DF-24-18010 Litigation Record Search

5/15/2026 11:58 PM DALLAS CO., TEXAS DF-24-1 80 1 0 NO THE MARRIAGE OF § § & § SUPPLEMENTAL NOTICE AND MOTION FOR MAY 21 HEARING TO THE HONORABLE JUDGE OF SAID COURT: Jason McKemie, Respondent, files this Supplemental Emergency Notice and Motion to Include Additional Relief at the hearing currently set before Associate Judge Stacy Dunlop on Thursday, May Courts Building, 600 Commerce Street, 3rd Floor New Tower, Dallas, Texas 75202, and respectfully shows the Court as follows: I. PURPOSE OF THIS SUPPLEMENT a. Respondent's Emergency Motion for Written Dis...

...itioner be ordered to deposit not less than $100,000.00 in interim attorney-fee advancement and litigation-expense funding within twenty-four hours of the Court's order. 15 This relief should be without prejudice to later characterization, sanctions, reimbursement, final property division, disproportionate division, or other final allocation, and should not be treated as an advance against Respondent's share of the marital estate absent further written order. IV. HEALTHCARE, MEDICATION, HSA/FSA, AND BENEFITS ACCESS 16. Respondent renews all prior healthc...

...de inaccessible. V. EVIDENCE THEFT, LITIGATION-CRITICAL DATA, AND NON-USE RELIEF 23. Respondent supplements his prior preservation requests to clarify that the April 16, 2026 event was not ordinary property loss. 24. This is evidence theft, not ordinary property loss. 25. During or immediately after the April 16, 2026 residence-entry and cleanout event, Petitioner and/or persons acting with her removed, took, destroyed, damaged, or made inaccessible Respondent's hard drives, computers, storage media, camera/network equipment, litigation files, financial...

29. Respondent cannot determine what has been accessed, copied, imaged, uploaded, deleted, altered, searched, disclosed, selectively preserved, selectively destroyed, or used while outside his custody. 30. Respondent requests an immediate preservation and non-use order prohibiting Petitioner, counsel, agents, investigators, vendors, security personnel, movers, family members, representatives, and all persons acting in concert with her from accessing, opening, reviewing, searching, browsing, copying, imaging, cloning, uploading, downloading, transferring,...

b. dates and times of activity; c. individuals assigned; d. devices, networks, accounts, or portals used; e. reports or deliverables generated; f. communications with Petitioner, counsel, law enforcement, or third parties regarding Respondent; g. any access to Respondent's devices, accounts, cloud storage, files, or litigation exhibits; h. records bearing on unauthorized access, exhibit corruption, remote activity, or litigation-related evidence handling. 38. Respondent further requests preservation and review regarding the pre-hearing binder incident, i...

46. Respondent has previously identified, subpoenaed, or sought testimony from Christopher McNally in this case. 47. Mr. Steele's involvement is prejudicial because he is actively involved in collateral protective-order and fee-enforcement proceedings against Christopher McNally while this Texas trial is pending. 48. Petitioner obtained a protective order against Christopher McNally, later obtained a judgment or fee award arising from proceedings at which Respondent understands Mr. McNally was not present, and Petitioner and/or her counsel are now pursui...

...on materials, exhibit repositories, and electronically stored information were removed, damaged, destroyed, discarded, or made inaccessible during or after the April 16, 2026 property/evidence event. 60. Petitioner should not be permitted to argue Respondent failed to produce records while Respondent's devices, drives, files, evidence repositories, and financial records remain missing, damaged, inaccessible, or outside his control following the April 16 event. 7 of 13 DF-24-1 8010 Copy from re:SearchTX

...-offset emergency relief unless the Court expressly states otherwise in a later written order. X. TRIAL ABATEMENT / CONTINUANCE 64. Respondent requests that the June 11, 2026 trial be continued or abated and that pretrial deadlines be suspended until the Court first resolves the conditions preventing fair trial. 65. This request is not sought for delay. It is sought so that justice may be done. 66. Good cause exists because: a. Petitioner has not produced complete certified financial source records; third-party subpoena leave and subpoena returns remain...

...Respondent gives notice that he requests the Court hear and decide the issues in this Supplemental Emergency Notice and Motion at the hearing currently set for Thursday, 2026. 68. Respondent requests a court reporter or other official verbatim record. 69. If the Court denies any requested relief, Respondent requests a written ruling identifying whether denial is based on lack of evidence, lack of legal authority, procedural defect, timing, scope, jurisdiction, mootness, prior ruling, or another stated ground. Xil. PRAYER 1. Respondent respectfully reques...

...bursement, coercive compliance relief, adverse inference, exclusion, contempt, non-offset monetary relief, or other appropriate relief; 15. continue or abate the June 11,2026 trial: 16. suspend pretrial deadlines until the Court cures the prejudice identified in this supplement; 17. require a court reporter or official verbatim record; 18. issue written rulings identifying the basis for any denial; and 19. grant all other relief to which Respondent is justly entitled. Respectfully submitted, Jason McKemie 539 W Commerce St, Ste 2010 Dallas, TX 75208 214-...

...review of the case record, my review of prior filings, 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, stolen, destroyed, inaccessible, or removed hard drives and litigation materials, my review of healthcare and benefits access issues, my review of financial and survival conditions, my prior involvement in matters involving Jonathan Drake Steele and Christopher McNally, my review of witness-related issues affecting Christopher McNally, and...

...CTICABILITY This filing is submitted as a supplemental notice of interrelated issues for the hearing already set before Associate Judge Stacy Dunlop on Thursday, May 21, 2026, at 1:30 p.m. Respondent is not seeking a new hearing date by this filing. Respondent is identifying interrelated issues and requested relief that arise from pending filings already before the Court. Because the hearing is already set, trial remains set for June 11, 2026, and the issues involve immediate stabilization, healthcare access, evidence preservation, witness protection, tr...

DF-24-18010 NO _ THE MARRIAGE OF § § & § SUPPLEMENTAL NOTICE OF TRIAL-READINESS, STABILIZATION, PRESERVATION, AND WITNESS-PROTECTION ISSUES FOR MAY 21, 2026 Hearing: Thursday, May 21, 2026 at 1:30 p.m. Before: Associate Judge Stacy Dunlop Location: George L. Allen, Sr. Courts Building 600 Commerce Street, 3rd Floor New Tower Dallas, Texas 75202 Respectfully submitted, Jason McKemie 539 W Commerce St, Ste 2010 Dallas, TX 75208 214-868-4901 jmckemie@mckemie.net 13 of 13 DF-24-18010 Copy from re:SearchTX

...The rules governing Envelope ID: 114989048 Filing Code Description: Notice Of Hearing / Fiat 21 HEARING Filing Description: SUPPLEMENTAL NOTICE FOR MAY Status as of 5/18/2026 9:28 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Kim Jones kjones@sullivancook.com 5/15/2026 11:58:57 PM SENT Jeffrey ECook jcook@sullivancook.com 5/15/2026 11:58:57 PM SENT Tiffany Castenada tcastenada@sullivancook.com 5/15/2026 11:58:57 PM SENT William CCook wcook@sullivancook.com 5/15/2026 11:58:57 PM SENT Rebecca LArmstrong rebecca@armstronglawtexas.com 5...