 a.m. e Judge: Hon. Tamika Bha...
#155
2026-01-05
Respondent / Jason
Notice Of Filing
Page 6
CERTIFICATE_OF_SERVICE
NOTICE PRIOR COURT REPORTER REQUEST & OBJECTION TO OFF RECORD HEARING_179CB3AF.PDF
(214) 868-4901 | jmckemie@mckemie.net on Ff Jason McKemie STANDING REQUEST FOR PRESENCE OF COURT REPORTER 2 of 2 Oct. 29%, 2025 | DF-24-18010 6 of 7 CopyCopy fromfrom re:SearchTXre:SearchTX
#155
2026-01-05
Respondent / Jason
Notice Of Filing
Page 7
FILING_STAMP_OR_ESERVICE
NOTICE PRIOR COURT REPORTER REQUEST & OBJECTION TO OFF RECORD HEARING_179CB3AF.PDF
on the date and to the persons listed below. The rules governing Envelope ID: 107432127 Filing Code Description: Notice Of Filing Filing Description: STANDING REQUEST FOR COURT REPORTER FOR OCTOBER 31, 2025 HEARING AND ALL SUBSEQUENT PROCEEDINGS Status as of 10/30/2025 11:39AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Ethan Scroggins escroggins@sullivancook.com 10/29/2025 1:13:21 PM SENT Jason McKemie jmckemie@mckemie.net 10/29/2025 1:13:21 PM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 10/29/2025 1:13:21 PM SENT JASON EMORYM...
#155
2026-01-05
Respondent / Jason
Notice Of Filing
Page 8
FILING_STAMP_OR_ESERVICE
NOTICE PRIOR COURT REPORTER REQUEST & OBJECTION TO OFF RECORD HEARING_179CB3AF.PDF
...nvelope ID: 109629603 Filing Code Description: Notice Of Filing Filing Description: NOTICE OF PRIOR STANDING REQUEST FOR COURT REPORTER/ OFFICIAL RECORD Status as of 1/5/2026 9:00 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 1/4/2026 10:34:26 PM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 1/4/2026 10:34:26 PM SENT JASON EMORYMCKEMIE jason@callvital.com 1/4/2026 10:34:26 PM SENT Copy from re:SearchTX
#
2026-01-05
Respondent / Jason
Motion - Leave
Page 1
PLEADING_START_FILE_MARKED
MOTION FOR LEAVE TO CONDUCT LIMITED POST-CUTOFF_8CFBE77B.pdf
1/5/2026 12:00 AM DALLAS CO., TEXAS PETITIONER'S MOTION FOR LEAVE TO CONDUCT LIMITED POST-CUTOFF DISCOVERY IN THE MATTER OF THE MARRIAGE OF GWENDOLYN ULIJJASZ, Petitioner and JASON McKEMIE, Respondent TO THE HONORABLE JUDGE OF SAID COURT: Petitioner, Gwendolyn Ulijasz, appearing pro se, respectfully moves the Court for leave to conduct limited, targeted discovery after the discovery cutoff established in the Court's Pre- Trial Order and, in support, states as follows: I. PROCEDURAL BACKGROUND 1. This matter is set for final trial on February 24, 2026. 2....
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#
2026-01-05
Respondent / Jason
Motion - Leave
Page 2
PLEADING_BODY
MOTION FOR LEAVE TO CONDUCT LIMITED POST-CUTOFF_8CFBE77B.pdf
...ative electronic format, for mail addressed to Petitioner individually or jointly with Respondent that was received either directly or by "forward" into McKemie Mailbox 1015 during calendar year 2024 and 2025. No opening of mail or content beyond envelope/package exterior is requested. Copy from re:SearchTX
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#
2026-01-05
Respondent / Jason
Motion - Leave
Page 3
PLEADING_BODY
MOTION FOR LEAVE TO CONDUCT LIMITED POST-CUTOFF_8CFBE77B.pdf
9. Each proposed subpoena requests production with a custodian of records affidavit to streamline admissibility at trial. IV. GOOD CAUSE FOR LEAVE OF COURT 10. Good cause exists to permit this limited discovery because: a. The records were previously requested but not produced; b. Petitioner was excluded from access to the underlying accounts, records, and residence; c. A substantially similar subpoena covering calendar year 2024 was previously authorized by the 254th Court and complied with by the same mailbox provider; d. The requested discovery is pro...
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#
2026-01-05
Respondent / Jason
Motion - Leave
Page 4
FILING_STAMP_OR_ESERVICE
MOTION FOR LEAVE TO CONDUCT LIMITED POST-CUTOFF_8CFBE77B.pdf
on the date and to the persons listed below. The rules governing Envelope ID: 109623023 Filing Code Description: Motion - Leave Filing Description: Status as of 1/5/2026 8:49 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 1/3/2026 9:16:51 AM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 1/3/2026 9:16:51 AM SENT JASON EMORYMCKEMIE jason@callvital.com 1/3/2026 9:16:51 AM SENT Copy from re:SearchTX
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#
2026-01-05
Respondent / Jason
Motion - Leave
Page 1
PLEADING_START_FILE_MARKED
MOTION FOR LEAVE TO CONDUCT LIMITED POST-CUTOFF.pdf
1/5/2026 12:00 AM DALLAS CO., TEXAS PETITIONER'S MOTION FOR LEAVE TO CONDUCT LIMITED POST-CUTOFF DISCOVERY IN THE MATTER OF THE MARRIAGE OF GWENDOLYN ULIJJASZ, Petitioner and JASON McKEMIE, Respondent TO THE HONORABLE JUDGE OF SAID COURT: Petitioner, Gwendolyn Ulijasz, appearing pro se, respectfully moves the Court for leave to conduct limited, targeted discovery after the discovery cutoff established in the Court's Pre- Trial Order and, in support, states as follows: I. PROCEDURAL BACKGROUND 1. This matter is set for final trial on February 24, 2026. 2....
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#
2026-01-05
Respondent / Jason
Motion - Leave
Page 2
PLEADING_BODY
MOTION FOR LEAVE TO CONDUCT LIMITED POST-CUTOFF.pdf
...ative electronic format, for mail addressed to Petitioner individually or jointly with Respondent that was received either directly or by "forward" into McKemie Mailbox 1015 during calendar year 2024 and 2025. No opening of mail or content beyond envelope/package exterior is requested. Copy from re:SearchTX
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#
2026-01-05
Respondent / Jason
Motion - Leave
Page 3
PLEADING_BODY
MOTION FOR LEAVE TO CONDUCT LIMITED POST-CUTOFF.pdf
9. Each proposed subpoena requests production with a custodian of records affidavit to streamline admissibility at trial. IV. GOOD CAUSE FOR LEAVE OF COURT 10. Good cause exists to permit this limited discovery because: a. The records were previously requested but not produced; b. Petitioner was excluded from access to the underlying accounts, records, and residence; c. A substantially similar subpoena covering calendar year 2024 was previously authorized by the 254th Court and complied with by the same mailbox provider; d. The requested discovery is pro...
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#
2026-01-05
Respondent / Jason
Motion - Leave
Page 4
FILING_STAMP_OR_ESERVICE
MOTION FOR LEAVE TO CONDUCT LIMITED POST-CUTOFF.pdf
on the date and to the persons listed below. The rules governing Envelope ID: 109623023 Filing Code Description: Motion - Leave Filing Description: Status as of 1/5/2026 8:49 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 1/3/2026 9:16:51 AM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 1/3/2026 9:16:51 AM SENT JASON EMORYMCKEMIE jason@callvital.com 1/3/2026 9:16:51 AM SENT Copy from re:SearchTX
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