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2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 1
PLEADING_START_FILE_MARKED
RESPONDENT'S EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
1/12/2026 3:52 AM DALLAS CO., TEXAS NO. DF-24-18010 NOTICE: THIS DOCUMENT CONTAINS SENSITIVE MATERIALS THE MARRIAGE OF § § GWENDOLVN ULIJASZ § 302"? jupiciAL DISTRICT & § APPLICATION FOR EMERGENCY TRO FOR IMMEDIATE TEMPORARY SUPPORT TO PREVENT IMMINENT EVICTION, RESTORE HEALTHCARE ACCESS, AND MAINTAIN STATUS QUO TO THE HONORABLE JUDGE PRESIDING: COMES NOW, Respondent, Jason McKemie, pro se, and files this EMERGENCY APPLICATION FOR TRO FOR URGENT TEMPORARY SUPPORT TO PREVENT EVICTION AND MAINTAIN STATUS QUO, and respectfully shows the Court as follows: l....
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2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 2
CERTIFICATE_OF_COMPLIANCE
RESPONDENT'S EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
...der. 7. Approximately 19 False Police Reports Discovered thus far, one indicating the acquisition of a firearm Petitioner is carrying without a license to carry. DF-24-18010 2 of 13 Copy from re:SearchTX
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2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 3
PLEADING_BODY
RESPONDENT'S EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
...cessary: Any necessary removal or storage shall occur only by mutual agreement or a neutral third party and shall not constitute abandonment or waiver of claims. DF-24-18010 3 of 13 Copy from re:SearchTX
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2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 4
CERTIFICATE_OF_COMPLIANCE
RESPONDENT'S EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
...t imposed as punishment or as a determination of Petitioner's motive or intent. 2. CONDITIONAL BAD-FAITH/OBSTRUCTION COERCIVE INCENTIVES (¥ Check All That Apply) DF-24-18010 4 of 13 Copy from re:SearchTX
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2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 5
PLEADING_BODY
RESPONDENT'S EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
...rference with Respondent's housing stability, access to funds, or medical care pending return hearing, and shall accrue for each day such interference continues. DF-24-18010 5 of 13 Copy from re:SearchTX
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2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 6
DECLARATION
RESPONDENT'S EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
...nt the Temporary Restraining Order as requested and set an expedited return hearing. Respectfully submitted, Jason McKemie Respondent, Pro Se 539 W. Commerce St., Suite 2010 Dallas, Texas 75208 (214) 868-4901 jmckemie@mckemie.net EXHIBITS: e Exhibit A: Eviction judgment/notice (deadlines) e Exhibit B: Respondent's Unsworn Declaration EXHIBIT C: Ameriprise Statement DF-24-18010 6 of 13 Copy from re:SearchTX
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2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 7
PLEADING_BODY
RESPONDENT'S EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
DF-24-18010 THE MARRIAGE OF § § & ON EMERGENCY REINSTATEMENT OF HEALTHCARE On this day, the Court considered Jason McKemie's (Respondent's) Emergency Motion regarding reinstatement of healthcare coverage. The Court finds immediate relief is necessary to prevent medical har : IT1S RDERED: |. COMPLIANCE PATH (PETITIONER MUST CHOSE AND COMPLETE ONE PATH) 1. Within twenty-four (24) hours of the signing of this Order, Petitioner shall complete one of the following two compliance paths and provide Respondent written proof of completion (email is sufficient). O...
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2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 8
PLEADING_BODY
RESPONDENT'S EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
...nths): $2,684.56 (Medical $609.23 + Dental $55.32 + Vision $6.59, multiplied by four months), and 2. HSA/FSA replacement amounts totaling $17,959.00 (2025 HSA $5,959.00; 2026 HSA $6,000.00; 2025 FSA $3,000.00; 2026 FSA $3,000.00). IV. NON-INTERFERENCE A. Petitioner shall not interfere with, restrict, disable, or obstruct Respondent's access to healthcare coverage, prescriptions, or medical care pending further order of the Court. V. ENFORCEMENT AND PAYMENT DEADLINES A. to timely complete Option A or Option B (in ding written proof and/or required Prilure...
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2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 9
PLEADING_BODY
RESPONDENT'S EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
favor of Respondent in an amount equivalent to two (2) weeks of Petitioner's total grass compensation, including base'salary, bonuses, cashincentives, equity compensation, deferred compensation, and employer-provided remuneration of any Rind. Petitioner shall deposit that amount into joint ascount ending XX6893within seventy-two (72) hours of the noncompliance trigger. !f not deposited on time, a coercive fine of $1,000 per day shall accrue until paid in full. D. Future interference The same remedies apply to any future interference with Respondent"s acc...
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2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 10
EXHIBIT_START
RESPONDENT'S EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
...oyer plan administrator asserting that the divorce was finalized and that a judicially signed final decree existed. No final decree exists. Trial is set for February 24, 2026. 4. Regardless of what any benefits portal may display, my coverage has been functionally unreliable and non-usable in practice, including denial of pharmacy processing and inability to obtain prescriptions and medically necessary care. The interruption has shifted tens of thousands of dollars of deductibles and copays onto me at the worst possible time. My out-of- pocket maximum ha...
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2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 11
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
...ivan & Cook. Petitioner testified on or about October 31, 2025 that she ceased and/or withdrew from VEIP. This leaves two mutually exclusive outcomes as follows: DF-24-18010 11 of 13 Copy from re:SearchTX
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2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 12
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
...te temporary support is infeasible due to lack of funds is not accurate. | declare under penalty of perjury that the foregoing is true and correct. Jason McKemie DF-24-18010 12 of 13 Copy from re:SearchTX
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2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 13
EXHIBIT_START
RESPONDENT'S EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
...ut OCCA: ees Aah MoS Quali 210 Weep& « Make & transfer a Undate account nicknames Portfolia Progress September 2025 : : : rematt planner Henney pou cet A ti itis DF-24-18010 13 of 13 Copy from re:SearchTX
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2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 14
FILING_STAMP_OR_ESERVICE
RESPONDENT'S EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
...sted below. The rules governing Envelope ID: 109910601 Filing Code Description: Application - Temporary Restraining Order Filing Description: EMERGENCY Status as of 1/15/2026 9:33 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 1/12/2026 3:52:22 AM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 1/12/2026 3:52:22 AM SENT Copy from re:SearchTX
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2026-01-12
Respondent / Jason
Objections - Misc
Page 1
PLEADING_START_FILE_MARKED
PETITIONER'S OBJECTION AND EMERGENCY MOTION TO STRIKE_933E74F1.pdf
1/12/2026 8:53 AM DALLAS CO., TEXAS NO. DF-24-18010 IN THE MATTER OF THE MARRIAGE OF GWENDOLYN ULIJASZ-MCKEMIE, Petitioner and JASON MCKEMIE, Respondent PETITIONER'S OBJECTION TO EX PARTE CONSIDERATION, AND EMERGENCY MOTION TO STRIKE OR, IN THE ALTERNATIVE, SET FOR NOTICED HEARING WITH REMOTE APPEARANCE TO THE HONORABLE JUDGE OF SAID COURT: Petitioner, Gwendolyn Ulijasz-Mckemie, files this Objection to Ex Parte Consideration of Respondent's "Emergency Motion to Stay Eviction Proceedings, Extend Rent Registry Deadline, and Prevent Irreparable Harm Due to...
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2026-01-12
Respondent / Jason
Objections - Misc
Page 2
PROPOSED_ORDER_OR_ORDER
PETITIONER'S OBJECTION AND EMERGENCY MOTION TO STRIKE_933E74F1.pdf
Il. THE MOTION SEEKS MERITS-BASED RELIEF UNDER THE GUISE OF "NON-MERITS" Although Respondent characterizes the motion as "temporary" and "non-merits," the requested relief would: e Toll or excuse statutory rent registry requirements; e Reallocate rent obligations to Petitioner without adjudication; e Stay eviction proceedings already governed by landlord-tenant law; and e Prohibit Petitioner from entering or accessing property and personal effects. These requests go well beyond preservation of the status quo and constitute merits-based relief that cannot...
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2026-01-12
Respondent / Jason
Objections - Misc
Page 3
CERTIFICATE_OF_SERVICE
PETITIONER'S OBJECTION AND EMERGENCY MOTION TO STRIKE_933E74F1.pdf
VI. REQUEST FOR NOTICED HEARING AND REMOTE APPEARANCE If the Court determines that any portion of Respondent's motion warrants consideration, Petitioner respectfully requests that the matter be set for a noticed hearing. Petitioner again further requests permission to appear by Zoom or other remote means, as and cannot reasonably appear in person on short notice. Remote appearance will ensure fairness, due process, and efficient resolution without prejudice to any party and allow her to keep her day job in good standing. VII. PRAYER WHEREFORE, PREMISES C...
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2026-01-12
Respondent / Jason
Objections - Misc
Page 4
FILING_STAMP_OR_ESERVICE
PETITIONER'S OBJECTION AND EMERGENCY MOTION TO STRIKE_933E74F1.pdf
...listed below. The rules governing Envelope ID: 109914676 Filing Code Description: Objections - Misc Filing Description: AND EMERGENCY MOTION TO STRIKE Status as of 1/14/2026 2:51 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 1/12/2026 8:53:21 AM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 1/12/2026 8:53:21 AM SENT Gwendolyn Ulijasz gulijasz@gmail.com 1/12/2026 8:53:21 AM SENT JASON EMORYMCKEMIE jason@callvital.com 1/12/2026 8:53:21 AM SENT Copy from re:SearchTX
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#167
2026-01-12
Respondent / Jason
Objections - Misc
Page 1
PLEADING_START_FILE_MARKED
OBJECTION AND EMERGENCY MOTION TO STRIKE_933E74F1.pdf
1/12/2026 8:53 AM DALLAS CO., TEXAS NO. DF-24-18010 IN THE MATTER OF THE MARRIAGE OF GWENDOLYN ULIJASZ-MCKEMIE, Petitioner and JASON MCKEMIE, Respondent PETITIONER'S OBJECTION TO EX PARTE CONSIDERATION, AND EMERGENCY MOTION TO STRIKE OR, IN THE ALTERNATIVE, SET FOR NOTICED HEARING WITH REMOTE APPEARANCE TO THE HONORABLE JUDGE OF SAID COURT: Petitioner, Gwendolyn Ulijasz-Mckemie, files this Objection to Ex Parte Consideration of Respondent's "Emergency Motion to Stay Eviction Proceedings, Extend Rent Registry Deadline, and Prevent Irreparable Harm Due to...
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#167
2026-01-12
Respondent / Jason
Objections - Misc
Page 2
PROPOSED_ORDER_OR_ORDER
OBJECTION AND EMERGENCY MOTION TO STRIKE_933E74F1.pdf
Il. THE MOTION SEEKS MERITS-BASED RELIEF UNDER THE GUISE OF "NON-MERITS" Although Respondent characterizes the motion as "temporary" and "non-merits," the requested relief would: e Toll or excuse statutory rent registry requirements; e Reallocate rent obligations to Petitioner without adjudication; e Stay eviction proceedings already governed by landlord-tenant law; and e Prohibit Petitioner from entering or accessing property and personal effects. These requests go well beyond preservation of the status quo and constitute merits-based relief that cannot...
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#167
2026-01-12
Respondent / Jason
Objections - Misc
Page 3
CERTIFICATE_OF_SERVICE
OBJECTION AND EMERGENCY MOTION TO STRIKE_933E74F1.pdf
VI. REQUEST FOR NOTICED HEARING AND REMOTE APPEARANCE If the Court determines that any portion of Respondent's motion warrants consideration, Petitioner respectfully requests that the matter be set for a noticed hearing. Petitioner again further requests permission to appear by Zoom or other remote means, as and cannot reasonably appear in person on short notice. Remote appearance will ensure fairness, due process, and efficient resolution without prejudice to any party and allow her to keep her day job in good standing. VII. PRAYER WHEREFORE, PREMISES C...
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#167
2026-01-12
Respondent / Jason
Objections - Misc
Page 4
FILING_STAMP_OR_ESERVICE
OBJECTION AND EMERGENCY MOTION TO STRIKE_933E74F1.pdf
...listed below. The rules governing Envelope ID: 109914676 Filing Code Description: Objections - Misc Filing Description: AND EMERGENCY MOTION TO STRIKE Status as of 1/14/2026 2:51 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 1/12/2026 8:53:21 AM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 1/12/2026 8:53:21 AM SENT Gwendolyn Ulijasz gulijasz@gmail.com 1/12/2026 8:53:21 AM SENT JASON EMORYMCKEMIE jason@callvital.com 1/12/2026 8:53:21 AM SENT Copy from re:SearchTX
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#
2026-01-12
Respondent / Jason
Objections - Misc
Page 1
PLEADING_START_FILE_MARKED
OBJECTION AND EMERGENCY MOTION TO STRIKE.pdf
1/12/2026 8:53 AM DALLAS CO., TEXAS NO. DF-24-18010 IN THE MATTER OF THE MARRIAGE OF GWENDOLYN ULIJASZ-MCKEMIE, Petitioner and JASON MCKEMIE, Respondent PETITIONER'S OBJECTION TO EX PARTE CONSIDERATION, AND EMERGENCY MOTION TO STRIKE OR, IN THE ALTERNATIVE, SET FOR NOTICED HEARING WITH REMOTE APPEARANCE TO THE HONORABLE JUDGE OF SAID COURT: Petitioner, Gwendolyn Ulijasz-Mckemie, files this Objection to Ex Parte Consideration of Respondent's "Emergency Motion to Stay Eviction Proceedings, Extend Rent Registry Deadline, and Prevent Irreparable Harm Due to...
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2026-01-12
Respondent / Jason
Objections - Misc
Page 2
PROPOSED_ORDER_OR_ORDER
OBJECTION AND EMERGENCY MOTION TO STRIKE.pdf
Il. THE MOTION SEEKS MERITS-BASED RELIEF UNDER THE GUISE OF "NON-MERITS" Although Respondent characterizes the motion as "temporary" and "non-merits," the requested relief would: e Toll or excuse statutory rent registry requirements; e Reallocate rent obligations to Petitioner without adjudication; e Stay eviction proceedings already governed by landlord-tenant law; and e Prohibit Petitioner from entering or accessing property and personal effects. These requests go well beyond preservation of the status quo and constitute merits-based relief that cannot...
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2026-01-12
Respondent / Jason
Objections - Misc
Page 3
CERTIFICATE_OF_SERVICE
OBJECTION AND EMERGENCY MOTION TO STRIKE.pdf
VI. REQUEST FOR NOTICED HEARING AND REMOTE APPEARANCE If the Court determines that any portion of Respondent's motion warrants consideration, Petitioner respectfully requests that the matter be set for a noticed hearing. Petitioner again further requests permission to appear by Zoom or other remote means, as and cannot reasonably appear in person on short notice. Remote appearance will ensure fairness, due process, and efficient resolution without prejudice to any party and allow her to keep her day job in good standing. VII. PRAYER WHEREFORE, PREMISES C...
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#
2026-01-12
Respondent / Jason
Objections - Misc
Page 4
FILING_STAMP_OR_ESERVICE
OBJECTION AND EMERGENCY MOTION TO STRIKE.pdf
...listed below. The rules governing Envelope ID: 109914676 Filing Code Description: Objections - Misc Filing Description: AND EMERGENCY MOTION TO STRIKE Status as of 1/14/2026 2:51 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 1/12/2026 8:53:21 AM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 1/12/2026 8:53:21 AM SENT Gwendolyn Ulijasz gulijasz@gmail.com 1/12/2026 8:53:21 AM SENT JASON EMORYMCKEMIE jason@callvital.com 1/12/2026 8:53:21 AM SENT Copy from re:SearchTX
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#173
2026-01-12
Respondent / Jason
Motion - Miscellaneous IN
Page 1
PLEADING_START_FILE_MARKED
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
1/12/2026 2:22 AM DALLAS CO., TEXAS NOTICE: DOCUMENT CONTAINS DF-24-18010 NO. SENSITIVE INFORMATION. MARRIAGE OF § § & § EMERGENCY MOTION TO TEMPORARILY STAY OR, IN THE ALTERNATIVE, IMPOSE PROTECTIVE CONDITIONS ON COURT- AUTHORIZED PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY TO THE HONORABLE JUDGE OF SAID COURT: Jason McKemie respectfully moves for emergency relief to prevent irreparable and irreversible harm arising from a scheduled property retrieval or "clean-out" on January 17th, 2026, while Mr. McKemie is medically incapacitated and anticipating in...
#173
2026-01-12
Respondent / Jason
Motion - Miscellaneous IN
Page 2
PLEADING_BODY
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
...d strictly to personal effects. Only items on the list may be removed. 5. DEFINED SCOPE; EXCLUDED CATEGORIES AND AREAS. EMERGENCY MOTION TO TEMPORARILY STAY 2of5 DF-24-18010 Copy from re:SearchTX
#173
2026-01-12
Respondent / Jason
Motion - Miscellaneous IN
Page 3
PLEADING_BODY
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
...ification of the system. The cameras have operated continuously in this manner since August 2023. G. PRESERVATION OF PROPERTY IN EVENT OF EVICTION OR LOSS OF POSSESSION. 12. Inthe event Respondent is dispossessed of the residence for any reason, including eviction or execution of a writ of possession, Respondent requests an order expressly prohibiting Petitioner from entering the premises or removing any personal or marital property, and directing that any EMERGENCY MOTION TO TEMPORARILY STAY 3of5 DF-24-18010 Copy from re:SearchTX
#173
2026-01-12
Respondent / Jason
Motion - Miscellaneous IN
Page 4
PLEADING_BODY
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
...at repeated risk of law-enforcement involvement and false accusation. 16. FIREARM NOW PRESENT IN THE FACTUAL LANDSCAPE. EMERGENCY MOTION TO TEMPORARILY STAY 4of5 DF-24-18010 Copy from re:SearchTX
#173
2026-01-12
Respondent / Jason
Motion - Miscellaneous IN
Page 5
FILING_STAMP_OR_ESERVICE
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
...W. Commerce St., Ste. 2010 Dallas, Texas 75208 (214) 868-4901 jmckemie@mckemie.net File, and additionally by TX E-FILE, EMAIL (gulijasz@gmail.com), and on January 11th, 2026 at or about 8:30PM CST. Jason McKemie EMERGENCY MOTION TO TEMPORARILY STAY 5 of 5 DF-24-18010 Copy from re:SearchTX
#173
2026-01-12
Respondent / Jason
Motion - Miscellaneous IN
Page 6
PLEADING_BODY
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
NOTICE: DOCUMENT CONTAINS DF-24-18010 NO. SENSITIVE INFORMATION. MARRIAGE OF § (PROPOSED) ORDER ON EMERGENCY MOTION TO TEMPORARILY STAY OR IMPOSE PROTECTIVE CONDITIONS ON PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY On this day, the Court considered Jason McKemie's Emergency Motion to Temporarily Stay or, in the Alternative, Impose Protective Conditions on Court-Authorized Property Retrieval. The Court finds that emergency relief is warranted to prevent irreparable harm, preserve the status quo, and protect the integrity of the proceedings, and that Resp...
#173
2026-01-12
Respondent / Jason
Motion - Miscellaneous IN
Page 7
PLEADING_BODY
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
...no action to remove, destroy, conceal, alter, or transfer any household property pending further order of the Court. EMERGENCY MOTION TO TEMPORARILY STAY 2 of 4 DF-24-18010 Copy from re:SearchTX
#173
2026-01-12
Respondent / Jason
Motion - Miscellaneous IN
Page 8
PLEADING_BODY
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
C. SECURITY CAMERA STATUS QUO 12. No Alteration to Existing Security System. The residence is equipped with security cameras that automatically record upon detection of motion and/or sound. These cameras operated in this manner throughout the marriage and were installed in response to Petitioner's prior safety representations. a. No changes have been made to the system's configuration, scope, or operation. b. The system shall remain in status quo condition. c. No unauthorized surveillance, monitoring, or modification has occurred or is permitted. - D. ES...
#173
2026-01-12
Respondent / Jason
Motion - Miscellaneous IN
Page 9
PLEADING_BODY
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
...urt-imposed structure, supervision, and finality. G. CONTINUING JURISDICTION 17.. This Order shall remain in effect until further order of the Court. SIGNED on January » 2026 at : am / pm (Circle One). JUDGE PRESIDING EMERGENCY MOTION TO TEMPORARILY STAY 4 of 4 DF-24-18010 Copy from re:SearchTX
#173
2026-01-12
Respondent / Jason
Motion - Miscellaneous IN
Page 10
FILING_STAMP_OR_ESERVICE
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
...ion: EMERGENCY MOTION TO TEMORARY STAY OR THE ALTERNATIVE IMPOSE PROTECTIVE CONDITIONS ON COURT-AUTHORIZED PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY Status as of 1/13/2026 4:18 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 1/12/2026 2:22:00 AM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 1/12/2026 2:22:00 AM SENT JASON EMORYMCKEMIE jason@callvital.com 1/12/2026 2:22:00 AM SENT Copy from re:SearchTX
#
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 1
PLEADING_START_FILE_MARKED
FNL DF-24-18010 - MOTION - TRO.pdf copy.pdf
1/12/2026 3:52 AM DALLAS CO., TEXAS NO. DF-24-18010 NOTICE: THIS DOCUMENT CONTAINS SENSITIVE MATERIALS THE MARRIAGE OF § § & § APPLICATION FOR EMERGENCY TRO FOR IMMEDIATE TEMPORARY SUPPORT TO PREVENT IMMINENT EVICTION, RESTORE HEALTHCARE ACCESS, AND MAINTAIN STATUS QUO TO THE HONORABLE JUDGE PRESIDING: COMES NOW, Respondent, Jason McKemie, pro se, and files this EMERGENCY APPLICATION FOR TRO FOR URGENT TEMPORARY SUPPORT TO PREVENT EVICTION AND MAINTAIN STATUS QUO, and respectfully shows the Court as follows: I. INTRODUCTION & EMERGENCY NATURE Respondent...
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2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 2
CERTIFICATE_OF_COMPLIANCE
FNL DF-24-18010 - MOTION - TRO.pdf copy.pdf
...der. 7. Approximately 19 False Police Reports Discovered thus far, one indicating the acquisition of a firearm Petitioner is carrying without a license to carry. DF-24-18010 2 of 13
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#
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 3
PLEADING_BODY
FNL DF-24-18010 - MOTION - TRO.pdf copy.pdf
...cessary: Any necessary removal or storage shall occur only by mutual agreement or a neutral third party and shall not constitute abandonment or waiver of claims. DF-24-18010 3 of 13
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#
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 4
CERTIFICATE_OF_COMPLIANCE
FNL DF-24-18010 - MOTION - TRO.pdf copy.pdf
...ot imposed as punishment or as a determination of Petitioner’s motive or intent. 2. CONDITIONAL BAD-FAITH/OBSTRUCTION COERCIVE INCENTIVES ( Check All That Apply) DF-24-18010 4 of 13
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#
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 5
PLEADING_BODY
FNL DF-24-18010 - MOTION - TRO.pdf copy.pdf
...rference with Respondent’s housing stability, access to funds, or medical care pending return hearing, and shall accrue for each day such interference continues. DF-24-18010 5 of 13
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#
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 6
DECLARATION
FNL DF-24-18010 - MOTION - TRO.pdf copy.pdf
...nt the Temporary Restraining Order as requested and set an expedited return hearing. Respectfully submitted, Jason McKemie Respondent, Pro Se 539 W. Commerce St., Suite 2010 Dallas, Texas 75208 (214) 868-4901 jmckemie@mckemie.net EXHIBITS: • Exhibit A: Eviction judgment/notice (deadlines) • Exhibit B: Respondent’s Unsworn Declaration • EXHIBIT C: Ameriprise Statement DF-24-18010 6 of 13
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2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 7
PLEADING_BODY
FNL DF-24-18010 - MOTION - TRO.pdf copy.pdf
7 of 13
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#
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 8
PLEADING_BODY
FNL DF-24-18010 - MOTION - TRO.pdf copy.pdf
8 of 13
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#
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 9
PLEADING_BODY
FNL DF-24-18010 - MOTION - TRO.pdf copy.pdf
9 of 13
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#
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 10
EXHIBIT_START
FNL DF-24-18010 - MOTION - TRO.pdf copy.pdf
...oyer plan administrator asserting that the divorce was finalized and that a judicially signed final decree existed. No final decree exists. Trial is set for February 24, 2026. 4. Regardless of what any benefits portal may display, my coverage has been functionally unreliable and non-usable in practice, including denial of pharmacy processing and inability to obtain prescriptions and medically necessary care. The interruption has shifted tens of thousands of dollars of deductibles and copays onto me at the worst possible time. My out-of- pocket maximum ha...
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#
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 11
EXHIBIT_CONTINUATION
FNL DF-24-18010 - MOTION - TRO.pdf copy.pdf
...& Cook. § Petitioner testified on or about October 31, 2025 that she ceased and/or withdrew from VEIP. § This leaves two mutually exclusive outcomes as follows: DF-24-18010 11 of 13
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2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 12
EXHIBIT_CONTINUATION
FNL DF-24-18010 - MOTION - TRO.pdf copy.pdf
...te temporary support is infeasible due to lack of funds is not accurate. I declare under penalty of perjury that the foregoing is true and correct. Jason McKemie DF-24-18010 12 of 13
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2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 13
EXHIBIT_START
FNL DF-24-18010 - MOTION - TRO.pdf copy.pdf
EXHIBIT C DF-24-18010 13 of 13
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2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 14
FILING_STAMP_OR_ESERVICE
FNL DF-24-18010 - MOTION - TRO.pdf copy.pdf
...sted below. The rules governing Envelope ID: 109910601 Filing Code Description: Application - Temporary Restraining Order Filing Description: EMERGENCY Status as of 1/15/2026 9:33 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 1/12/2026 3:52:22 AM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 1/12/2026 3:52:22 AM SENT
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#175
2026-01-12
Respondent / Jason
Motion - Stay
Page 1
PLEADING_START_FILE_MARKED
EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS_BEE80C57.pdf
1/12/2026 3:03 AM DALLAS CO., TEXAS NOTICE: DOCUMENT CONTAINS DF-24-18010 NO. SENSITIVE INFORMATION. MARRIAGE OF § § & § EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS, EXTEND RENT REGISTRY DEADLINE, AND PREVENT IRREPARABLE HARM DUE TO MEDICAL INCAPACITY (NON-MERITS REQUEST) TO THE HONORABLE JUDGE OF SAID COURT: Respondent, Jason McKemie, files this Emergency Motion to Stay Eviction Proceedings, Extend the Rent Registry Deadline, and Prevent Irreparable Harm Due to Medical Incapacity. This motion is temporary, narrowly tailored, and non-merits based. Resp...
#175
2026-01-12
Respondent / Jason
Motion - Stay
Page 2
PLEADING_BODY
EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS_BEE80C57.pdf
...ity to prevent eviction proceedings from undermining parallel court orders or creating inconsistent outcomes. V. NARROW RELIEF REQUESTED (NO MERITS ADJUDICATION) DF-24-18010 2 of 4 Copy from re:SearchTX
#175
2026-01-12
Respondent / Jason
Motion - Stay
Page 3
PLEADING_BODY
EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS_BEE80C57.pdf
...thereafter; 11. Extension of the rent registry deadline for a reasonable period to allow medical stabilization and receipt of court-ordered funds; OR, IN THE ALTERNATIVE 12. Stay of execution as to possession and personal property only, prohibiting removal during hospitalization; 13. Preservation of property, prohibiting removal by Petitioner and directing landlord-controlled inventory and storage if possession changes. VI. EQUITABLE ALLOCATION OF RENT DURING COURT-ORDERED PAYMENT DELAY 14. Equitable Allocation of Rent During Court-Ordered Payment Delay....
#175
2026-01-12
Respondent / Jason
Motion - Stay
Page 4
PLEADING_BODY
EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS_BEE80C57.pdf
...t grant this Emergency Motion and such other and further relief as justice requires. Respectfully submitted, Jason McKemie Respondent, Pro Se 539 W. Commerce St., Suite 2010 Dallas, Texas 75208 21 868-4901 jmckemie@mckemie.net DF-24-18010 4 of 4 Copy from re:SearchTX
#175
2026-01-12
Respondent / Jason
Motion - Stay
Page 5
PROPOSED_ORDER_OR_ORDER
EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS_BEE80C57.pdf
NOTICE: DOCUMENT CONTAINS DF-24-18010 NO. SENSITIVE INFORMATION. MARRIAGE OF § § & § (PROPOSED) ORDER ON EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS, EXTEND RENT REGISTRY DEADLINE, AND PRESERVE PROPERTY On this day, the Court considered Jason McKemie's Emergency Motion to Stay Eviction Proceedings, Extend Rent Registry Deadline, and Prevent Irreparable Harm. The Court finds that emergency relief is warranted to prevent irreparable harm, preserve the status quo, and protect the integrity of the proceedings, and that Respondent's medical incapacity furth...
#175
2026-01-12
Respondent / Jason
Motion - Stay
Page 6
PLEADING_BODY
EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS_BEE80C57.pdf
...he landlord or lawful authority, with written inventory preserved. E. CONTINUING JURISDICTION 7. This Order remains in effect until further order of the Court. SIGNED on 2026 at O a.m. 0J p.m. JUDGE PRESIDING DF-24-18010 6 of 4 Copy from re:SearchTX
#175
2026-01-12
Respondent / Jason
Motion - Stay
Page 7
FILING_STAMP_OR_ESERVICE
EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS_BEE80C57.pdf
...ow. The rules governing Envelope ID: 109910402 Filing Code Description: Motion - Stay Filing Description: EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS Status as of 1/13/2026 8:43 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 1/12/2026 3:03:02 AM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 1/12/2026 3:03:02 AM SENT Copy from re:SearchTX
#164
2026-01-12
Respondent / Jason
Motion - Miscellaneous
Page 1
PLEADING_START_FILE_MARKED
EMERGENCY MOTION ON MEDICAL HARM_8BE697F0.pdf
1/12/2026 5:26 AM DALLAS CO., TEXAS NOTICE: DOCUMENT CONTAINS DF-24-18010 NO. SENSITIVE INFORMATION. MARRIAGE OF & EMERGENCY MOTION FOR MEDICAL PRESERVATION, INTERIM MAKE-WHOLE RELIEF, JUDICIAL FINDINGS OF MISREPRESENTATION/IMPOSSIBILITY, CONDITIONAL SANCTIONS, AND THIRD-PARTY SUBPOENA AUTHORITY (QLE RECORDS) Respondent, Jason McKemie, files this Emergency Motion because he has suffered actual, ongoing medical harm due to abrupt loss of healthcare and prescription access, and because Petitioner's asserted "compliance" is materially inconsistent with obje...
#164
2026-01-12
Respondent / Jason
Motion - Miscellaneous
Page 2
PLEADING_BODY
EMERGENCY MOTION ON MEDICAL HARM_8BE697F0.pdf
...replacement requires primary-holder authentication and/or PIN; and Respondent cannot upload documentation or use funds without access that Petitioner refuses to provide. 12. Respondent's physical HSA card does not function for qualified transactions. Result: Petitioner's compliance theory demands acts that are technically impossible for Respondent to perform under current system restrictions. IV. JUDICIAL FINDINGS ARE NECESSARY NOW A. Respondent is not asking the Court to determine intent today. Respondent asks the Court to make limited findings that: EM...
#164
2026-01-12
Respondent / Jason
Motion - Miscellaneous
Page 3
PLEADING_BODY
EMERGENCY MOTION ON MEDICAL HARM_8BE697F0.pdf
...ine whether material misrepresentations were made to the Court and whether compliance was obstructed. EMERGECY MOTION: MEDICAL HARMS & RESERVATION OF RIGHTS 3of5 DF-24-18010 Copy from re:SearchTX
#164
2026-01-12
Respondent / Jason
Motion - Miscellaneous
Page 4
PLEADING_BODY
EMERGENCY MOTION ON MEDICAL HARM_8BE697F0.pdf
...sion package and audit trail, and order expedited production within 10 days. E. Conditional Sanctions EMERGECY MOTION: MEDICAL HARMS & RESERVATION OF RIGHTS 4of5 DF-24-18010 Copy from re:SearchTX
#164
2026-01-12
Respondent / Jason
Motion - Miscellaneous
Page 5
FILING_STAMP_OR_ESERVICE
EMERGENCY MOTION ON MEDICAL HARM_8BE697F0.pdf
...the Court grant the requested relief. Respectfully submitted, Son [KL Jason McKemie 539 W Commerce St., Ste. 2010, Dallas, TX 75208 (214) 868-4901 | jmckemie@mckemie.net 2026. Jason McKemie EMERGECY MOTION: MEDICAL HARMS & RESERVATION OF RIGHTS 5of5 DF-24-18010 Copy from re:SearchTX
#164
2026-01-12
Respondent / Jason
Motion - Miscellaneous
Page 6
FILING_STAMP_OR_ESERVICE
EMERGENCY MOTION ON MEDICAL HARM_8BE697F0.pdf
...below. The rules governing Envelope ID: 109911090 Filing Code Description: Motion - Miscellaneous Filing Description: EMERGENCY MOTION ON MEDICAL HARM Status as of 1/15/2026 12:00 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 1/12/2026 5:26:49 AM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 1/12/2026 5:26:49 AM SENT Copy from re:SearchTX
#165
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 1
PLEADING_START_FILE_MARKED
EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
1/12/2026 3:52 AM DALLAS CO., TEXAS NO. DF-24-18010 NOTICE: THIS DOCUMENT CONTAINS SENSITIVE MATERIALS THE MARRIAGE OF § § GWENDOLVN ULIJASZ § 302"? jupiciAL DISTRICT & § APPLICATION FOR EMERGENCY TRO FOR IMMEDIATE TEMPORARY SUPPORT TO PREVENT IMMINENT EVICTION, RESTORE HEALTHCARE ACCESS, AND MAINTAIN STATUS QUO TO THE HONORABLE JUDGE PRESIDING: COMES NOW, Respondent, Jason McKemie, pro se, and files this EMERGENCY APPLICATION FOR TRO FOR URGENT TEMPORARY SUPPORT TO PREVENT EVICTION AND MAINTAIN STATUS QUO, and respectfully shows the Court as follows: l....
#165
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 2
CERTIFICATE_OF_COMPLIANCE
EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
...der. 7. Approximately 19 False Police Reports Discovered thus far, one indicating the acquisition of a firearm Petitioner is carrying without a license to carry. DF-24-18010 2 of 13 Copy from re:SearchTX
#165
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 3
PLEADING_BODY
EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
...cessary: Any necessary removal or storage shall occur only by mutual agreement or a neutral third party and shall not constitute abandonment or waiver of claims. DF-24-18010 3 of 13 Copy from re:SearchTX
#165
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 4
CERTIFICATE_OF_COMPLIANCE
EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
...t imposed as punishment or as a determination of Petitioner's motive or intent. 2. CONDITIONAL BAD-FAITH/OBSTRUCTION COERCIVE INCENTIVES (¥ Check All That Apply) DF-24-18010 4 of 13 Copy from re:SearchTX
#165
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 5
PLEADING_BODY
EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
...rference with Respondent's housing stability, access to funds, or medical care pending return hearing, and shall accrue for each day such interference continues. DF-24-18010 5 of 13 Copy from re:SearchTX
#165
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 6
DECLARATION
EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
...nt the Temporary Restraining Order as requested and set an expedited return hearing. Respectfully submitted, Jason McKemie Respondent, Pro Se 539 W. Commerce St., Suite 2010 Dallas, Texas 75208 (214) 868-4901 jmckemie@mckemie.net EXHIBITS: e Exhibit A: Eviction judgment/notice (deadlines) e Exhibit B: Respondent's Unsworn Declaration EXHIBIT C: Ameriprise Statement DF-24-18010 6 of 13 Copy from re:SearchTX
#165
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 7
PLEADING_BODY
EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
DF-24-18010 THE MARRIAGE OF § § & ON EMERGENCY REINSTATEMENT OF HEALTHCARE On this day, the Court considered Jason McKemie's (Respondent's) Emergency Motion regarding reinstatement of healthcare coverage. The Court finds immediate relief is necessary to prevent medical har : IT1S RDERED: |. COMPLIANCE PATH (PETITIONER MUST CHOSE AND COMPLETE ONE PATH) 1. Within twenty-four (24) hours of the signing of this Order, Petitioner shall complete one of the following two compliance paths and provide Respondent written proof of completion (email is sufficient). O...
#165
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 8
PLEADING_BODY
EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
...nths): $2,684.56 (Medical $609.23 + Dental $55.32 + Vision $6.59, multiplied by four months), and 2. HSA/FSA replacement amounts totaling $17,959.00 (2025 HSA $5,959.00; 2026 HSA $6,000.00; 2025 FSA $3,000.00; 2026 FSA $3,000.00). IV. NON-INTERFERENCE A. Petitioner shall not interfere with, restrict, disable, or obstruct Respondent's access to healthcare coverage, prescriptions, or medical care pending further order of the Court. V. ENFORCEMENT AND PAYMENT DEADLINES A. to timely complete Option A or Option B (in ding written proof and/or required Prilure...
#165
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 9
PLEADING_BODY
EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
favor of Respondent in an amount equivalent to two (2) weeks of Petitioner's total grass compensation, including base'salary, bonuses, cashincentives, equity compensation, deferred compensation, and employer-provided remuneration of any Rind. Petitioner shall deposit that amount into joint ascount ending XX6893within seventy-two (72) hours of the noncompliance trigger. !f not deposited on time, a coercive fine of $1,000 per day shall accrue until paid in full. D. Future interference The same remedies apply to any future interference with Respondent"s acc...
#165
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 10
EXHIBIT_START
EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
...oyer plan administrator asserting that the divorce was finalized and that a judicially signed final decree existed. No final decree exists. Trial is set for February 24, 2026. 4. Regardless of what any benefits portal may display, my coverage has been functionally unreliable and non-usable in practice, including denial of pharmacy processing and inability to obtain prescriptions and medically necessary care. The interruption has shifted tens of thousands of dollars of deductibles and copays onto me at the worst possible time. My out-of- pocket maximum ha...
#165
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 11
EXHIBIT_CONTINUATION
EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
...ivan & Cook. Petitioner testified on or about October 31, 2025 that she ceased and/or withdrew from VEIP. This leaves two mutually exclusive outcomes as follows: DF-24-18010 11 of 13 Copy from re:SearchTX
#165
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 12
EXHIBIT_CONTINUATION
EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
...te temporary support is infeasible due to lack of funds is not accurate. | declare under penalty of perjury that the foregoing is true and correct. Jason McKemie DF-24-18010 12 of 13 Copy from re:SearchTX