#198
2026-02-20
Petitioner / Gwendolyn
Notice Of Filing IN LIMINE REGARDING
Page 1
PLEADING_START_FILE_MARKED
PETITIONER'S MOTION IN LIMINE REGARDING AUDIO AND VIDEO RECORDING_F5BE53C3.pdf
2/20/2026 4:59 PM DALLAS CO., TEXAS IN THE MATTER OF THE MARRIAGE OF GWENDOLYN ULIJASZ-MCKEMIE AND JASON MCKEMIE Petitioner's Motion in Limine Regarding Audio and Video Recordings TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW Petitioner, Gwen Ulijasz ("Petitioner"), appearing pro se, and files this Motion in Limine Regarding Audio and Video Recordings, and respectfully shows the Court as follows: 1. Purpose of Motion Petitioner files this Motion in Limine for the limited and procedural purpose of ensuring an orderly, efficient, and fair trial. This mot...
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#198
2026-02-20
Petitioner / Gwendolyn
Notice Of Filing IN LIMINE REGARDING
Page 2
PLEADING_BODY
PETITIONER'S MOTION IN LIMINE REGARDING AUDIO AND VIDEO RECORDING_F5BE53C3.pdf
...reference, describe, or play any audio or video recordings involving Petitioner unless and until such recordings were: i. Marked as exhibits by the deadline passed (2/17/2026); ii. Properly disclosed; iii. Authenticated; and iv. Specifically ruled admissible by the Court. B. Any request to introduce such recordings shall be addressed outside the flow of testimony, at the Court's discretion. 5. No Prejudgment Requested Petitioner does not ask the Court to determine the admissibility, legality, or weight of any recordings at this time, only to require that...
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#198
2026-02-20
Petitioner / Gwendolyn
Notice Of Filing IN LIMINE REGARDING
Page 3
FILING_STAMP_OR_ESERVICE
PETITIONER'S MOTION IN LIMINE REGARDING AUDIO AND VIDEO RECORDING_F5BE53C3.pdf
...Envelope ID: 111545342 Filing Code Description: Notice Of Filing IN LIMINE REGARDING Filing Description: PETITIONER'S MOTION AUDIO AND VIDEO RECORDING Status as of 2/23/2026 2:25 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 2/20/2026 4:59:43 PM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 2/20/2026 4:59:43 PM SENT Gwendolyn Ulijasz gulijasz@gmail.com 2/20/2026 4:59:43 PM SENT JASON EMORYMCKEMIE jason@callvital.com 2/20/2026 4:59:43 PM SENT Copy from re:SearchTX
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#199
2026-02-20
Respondent / Jason
Notice Of Filing
Page 1
PLEADING_START_FILE_MARKED
EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL_109EBB73.pdf
2/20/2026 4:59 PM DALLAS CO., TEXAS THE MARRIAGE OF § § nd & § EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL TO THE HONORABLE COURT: Movant Jason McKemie, appearing pro se, files this Emergency Verified Motion to Continue or Abate the February 24, 2026 bench trial setting and to enter trial-readiness orders required for any final adjudication on property division, reimbursement claims, and credibility-dependent issues. This Motion is a procedural stop-button. It asks the Court to prevent trial on a record that remains legally stayed (bankrup...
#199
2026-02-20
Respondent / Jason
Notice Of Filing
Page 2
PROPOSED_ORDER_OR_ORDER
EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL_109EBB73.pdf
...NOT READY BECAUSE DISCOVERY NONCOMPLIANCE WAS CONFIRMED INSIDE THE FINAL PRETRIAL WINDOW The procedural posture alone establishes the case is not trial-ready: January 6, 2026: Motion to Compel discovery and HSA-related requests heard. January 9, 2026: Court-ordered production deadline. January 20, 2026: Status hearing to assess compliance. February 5, 2026: Compliance hearing held inside the final pretrial window. Petitioner did not complete production by January 9. Compliance status hearings followed because the compelled deficiencies remained unresolve...
#199
2026-02-20
Respondent / Jason
Notice Of Filing
Page 3
PLEADING_BODY
EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL_109EBB73.pdf
A. The January 6 ruling is not being challenged On January 6, 2026, the Associate Judge heard Movant's Motion to Compel discovery and requests regarding HSA. The Associate Judge's written report reflects that: 1. The Court granted Movant's request that financial documents be turned over by January 9, 2026; and 2. The HSA card was noted as provided at the time of the hearing. Movant does not seek de novo review of that ruling. Movant does not ask the Court to overturn, rehear, or modify it. Movant does not contend the Associate Judge erred. B. The issue n...
#199
2026-02-20
Respondent / Jason
Notice Of Filing
Page 4
PLEADING_BODY
EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL_109EBB73.pdf
...d HSA/FSA functionality. That relief has not been complied with. Movant requires surgery and ongoing medical care and has been repeatedly hospitalized. As of February 2, 2026, Movant's benefits summary reflects multiple benefit categories remain "Coverage Waived," including: e Employee Critical Illness e Spouse/Domestic Partner Critical Illness e Optional Life Insurance e Optional AD&D Copy from re:SearchTX
#199
2026-02-20
Respondent / Jason
Notice Of Filing
Page 5
PROPOSED_ORDER_OR_ORDER
EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL_109EBB73.pdf
...TRANSCRIPT / RECORD DEFECT JANUARY 7 TRANSCRIPT IS NECESSARY FOR TRIAL PREP AND REVIEWABILITY Movant has repeatedly moved for the certified transcript of the January 7, 2025 hearing and requested that it be treated as a litigation expense payable from community funds under Petitioner's control. Movant submitted a proposed order authorizing procurement and payment The absence of this transcript prejudices trial preparation and prevents meaningful testing of sworn representations made at the foundational hearing. Relief requested: Sign the transcript autho...
#199
2026-02-20
Respondent / Jason
Notice Of Filing
Page 6
DECLARATION
EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL_109EBB73.pdf
VIII. PRAYER For the foregoing reasons, Movant respectfully requests that the Court grant the Relief Requested, continue or abate the February 24, 2026 bench trial setting, enter written trial-readiness orders, and grant all other relief to which Movant is justly entitled. VERIFIED UNSWORN DECLARATION (TEX. CIV. PRAC. & REM. CODE § 132.001) My name is Jason McKemie. My date of birth is April 8,. 1 1976. My address is 539 W. Commerce St., Suite 2010, Dallas, Texas 75208. | declare under penalty of perjury that the factual statements in this Motion are tru...
#199
2026-02-20
Respondent / Jason
Notice Of Filing
Page 7
CERTIFICATE_OF_SERVICE
EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL_109EBB73.pdf
record and/or parties entitled to notice in accordance with the Texas Rules of Civil Procedure and : Jas6o-McKemie Copy from re:SearchTX
#199
2026-02-20
Respondent / Jason
Notice Of Filing
Page 8
FILING_STAMP_OR_ESERVICE
EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL_109EBB73.pdf
...verning Envelope ID: 111545338 Filing Code Description: Notice Of Filing Filing Description: EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL Status as of 2/23/2026 2:22 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 2/20/2026 4:59:43 PM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 2/20/2026 4:59:43 PM SENT Copy from re:SearchTX