DF-24-18010 Litigation Record Search

5/11/2026 4:23 PM DALLAS CO., TEXAS DF-24-18010 NO. MARRIAGE OF § § § RESPONDENT'S EMERGENCY MOTION FOR WRITTEN DISCOVERY RULINGS, SUBPOENA LEAVE, EVIDENCE PRESERVATION, AND IMMEDIATE HEARING TO THE HONORABLE JUDGE OF SAID COURT: | , Respondent McKemie, Respondent pro se, files this Emergency Motion to Convert Prior Motion-to- Compel Compliance Hearings Into Written Rulings, Enforce Certified Financial Discovery, Grant Leave to Issue Third-Party Subpoenas, Preserve Evidence, and Set Immediate Hearing, and respectfully shows the Court as follows: I. EMERG...

...d complete institution-origin monthly statements, account continuity records, transaction-detail pages, custodian-verifiable records, and third-party subpoena authority. 11. The prior record reflects repeated issues with incomplete financial production, including missing monthly statements, missing transaction-detail pages, duplicate or recycled production, editable activity exports, missing account continuity, and lack of institution-origin certified records. 12. Respondent requests that the Court enter written rulings on the prior motion-to-compel and...

16. The marital estate cannot be fairly divided without complete, certified, institution-origin financial records. 17. Respondent requests an order requiring Petitioner to produce, within three calendar days, complete certified financial records including: a. complete monthly statements, all pages, for every bank account, credit card, brokerage account, investment account, retirement account, HSA, FSA, reimbursement account, business account, trust account, payroll account, benefit account, and financial account used, controlled, accessed, funded, or ben...

...d Petitioner's incomplete production has made third-party verification indispensable. V. APRIL 16 EVIDENCE THEFT / HARD-DRIVE LOSS MAKES RELIEF CRITICAL 24. On April 16, 2026, Petitioner participated in, coordinated, authorized, benefited from, or failed to prevent an entry/cleanout/property-removal event at Respondent's residence. DF-24-18010 4 of 12 Copy from re:SearchTX

25. After that event, Respondent discovered missing, damaged, destroyed, contaminated, or inaccessible computers, hard drives, storage media, litigation records, exhibit files, financial analysis, contradiction maps, trial-preparation materials, professional equipment, and evidence repositories. 26. The missing/damaged devices included materials used to organize and prove approximately sixteen months of litigation work. 27. Respondent has had to attempt reconstruction while simultaneously dealing with loss of computer access, delayed internet access, pro...

property, accessed property, copied data, discarded property, destroyed property, or transferred property; e. identify the current location of every item removed; f. return all computers, hard drives, storage media, litigation files, financial records, and evidence repositories through a neutral forensic protocol or make them available for neutral forensic imaging before either party accesses them. Vil. GOOD CAUSE AND NO TACTICAL DELAY 31. Respondent did not delay. 32. The April 16 event disabled Respondent's ability to litigate and delayed his ability t...

.... Texas Rule of Civil Procedure 196 governs requests for production and inspection of documents, tangible things, and electronic data. 41. Texas Rule of Civil Procedure 205 governs discovery from nonparties by subpoena. 42. Texas Rule of Civil Procedure 215 authorizes orders compelling discovery and sanctions for discovery abuse, incomplete responses, evasive responses, delay, and resistance to discovery. 43. The Court also has inherent authority to preserve evidence, protect the integrity of proceedings, enforce prior orders, prevent abuse of process, a...

...on my personal knowledge, my review of the case record, my review of prior discovery submissions, my review of the condition of my residence and property after April 16, 2026, my attempts to identify missing/damaged hard drives and litigation materials, and my review of the docket and prior filings. DF-24-18010 8 of 12 Copy from re:SearchTX

Jason McKemie DF-24-18010 9 of 12 Copy from re:SearchTX

CERTIFICATE OF CONFERENCE discovery remains incomplete, prior compliance issues require written rulings, third-party subpoenas are necessary for estate verification, and evidence repositories/hard drives were stolen, removed, damaged, or made inaccessible after the April 16 event. Respondent has attempted or will attempt to confer with counsel regarding immediate hearing availability and preservation of evidence. Given the imminent trial deadline and preservation risk, Respondent files this motion immediately to preserve rights and prevent further prejud...

Rules of Civil Procedure on May 11, 2026. Meh Jason McKemie DF-24-18010 11 of 12 Copy from re:SearchTX

...ellaneous Filing Description: RESPONDENT'S EMERGENCY MOTION FOR WRITTEN DISCOVERY RULINGS , SUBPOENA LEAVE, EVIDENCE PRESERVATION AND IMMEDIATE HEARING Status as of 5/12/2026 10:59 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Kim Jones kjones@sullivancook.com 5/11/2026 4:23:11 PM SENT Lauren N.Shaw lauren@armstronglawtexas.com 5/11/2026 4:23:11 PM SENT Jason McKemie jmckemie@mckemie.net 5/11/2026 4:23:11 PM SENT Gwendolyn Ulijasz gulijasz@gmail.com 5/11/2026 4:23:11 PM SENT JASON EMORYMCKEMIE jason@callvital.com 5/11/2026 4:23:11 P...