#188
2026-02-02
Respondent / Jason
Motion - Miscellaneous
Page 1
PLEADING_START_FILE_MARKED
MOTION TO COMPEL COMPLETE FINANCIALS_C133CDAF.pdf
2/2/2026 11:52 PM NOTICE: THIS DOCUMENT DALLAS CO., TEXAS MARRIAGE OF § § & § EMERGENCY MOTION TO ABATE ALL PROCEEDINGS, PRESERVE LIFE- SAFETY, COMPEL A WRITTEN RECORD, AND AUTHORIZE THIRD-PARTY SUBPOENAS FOR ADMINISTRATIVE RECORDS QLE/HEALTHCARE TO THE HONORABLE JUDGE OF SAID COURT: Movant, Jason McKemie, appears pro se due to financial deprivation and medical incapacity, and files this Emergency Motion to prevent irreparable harm and preserve due process. This Motion is I. EMERGENCY NATURE AND RELIEF REQUESTED This Court is currently being asked to pro...
#188
2026-02-02
Respondent / Jason
Motion - Miscellaneous
Page 2
PROPOSED_ORDER_OR_ORDER
MOTION TO COMPEL COMPLETE FINANCIALS_C133CDAF.pdf
...ory is not delay-for-delay's sake; it is the record of repeated, unresolved life-safety issues. B. Court-Ordered Restoration Remains Uncured in Practice On December 17, 2025, the Court ordered restoration of healthcare/HSA access within 24 hours. As of today, Movant remains without functional access to critical medications and benefits needed to prevent serious harm. Movant has suffered repeated emergency-room presentations, and treating providers have warned that continued interruption of medication access results in recurring emergency care and risk of...
#188
2026-02-02
Respondent / Jason
Motion - Miscellaneous
Page 3
PLEADING_BODY
MOTION TO COMPEL COMPLETE FINANCIALS_C133CDAF.pdf
will require subpoenas to third parties. Proceeding toward trial without complete records is not "moving the case forward"; it is moving forward blind. E. Federal Bankruptcy Trustee Review Overlaps with the Marital Estate shifting, alleged fraudulent reporting of legal/medical charges, and related issues that overlap directly with relief sought in this case. Proceeding in state court without allowing the trustee process to stabilize will cause inconsistent rulings and irreparable prejudice. lil. ARGUMENT A. Abatement is Required to Prevent Irreparable Ha...
#188
2026-02-02
Respondent / Jason
Motion - Miscellaneous
Page 4
PLEADING_BODY
MOTION TO COMPEL COMPLETE FINANCIALS_C133CDAF.pdf
2. QLE/BENEFITS SUBPOENAS (ACCENTURE/BUSINESSOLVER): Authorize issuance of narrow third-party subpoenas to Accenture/Businessolver for QLE/eligibility administrative record and recordings; 3. SANCTIONS AND INTERIM MAKE-WHOLE RELIEF (LIFE-SAFETY / FUNCTIONAL ACCESS): Order sanctions and interim make-whole relief based on materially false and irreconcilable representations to the Court and continued noncompliance with healthcare/HSA orders, including immediate relief sufficient to restore functional access to critical medications and healthcare without req...
#188
2026-02-02
Respondent / Jason
Motion - Miscellaneous
Page 5
CERTIFICATE_OF_SERVICE
MOTION TO COMPEL COMPLETE FINANCIALS_C133CDAF.pdf
emie EMERGENCY MOTION TO ABATE ALL PROCEEDINGS, PRESERVE LIFE-SAFETY, COMPEL A WRITTEN RECORD, AND AUTHORIZE THIRD-PARTY SUBPOENAS FOR QLE/HEALTHCARE ADMINISTRATIVE RECORDS 5 of 5 Copy from re:SearchTX
#188
2026-02-02
Respondent / Jason
Motion - Miscellaneous
Page 6
FILING_STAMP_OR_ESERVICE
MOTION TO COMPEL COMPLETE FINANCIALS_C133CDAF.pdf
...: Motion - Miscellaneous Filing Description: EMERGENCY MOTION TO ABATE PROCEEDINGS, PRESERVE LIFE-SAFETY, COMPEL A WRITTEN RECORD, & AUTHORIZE SUBPOENAS Status as of 2/4/2026 8:28 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 2/2/2026 11:52:41 PM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 2/2/2026 11:52:41 PM SENT Copy from re:SearchTX