#194
2026-02-17
Respondent / Jason
Witness List
Page 1
PLEADING_START_FILE_MARKED
WITNESS LIST-PLAINTIFF'S FINAL WITNESS LIST_51ECB7EC.pdf
2/17/2026 10:15 PM DALLAS CO., TEXAS NO. DF-24-18010 THE MARRIAGE OF § § (PETITIONER) v. § PLAINTIFF'S FINAL WITNESS LIST TRIAL SETTING: FEBRUARY 24, 2026 - Petitioner 1. Gwendolyn Laura Ulijasz-McKemie - 2. Jason Emory McKemie Respondent (Adverse party) Petitioner reserves the right to call any witness necessary for rebuttal or impeachment. Respectfully submitted, Gwendolyn. Laura.Ulijasz-McKemie 11703 Huebner Road, Stel06 PMB499 San Antonio TX 78230 210-278-6377 GUlijasz@gmail.com Pro Se Copy from re:SearchTX
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#194
2026-02-17
Respondent / Jason
Witness List
Page 2
FILING_STAMP_OR_ESERVICE
WITNESS LIST-PLAINTIFF'S FINAL WITNESS LIST_51ECB7EC.pdf
...rsons listed below. The rules governing Envelope ID: 111376188 Filing Code Description: Witness List Filing Description: PLAINTIFF'S FINAL WITNESS LIST Status as of 2/18/2026 10:56 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Ethan Scroggins escroggins@sullivancook.com 2/17/2026 10:15:50 PM SENT Jason McKemie jmckemie@mckemie.net 2/17/2026 10:15:50 PM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 2/17/2026 10:15:50 PM SENT Gwendolyn Ulijasz gulijasz@gmail.com 2/17/2026 10:15:50 PM SENT JASON EMORYMCKEMIE jason@callvital.com 2/1...
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#193
2026-02-17
Filer unknown
Miscellaneous Event
Page 1
PLEADING_START_FILE_MARKED
WIFE PROPOSED PROPERTY DIVISION_FE6258FD.pdf
2/17/2026 10:21 PM DALLAS CO., TEXAS Value Used for Percent to Percent to Note Description His Value Her Value To Husband To Wife Division Husband Wife COMMUNITY ASSETS REAL PROPERTY (including Mineral Interests) 1 Secur ty Deposit for Pet's current Residence $3,800 $3,800 $3,800 $0 0% 100% CASH AND ACCOUNTS WITH FINANCIAL INSTITUTIONS (including Brokerage and Mutual Funds) Chase Checking x6893 $536 ~$428 -$428 $0 -$428 0% 100% 2 Chase Checking x9259 $8,203 $8,203 $0 $8,203 0% 100% 3 Chase Checking x7496 $82 $82 $0 $82 0% 100% 4 Chase GLU Checking x8627...
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#193
2026-02-17
Filer unknown
Miscellaneous Event
Page 2
PLEADING_BODY
WIFE PROPOSED PROPERTY DIVISION_FE6258FD.pdf
2 MetLife MSA $0 $0 $0 $0 0% 100% 3 sccenture Inspi $0 $0 0° 100% MOTOR VEHICLES, BOATS, AIRPLANES, CYCLES, ETC. 1 2023 BMW M340xi $68,710 -$11,000 -$11,000 $0 -$11,000 0% 100% 2 2018 Jaguar F-Pace -$5,000 -$5,000 -$5,000 $0 100% 0% OTHER TANGIBLE PERSONAL PROPERTY Hospitech solutions LLC. x At&t pension x Domain names x lonos acccount - Domains and email addresses x Storage Unit x Personal property at Dallas house - see attached Exhibit A x CLUB MEMBERSHIPS/TRAVEL AWARD BENEFITS 1 Gwen Airline Miles $200 $200 $0 $200 0% 100% 2 Sam's Club and Costco $0 $...
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#193
2026-02-17
Filer unknown
Miscellaneous Event
Page 3
PLEADING_BODY
WIFE PROPOSED PROPERTY DIVISION_FE6258FD.pdf
...ate -$83,261 $2,656 -$85,917 WIFE'S SEPARATE ESTATE 1 Advantigen Biosciences, LLC shares $ 130,000.00 $ 100,000.00 $ 100,000.00 $0 $ 100,000.00 0% 100% 2 AIG 401k (2015-2020) $ 91,087.00 $ 121,272.00 $ 121,272.00 $0 $ 121,272.00 0% 100% 3 Ameriprse Financial Traditional IRA $ 297,208.00 $ 287,771.00 $ 287,771.00 $0 $ 287,771.00 0% 100% 4 Ameriprise Financial Roth IRA $ 151,315.00 $ 146,516.00 $ 146,516.00 $0 $ 146,516.00 0% 100% Employee Stock Benefit Plans 1 Accenture New Hire Equity Restricted Stock (510 Sh Vests in 2029) $124,838 $124,838 $0 $124,838...
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#193
2026-02-17
Filer unknown
Miscellaneous Event
Page 4
FILING_STAMP_OR_ESERVICE
WIFE PROPOSED PROPERTY DIVISION_FE6258FD.pdf
...ns listed below. The rules governing Envelope ID: 111376255 Filing Code Description: Miscellaneous Event Filing Description: PROPOSED PROPERTY DIVISION Status as of 2/18/2026 1:40 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 2/17/2026 10:21:36 PM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 2/17/2026 10:21:36 PM SENT Gwendolyn Ulijasz gulijasz@gmail.com 2/17/2026 10:21:36 PM SENT JASON EMORYMCKEMIE jason@callvital.com 2/17/2026 10:21:36 PM SENT Copy from re:SearchTX
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#195
2026-02-17
Respondent / Jason
Objections - Misc
Page 1
PLEADING_START_FILE_MARKED
RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS_408A7A93.pdf
2/17/2026 7:34 AM THE MARRIAGE OF § § § RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS Respondent, Jason McKemie, files this Formal Objection to any Purported Sealing of Records in this matter and gives notice to the Court that no valid sealing order has been noticed, heard, or entered on the record with Respondent's participation. Respondent has never been served with a motion to seal, afforded notice of any request to seal, or provided an opportunity to be heard in related matters. Respondent has nevertheless discovered an unsigned a...
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#195
2026-02-17
Respondent / Jason
Objections - Misc
Page 2
PROPOSED_ORDER_OR_ORDER
RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS_408A7A93.pdf
...tes due process and is procedurally improper. Il. CHRONOLOGICAL TIMELINE OF MEDICAL INCAPACITATION, FINANCIAL DEPRIVATION, AND PROCEDURAL AMBUSH - TUESDAY, DECEMBER 10, 2024 Respondent Drives Himself to Surgery Respondent undergoes emergency invasive spinal surgery following a six-day hospitalization, during which he experienced paralysis from the waist down for approximately two days. Respondent is discharged under physician-directed recovery and requires prescribed rehabilitation equipment and uninterrupted access to healthcare and financial resources....
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#195
2026-02-17
Respondent / Jason
Objections - Misc
Page 3
PLEADING_BODY
RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS_408A7A93.pdf
...ncial distress, that they are at risk of bouncing their utility payment, and asserts she has no attorney and cannot begin interviewing attorneys until] at least December 17-18, insisting that his retainer not be reinstated until that time so that they can retain counsel jointly. For approximately four months prior, Petitioner had represented that the parties were experiencing a "short-term cash crunch," directing Respondent to place increasing household expenses on his personal credit cards. As they would start their day, Petitioner would tell him, "Reme...
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#195
2026-02-17
Respondent / Jason
Objections - Misc
Page 4
PLEADING_BODY
RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS_408A7A93.pdf
MONDAY, DECEMBER 16, 2024 - The Procedural Theft of Petitioner Status On Monday, Petitioner's counsel (Donna Tomlinson) files an Ex Parte Petition for a Protective Order and a Petition for an Annulment of Marriage based on false allegations, thereby preempting Respondent's pending divorce filing and procedurally securing petitioner status, despite Respondent having retained counsel first and while Respondent remained medically incapacitated and without functional access to financial or legal resources. PROCEDURAL IMPACT Since the inception of these proce...
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#195
2026-02-17
Respondent / Jason
Objections - Misc
Page 5
EXHIBIT_START
RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS_408A7A93.pdf
...order petition 5 days later. The sequence of events unfolded precisely as predicted in that recorded call. Moreover, Petitioner's description of events on December 12, 2024 differs materially across multiple sources: her sworn protective order petition (Exhibit B), her statements to law enforcement (Exhibit C), and the contemporaneous text between the parties (Exhibit D). These accounts are not message exchanges merely framed differently they present inconsistent narratives regarding tone, conduct, and sequence of events. Where credibility is central an...
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#195
2026-02-17
Respondent / Jason
Objections - Misc
Page 6
EXHIBIT_CONTINUATION
RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS_408A7A93.pdf
...nsiderations weigh decisively against any attempt to seal. VI. SWORN TESTIMONY REGARDING EMPLOYER SETTLEMENTS AND SUBSEQUENT DOCUMENTARY CONTRADICTION At the January 7, 2025 hearing, Petitioner testified under oath in response to direct questioning by Respondent's then-counsel, Brant Webb, regarding whether she had received settlements from prior employers, including AIG and AllianceBernstein, and whether she had sought or received any settlement from Cognizant Technology Solutions. Petitioner was questioned separately and distinctly as to each employer....
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#195
2026-02-17
Respondent / Jason
Objections - Misc
Page 7
EXHIBIT_CONTINUATION
RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS_408A7A93.pdf
The existence of multiple settlements-each resolved in connection with employment separation and allegations asserted at the time of departure-is material to credibility. Petitioner's categorical denial of all such settlements when questioned individually and under oath invites judicial scrutiny. The later disclosure of these agreements, combined with their subsequent characterization and use in financial disclosures, mediation representations, and employment positioning, bears directly on the reliability of sworn testimony and the integrity of represent...
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#195
2026-02-17
Respondent / Jason
Objections - Misc
Page 8
EXHIBIT_CONTINUATION
RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS_408A7A93.pdf
publicly asserted and carried foreseeable reputational and safety consequences for Respondent. The evidentiary record now reflects that: e Nosurveillance devices were discovered at the marital residence; e The item identified as a concealed surveillance device was a commercially available household hygrometer, which Petitioner herself identified by name and function in recorded video; e The alleged vehicle tracking device belonged to Petitioner, as confirmed by her own discovery materials; and e Video evidence documents the removal and destruction of hom...
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#195
2026-02-17
Respondent / Jason
Objections - Misc
Page 9
EXHIBIT_CONTINUATION
RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS_408A7A93.pdf
....net EXHIBITS Z Petitioner's Order to Seal Records a A Respondent's 911 Call Predicting False Police Reports & the Filing of Fraudulent Protective Order on December 11, 2024 B Petitioner's "PROTECTIVE ORDER" Version of Thursday, Dec 12, 2024 C Petitioner's "POLICE REPORT" Version of Thursday, Dec 12, 2024 D Respondent and Petitioner's Text Message Exchanges on Thursday, Dec 12, 2024 (Following Petitioner's Reporting of Respondent's Divorce Retainer as Fraud (12/12/24), Respondent is expressing he does not feel safe, and that he needs his legal retainer r...
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#195
2026-02-17
Respondent / Jason
Objections - Misc
Page 10
EXHIBIT_START
RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS_408A7A93.pdf
EXHIBIT Z THE MARRIAGE OF § § AND § Order to Seal Court Records Matter of the Marriage of Gwendolyn Ulijasz-McKemie and Jason McKemie" are sealed, except those documents that are required by law to be recorded in the minutes of the Court. The documents shall not be opened or released except on appropriate court order. SIGNED on XXXX JUDGE PRESIDING EXHIBIT NOT FOR SIGNATURE Order to Seal Court Records 10 of 23 Copy from re:SearchTX
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#195
2026-02-17
Respondent / Jason
Objections - Misc
Page 11
EXHIBIT_CONTINUATION
RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS_408A7A93.pdf
4f7725, 2:47 PM inform Browser : 21.102.282.13 : 23.103.1484.5 - Raports - Incident Report Incident Detail Report EXHIBITA Data Source; Data Warehouse Incident Status: Closed lacident number: 24-2741556 Case Numbers: Inciden! Dale: 12/14/2024 15:28:23 Report Generaled: 4/7/2025 14:47:25 Ey Incident Information incident Type: 1Man Alarm Level: - Other Priority: 3 - General Service Problem: 40 Determinant: Agency: Police Base Response#: Jurisdiction: Daiias Police Confinnation#: Division: Northwest Taken By: Macias, Rocio Battalion: §20 - MAN Response Area...
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#195
2026-02-17
Respondent / Jason
Objections - Misc
Page 12
EXHIBIT_CONTINUATION
RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS_408A7A93.pdf
...P 125112024 5:35:38 ANHALI Statistics <Blank> INT Insert:Dec 112024 15:28:22 / INT SendNP:Dee 11 2024 15:28:22 i WS RecvNP:Dec 11 2024 15:28:22 WS 11 2024 15:35:38 12/11/2026 15:35:38 Read Comment 5609 La Foy Bivd CommentProcess:Decfor incident 937 was marke 12/11/2024 16:11:36 Read Incident as road, 12h 12024 16:11:36 Read Comment incident 937 was Marked as Read. Comment for Incident 937 was Marke 121 4/2024 16:18:53 UscrAction as Read. 12/11/2024 17:10:26 Read Comment 5609 La Foy Blvd CommentUser clickedfor Exit/SaveIncident 937 was markec 12/11/2024 7...
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#195
2026-02-17
Respondent / Jason
Objections - Misc
Page 13
EXHIBIT_CONTINUATION
RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS_408A7A93.pdf
EXHIBITB PETITIONER'S "PROTECTIVE ORDER VERSION" OF THURSDAY, DECEMBER 12TH, 2024 Jason has grown increasingly agitated and aggressive, particularly when I ask him about his drug use and his constant spending. He is having manic episodes, and I cannot reason with him at all. Jason's manic behavior includes staying up most nights, active and walking around the house through all hours of the night. During that time, Jason rearranges items on the kitchen countertop, organizes cabinets, and does this over and over again. During this behavior, I am kept awake...
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#195
2026-02-17
Respondent / Jason
Objections - Misc
Page 14
EXHIBIT_START
RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS_408A7A93.pdf
4/7/25, 2:47 PM inform Browser : 21,102.2B2.13 : 23.103.1484.5 - Reports - Incident Report 05/03/2020 EXHIBIT C 1202330 5609 La Foy Bivd RESIDENTIACIosed 08/02/2023 ts 08/02/2024 1127190 5609 La Foy Blvd RESIDENTIAClased 10/21/2008 lo 10/31/2009 Pre-Scheduled Information No Pre-Scheduled Information Transports No Transports information Transport Legs No Transports Information Comments Date Time User Type Conf. Comments [1] WELFARE CHECK ON HUSBAND, RP IS WIFE (MCKINNEY, GWENDOLYN), COMP HAS NOT RESPONDING MESSAGES, ANSWERED CALLS, HAS 12/14/2024 22:04:53...
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#195
2026-02-17
Respondent / Jason
Objections - Misc
Page 15
EXHIBIT_START
RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS_408A7A93.pdf
EXHIBIT D Ok Sounds good $82 on eBay ? That was the other o wasn't sure Dominique's gift Ok thx. That charge already had gone through, so unlike the attorney retainer and the airline ticket. They said that | could call them back and let them know about that one this afternoon. Thank you. Sure. If you see anything else, just let me know | \dk if should pack for two weeks or not? | think yes ? guess I'll just do that so long as we are spinning a little and we can talk tomorrow or this weekend. Or if you have a decision already for Christmas you can et me k...
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#195
2026-02-17
Respondent / Jason
Objections - Misc
Page 16
EXHIBIT_CONTINUATION
RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS_408A7A93.pdf
{i understand. Same | shouldn't have committed to leave the house Gwen, today. I'm broken. Physically, mentally, and emotionally. My back is in so much pain. I'm really having a tough time. And I've been told not to leave the house as well. You are more than welcome to come here, shower, change clothes, get a suitcase together, and whatever | know she's else you might need. Katie's here and dying to see you. But my request would be that you | could find a hotel for tonight. I'm really hurting and just need to lay down and be still and try to relax. I'm a...
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#195
2026-02-17
Respondent / Jason
Objections - Misc
Page 17
EXHIBIT_CONTINUATION
RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS_408A7A93.pdf
.... Actually, I'm pretty embarrassed about the whole thing and... | made your day so fucked 'm, I'm just really sorry | don't mind Ok. Well | will give you a lot of space. 17 of 23 | think | Know where it is. sleeping on the air mattress. | assume Stuart has some idea about what's going on, Copy from re:SearchTX
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#195
2026-02-17
Respondent / Jason
Objections - Misc
Page 18
EXHIBIT_CONTINUATION
RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS_408A7A93.pdf
yes ? Just want to be aware Found out | can have you on my healthcare through Cobra for 6 months. In case. That's really kind of you. But don't worry about that right now. Just focus on your work, all that shit will work out. Stuart knows that we're having a tough time Ok Thu, Dec 12 at 8:46 PM I'm just packing for WI up here. Just letting you know. It'll take me another 30-45 mins or so. Then I'll just be working. I'll sleep in my office. It's fine. Thu, Dec 12 at 14:07 PM | came upstairs to get my pillow & saw that you had gotten yours. | already have...
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#195
2026-02-17
Respondent / Jason
Objections - Misc
Page 19
EXHIBIT_CONTINUATION
RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS_408A7A93.pdf
Thank you Gwen for agreeing to make this payment | don't feel safe or even Informed of various today. options, including those you've suggested. | want you to know that it really meant a lot to me yesterday when you were so understanding about | needed to everything, and told me that if that's what feel comfortable; that you would immediately make that payment. | | feel lost, hurt, confused, and financially isolated. sincerely appreciate you making this payment for a retainer. | just want to get some guidance as well as options, and it's my desire to fin...
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#195
2026-02-17
Respondent / Jason
Objections - Misc
Page 20
EXHIBIT_CONTINUATION
RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS_408A7A93.pdf
...Paid: Name: McKemie Payment AMEX StatementGwen Method: Number: Ulijasz Card paying on Number: behalf of Entry Manual Jason Mode: Auth Code: 240309 Payment December 13, 2024 01:25 pm 20 of 23 Date: Transaction 123576476 ruCopy from re:SearchTX
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#195
2026-02-17
Respondent / Jason
Objections - Misc
Page 21
EXHIBIT_CONTINUATION
RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS_408A7A93.pdf
Payment id: SzKpTPPdScOgYER | can relate Gwen. I've been destroyed over this, @ completely devastated. Hearing that you told your mother that, really felt like a | am deeply sad and quite dagger right in the heart. literally blowing my eyes out right now. | just wanted to talk to this attorney and see what options there are and get some guidance. And I'm looking for things with a potentially positive outcomes, but | also want to understand all potential outcome so I'm not caught off guard anymore. It's just tearing me apart to hear these things as a surp...
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#195
2026-02-17
Respondent / Jason
Objections - Misc
Page 22
EXHIBIT_CONTINUATION
RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS_408A7A93.pdf
wy Ashley Safe travels. My flight taking off too Today 6 3AM Cio Today 12 5.1PM | bother you for Thanks Ashley , can Dannetta's cell number ? She and are having the same teams and email issue. | | had just left the house and she and to touch base on Mondays details this afternoon. | have no sure-fire Realizing she and way to get ahold of each other. Denvered Let me find it | don't have it and it's not on her workday - let me ping her | Here's proof. freaking have to ask Ashley for people's cell phone numbers. understand that and that's fine. We don't hav...
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#195
2026-02-17
Respondent / Jason
Objections - Misc
Page 23
CERTIFICATE_OF_SERVICE
RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS_408A7A93.pdf
RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS DF-24-18010 23 of 23 Copy from re:SearchTX
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#195
2026-02-17
Respondent / Jason
Objections - Misc
Page 24
FILING_STAMP_OR_ESERVICE
RESPONDENT'S FORMAL OBJECTION TO ANY PURPORTED SEALING OF RECORDS_408A7A93.pdf
...ules governing Envelope ID: 111323549 Filing Code Description: Objections - Misc Filing Description: RESPONDENT'S - TO ANY PURPORTED SEALING OF RECORDS Status as of 2/17/2026 10:34 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 2/17/2026 7:34:33 AM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 2/17/2026 7:34:33 AM SENT Gwendolyn Ulijasz gulijasz@gmail.com 2/17/2026 7:34:33 AM SENT Copy from re:SearchTX
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