#216
2026-04-07
Respondent / Jason
Objections - Misc
Page 1
PLEADING_START_FILE_MARKED
OBJECTION TO PRO HAC VICE AND REQUEST ENFORCEMENT & STABILIZATION_72275AB8.pdf
4/7/2026 3:08 PM DALLAS CO., TEXAS vo, DF-24-18010 THE MARRIAGE OF § § & § RESPONDENT'S OBJECTION TO SWORN MOTION OF JONATHAN DRAKE STEELE TO APPEAR PRO HAC VICE; REQUEST FOR IMMEDIATE DENIAL; AND, ONLY IN THE ALTERNATIVE, REQUEST TO DEFER RULING, SET EMERGENCY STABILIZATION HEARING, SOURCE-OF-FUNDS DISCLOSURE, AUTHORIZE SOURCE-RECORD REQUIRE SUBPOENAS, AND ENTER PROTECTIVE CONDITIONS TO THE HONORABLE COURT: Respondent Jason McKemie objects to the proposed order granting Jonathan Drake Steele pro hac vice admission. The request should be denied. At minim...
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#216
2026-04-07
Respondent / Jason
Objections - Misc
Page 2
PLEADING_BODY
OBJECTION TO PRO HAC VICE AND REQUEST ENFORCEMENT & STABILIZATION_72275AB8.pdf
3. The motion does not establish case-specific good cause. It supplies threshold licensure and status representations. It does not explain why this Court should authorize out-of-state litigation expansion now, over written objection, in a case already warped by healthcare obstruction, discovery collapse, source-record contamination, and extreme asymmetry in access to counsel and money. 4. Before any order is signed, Petitioner should be required by sworn filing to disclose whether the requested appearance is general or limited, the exact subject matter o...
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#216
2026-04-07
Respondent / Jason
Objections - Misc
Page 3
PLEADING_BODY
OBJECTION TO PRO HAC VICE AND REQUEST ENFORCEMENT & STABILIZATION_72275AB8.pdf
paying her bills. Even on that version of events, support was warranted, because Respondent could not afford critical heart medication or basic necessities. The later- produced records then showed what Respondent had already told the Court was there: substantial additional funds, including the second half of Petitioner's signing bonus, while community assets had been concealed and Respondent was being told the parties were in financial distress and pushed to absorb family holiday spending on his personal credit cards. Respondent had nothing for medicatio...
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#216
2026-04-07
Respondent / Jason
Objections - Misc
Page 4
PLEADING_BODY
OBJECTION TO PRO HAC VICE AND REQUEST ENFORCEMENT & STABILIZATION_72275AB8.pdf
healthcare coverage. Respondent remains impaired by a torn rotator cuff, ruptured bicep, torn shoulder tendons, and a compressed L5/L6 nerve, in addition to congestive-heart-failure complications following him being immediately cut off a GLP- 1 inhibitor after 18 months on it at the maximum dose due to Petitioner's termination of his medical benefits through the submission of a false QLE. Respondent learned of this termination 24 days after the termination, and all billed medical services for the prior 24 days were clawed back and then services were bill...
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#216
2026-04-07
Respondent / Jason
Objections - Misc
Page 5
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OBJECTION TO PRO HAC VICE AND REQUEST ENFORCEMENT & STABILIZATION_72275AB8.pdf
appearing to position those healthcare funds outside the reach of the Court's prior reimbursement order. j. Respondent remains in ongoing pain, cannot sleep in a bed, is forced to sleep upright on a couch, and remains blocked from medically necessary surgery. This is not confusion. It is sustained obstruction of healthcare access, and it is actively harming Respondent. 11. HSA access has been obstructed since the second day of these proceedings. No healthcare-related order has been complied with in any functional sense. Petitioner was ordered to obtain a...
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#216
2026-04-07
Respondent / Jason
Objections - Misc
Page 6
PLEADING_BODY
OBJECTION TO PRO HAC VICE AND REQUEST ENFORCEMENT & STABILIZATION_72275AB8.pdf
14. This Court should not authorize another lawyer for the party obstructing access to medication while the opposing party is still fighting to restore basic medical care. 15. Any order concerning healthcare, benefits, HSA/FSA access, or medical funding must include: - adate-certain deadline; third-party verification where necessary; and anautomatic compliance hearing within 48 hours after the deadline. compliance. IV. STABILIZATION COMES FIRST 16. Before Petitioner is permitted to add still more counsel, this Court must first stabilize the case. 17. Res...
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#216
2026-04-07
Respondent / Jason
Objections - Misc
Page 7
PLEADING_BODY
OBJECTION TO PRO HAC VICE AND REQUEST ENFORCEMENT & STABILIZATION_72275AB8.pdf
..., re-entry, blanket objections, and end-of-window gamesmanship. In the second court, after Respondent warned that the same tactic would repeat, it did. 20. On January 6, 2026, the Court ordered compliance and set a hearing for January 9. Petitioner was found noncompliant. Another hearing on January 20 again resulted in noncompliance. A third hearing on February 5 followed, and again Petitioner remained noncompliant. At that hearing, Petitioner still could not produce even one complete bank statement for even one requested month from the relevant Chase ac...
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#216
2026-04-07
Respondent / Jason
Objections - Misc
Page 8
PLEADING_BODY
OBJECTION TO PRO HAC VICE AND REQUEST ENFORCEMENT & STABILIZATION_72275AB8.pdf
26. Petitioner's counsel churn has not been random. It repeatedly coincided with discovery pressure, was justified by claimed financial difficulty, and was later contradicted by financial records showing substantial funds and account activity. Respondent's Motion to Establish Conditions for Re-Entry of Counsel and to Preserve Fair Trial Procedures because the tactic had already been used to delay compliance, distort preparation, and force proceedings forward on unequal footing. The conditions requested here are therefore not speculative or newly invented...
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#216
2026-04-07
Respondent / Jason
Objections - Misc
Page 9
PLEADING_BODY
OBJECTION TO PRO HAC VICE AND REQUEST ENFORCEMENT & STABILIZATION_72275AB8.pdf
32. The record also remains burdened by protective-order allegations that Respondent contends did not occur and are contradicted by transcript, audio, video, and text- exhibits. A case built on disputed allegations and broken financial records message should not be further armed before the Court first addresses the foundation. Vil. THIS CASE HAS SPILLED INTO MULTIPLE COURTS, AGENCIES, AND FEDERAL FORUMS 33 This case is no longer contained within one family-court docket. It has spilled into multiple JP-court eviction proceedings, a county-court appeal fro...
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#216
2026-04-07
Respondent / Jason
Objections - Misc
Page 10
PLEADING_BODY
OBJECTION TO PRO HAC VICE AND REQUEST ENFORCEMENT & STABILIZATION_72275AB8.pdf
39. Respondent intended to call a former partner of Petitioner as a witness concerning Petitioner's alleged use of protective orders and related process to silence prior targets. Respondent contends that, on the eve of a hearing to extend a protective order involving that witness, the witness was arrested under suspicious circumstances, failed to appear, and a default extension was entered adding speech restrictions. Respondent further contends the protective-order extension package bearing Steele's office information was then injected into discovery, wi...
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#216
2026-04-07
Respondent / Jason
Objections - Misc
Page 11
PLEADING_BODY
OBJECTION TO PRO HAC VICE AND REQUEST ENFORCEMENT & STABILIZATION_72275AB8.pdf
d. the account or accounts from which those funds were paid. X. THE ASYMMETRY IS EXTREME, AND THE DAMAGE HAS SPREAD BEYOND THIS COURT 45. The asymmetry in this case is extreme. On one side is a party with repeated access to counsel, repeated ability to rotate firms, and the ability to fund not just lawyers but outside vendors, security-related activity, and continuing litigation escalation. On the other side is a party who has been eating from a food pantry, unable at times to afford heart medication, unable to fund transcripts, unable to stabilize housi...
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#216
2026-04-07
Respondent / Jason
Objections - Misc
Page 12
PLEADING_BODY
OBJECTION TO PRO HAC VICE AND REQUEST ENFORCEMENT & STABILIZATION_72275AB8.pdf
law firms, investigators, risk-mitigation vendors, security vendors, technology or cyber vendors, consultants, and any other case-related service provider, together with all sources of funds and proof of payment. Petitioner may not deplete or disguise community value through untraced litigation spend. Any claimed litigation expense that cannot be traced from source to recipient through competent source-record proof shall not be recognized as a valid community charge, shall not support further counsel expansion, shall not support any claim of financial in...
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#216
2026-04-07
Respondent / Jason
Objections - Misc
Page 13
PLEADING_BODY
OBJECTION TO PRO HAC VICE AND REQUEST ENFORCEMENT & STABILIZATION_72275AB8.pdf
h) No party shall enter, access, or attempt to access the marital residence or any disputed property except by written agreement, court order, or a scheduled transfer supervised by a neutral third party, civil standby, or other person approved by the Court. Any property retrieval shall occur only by written inventory, fixed date and time, and neutral supervision. approved written channel, neither party shall initiate direct contact with the other concerning disputed facts, property access, benefits, finances, or litigation issues. j) No party shall inter...
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#216
2026-04-07
Respondent / Jason
Objections - Misc
Page 14
PLEADING_BODY
OBJECTION TO PRO HAC VICE AND REQUEST ENFORCEMENT & STABILIZATION_72275AB8.pdf
54. Before any ruling on counsel expansion, the Court should set an emergency hearing on: a. healthcare restoration and HSA/FSA access; b. immediate stabilization relief; c. source-record discovery and funding disclosure; d. correction of unsupported factual predicates still operating in the record; and e. sanctions or enforcement for continuing obstruction. 55- The Court should order immediate make-whole relief sufficient to restore functional access to prescriptions, HSA/FSA funds, and the surgery previously blocked by the false QLE and continuing acce...
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#216
2026-04-07
Respondent / Jason
Objections - Misc
Page 15
PLEADING_BODY
OBJECTION TO PRO HAC VICE AND REQUEST ENFORCEMENT & STABILIZATION_72275AB8.pdf
...expenditures and third-party source-record relief; (5) enforce immediate healthcare and employer benefits reinstatement orders as well as the make whole relief for 2025/2026 lost benefits (HSA/FSA + out of pocket maximum benefits) restoration with automatic compliance settings; (6) appoint a neutral forensic accountant to reconstruct the estate back to August 2023; and (7) grant all other relief, at law or in equity, to which Respondent may be justly entitled. Respectfully Submitted, Jason McKemie (Pro Se) 539 W. Commerce St., Suite 2010 Dallas, Texas 7...
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#216
2026-04-07
Respondent / Jason
Objections - Misc
Page 16
EXHIBIT_START
OBJECTION TO PRO HAC VICE AND REQUEST ENFORCEMENT & STABILIZATION_72275AB8.pdf
EXHIBIT INDEX No exhibits are attached to this Exhibits referenced herein filing. 6. of42 TOOT Ty RESPONDENT'S OBJECTION TO JONATHAN DRAKE STEELE'S PRO HAC VICE ADMISSION DF-24-18010 Copy from re:SearchTX
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#216
2026-04-07
Respondent / Jason
Objections - Misc
Page 17
CERTIFICATE_OF_SERVICE
OBJECTION TO PRO HAC VICE AND REQUEST ENFORCEMENT & STABILIZATION_72275AB8.pdf
filing manager on April 7, 2026. JasonMmemie RESPONDENT'S OBJECTION TO JONATHAN DRAKE STEELE'S PRO HAC VICE ADMISSION DF-24-18010 Copy from re:SearchTX
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#216
2026-04-07
Respondent / Jason
Objections - Misc
Page 18
FILING_STAMP_OR_ESERVICE
OBJECTION TO PRO HAC VICE AND REQUEST ENFORCEMENT & STABILIZATION_72275AB8.pdf
...Description: RESPONDENT'S OBJECTION TO SWORN MOTION OF JONATHAN DRAKE STEELE TO APPEAR PRO HAC VICE, AND REQUEST PRIORITIZE ENFORCEMENT & STABILIZATION Status as of 4/7/2026 4:06 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Rebecca LArmstrong rebecca@armstronglawtexas.com 4/7/2026 3:08:09 PM SENT Terra Aguirre terra@armstronglawtexas.com 4/7/2026 3:08:09 PM SENT Lauren N.Shaw lauren@armstronglawtexas.com 4/7/2026 3:08:09 PM SENT Jason McKemie jmckemie@mckemie.net 4/7/2026 3:08:09 PM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.co...
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