DF-24-18010 Litigation Record Search

6/4/2026 1:29 PM DALLAS CO., TEXAS DF-24-18010 NO. THE MARRIAGE OF § § & § JASON MCKEMIE'S REQUEST FOR DE NOVO HEARING; OBJECTIONS TO ASSOCIATE JUDGE'S REPORT; REQUEST TO STAY ENTRY AND EFFECT OF REPORT PENDING DE NOVO REVIEW; REQUEST FOR EMERGENCY SETTING BEFORE REFERRING COURT; AND REQUEST FOR ADEQUATE EVIDENTIARY TIME, COURT REPORTER, EXHIBIT ADMISSION, WITNESS TESTIMONY, AND WRITTEN RULINGS TO THE HONORABLE JUDGE OF SAID COURT: Respondent, Jason McKemie, files this Request for De Novo Hearing under Texas Family Code § 201.015 and objects to the Assoc...

...ent, Sanctions, Continuance, and Leave to Issue Third-Party Subpoenas. 2. The refusal or failure to consider Jason's continuance / abatement request despite the June 11, 2026, trial setting and the unresolved source-record, discovery, healthcare, stolen-evidence, and trial-readiness defects. 3. The denial of leave to issue third-party subpoenas for financial source records, including but not limited to bank records, credit-card records, payment-source records, overpayment/refund records, replacement-card/account-lineage records, payroll records, Accentur...

...cked benefits access, OQLE/benefits issues, HSA/FSA functionality, medical reimbursement control, and administrator access. 12.The denial or failure to address April 16, 2026 evidence theft, stolen hard drives, stolen evidence repositories, stolen devices, stolen litigation files, stolen financial records, stolen trial-preparation materials, stolen medical/legal records, stolen professional records, stolen electronics, stolen music/studio equipment, stolen medication, stolen safes/briefcases, and the resulting chain-of-custody crisis. 13.The denial or fa...

...functional litigation infrastructure, and unresolved witness-protection issues. 20.Any finding, conclusion, recommendation, refusal, or omission that permits the June 11,2026trial to proceed before the District Judge conducts de novo review and before source-record verification, stolen-evidence relief, healthcare enforcement, and trial-readiness defects are resolved. 21.Anyfinding,conclusion,recommendation,refusal,oromissionthattreatstheJune1 hearing as a merits adjudication. 22.Any finding, conclusion, recommendation, refusal, or omission that treats Ja...

...or prior representations. Jason was unable to overcome those objections in the compressed setting. Asa result: 1. No meaningful exhibit record was admitted. 2. No Rule 1006 summary chart was admitted and tested. 3. No complete production-gap chart was admitted and tested. 4. No source-record deficiency chart was admitted and tested. 5. No witness testimony was fully developed. 6. No complete offer of proof was made. 7. No merits adjudication occurred on the actual source-record issues. 8. No merits adjudication occurred on the stolen-evidence issues. 9....

...mony; 3. Petitioner's sworn financial materials; 4. Jonathan Drake Steele's affidavit and fee/protective-expense request; 5. production indexes and Bates logs; 6. Rule 1006 source-record summary charts; 7. missing-statement and account-continuity charts; 8. VEIP/equity/payroll/Accenture compensation records; 9. HSA/FSA/healthcare/OLE/benefits records; 10.April 16 theft and chain-of-custody evidence; 11.recordsidentifyingmissing/stolenharddrives,devices,litigationrecords,trial materials, financial records, and evidence repositories; 12. prior notices and...

...ive materials; 11 .permits trial to proceed before de novo review and before the District Judge resolves trial-readiness defects. VI. REQUEST TO CONTINUE OR ABATE JUNE11,2026, TRIAL PENDING DE NOVO REVIEW Trial is presently set for June 11, 2026. The District Judge cannot conduct meaningful de novo review after trial has already occurred. The denial of subpoena leave, refusal to consider continuance, failure to decide source- record verification, failure to address stolen evidence, failure to enforce healthcare, and failure to address trial-readiness def...

Jason therefore requests that the Court immediately continue or abate the June11,2026 trial setting until: 1. the District Judge conducts the de novo hearing; 2. the Court makes written rulings on each specified issue; 3. third-party source-record subpoenas are authorized and returned; 4. healthcare/HSA/FSA/OLE/benefits issues are enforced; 5. stolen-evidence non-access, non-use, preservation, and return relief is entered; 6. Petitioner's protective-order and fee/protective-expense requests are denied in full; 7. the Court determines whether the marital...

6. CONTINUE or ABATE the June 11,2026, trial setting until the marital estate can be reconstructed from complete, continuous, source-verifiable records; 7. DENY Petitioner's Counter-Motion for Protective Order in full to the extent it blocks, restricts, burdens, delays, chills, or prevents source-record verification; 8. DENY Petitioner's request for attorney's fees, court costs, protective expenses, expert/vendor expenses, discovery expenses, or any cost shifting against Jason McKemie in full, with no later prove-up, no reserved entitlement, and no cost...

16.PRESERVEandSETFORHEARINGJason McKemie's requests for fraud-on-the- community findings, fraud-upon-the-Court findings, estate reconstitution under Texas Family Code § 7.009, disproportionate division under Texas Family Code § 7.001, adverse inferences, reimbursement, add-backs, fee shifting against Petitioner and responsible counsel, sanctions, healthcare enforcement, stabilization relief, and April 16 theft remedies; 17.REQUIREwritten rulings on every item granted, denied, or otherwise decided, identifying whether any denial is based on lack of eviden...

hearing before the June 11,2026trial setting; and require written rulings identifying whether each item is granted, denied, deferred for separate setting, or not reached. sanctions motion. Jason requests de novo review of the sanctions, show-cause, counsel-certification, fee-shifting, protective-order abuse, and source-record verification issues to the extent those issues were already raised by the filings and hearing record before or at the June 1, 2026, hearing. To the extent the Court determines that any sanctions, counsel-certification, witness-prote...

6. |was not provided the full amount of time originally allotted to present evidence and argument concerning enforcement, sanctions, continuance, third-party subpoena leave, source-record verification, healthcare enforcement, trial-readiness defects, stolen evidence repositories, and Petitioner's protective-order and fee/protective- expense requests. 7. When attempted to present evidence concerning written email communications between me and Petitioner's former counsel, Petitioner's counsel repeatedly | was attempting to identify, authenticate, objected...

...bility to share digitally prepared evidence as planned, my ability to present and submit evidence was significantly impaired. Executed in Brazos County, Texas on June 4, 2026. Respectfully Submitted, Jason McKemie 539 W. Commerce St., Suite 2010 Dallas, Texas 75208 214-868-4901 jmckemie@mckemie.net accordance with the Texas Rules of Civil Procedure on June 4, 2026. Jobe Jason McKemie DF-24-18010 Request for De Novo Hearing on Respondent's: Motion for Enforcement, Sanctions, Continuance, and Leave to Issue Third-Party Subpoenas! Copy from re:SearchTX

EXHIBIT INDEX Exhibit 1 Order Reserving Sanctions, Fee Shifting, Estate Reconstitution, Adverse Inferences, And Healthcare Enforcement For Further Hearing Exhibit 2 Order Granting Leave to Issue Third-Party Subpoenas for Financial, Lease, QLE, Benefits, And Estate Source Records Exhibit 3 Order Granting Leave to Issue Third-Party Subpoenas Concerning April16 Theft, Movers, Security, Contractors, And Chain of Custody Exhibit 4 Subpoena Targets Exhibit 5 Respondent's Motion for Enforcement, Sanctions, Continuance, And Leave to Issue Third-Party Subpoenas E...

Exhibit -7 Continued. EXHIBIT INDEX Exhibit Title Purpose Procedural history demonstrating repeated filings, unresolved motions, - Exhibit A Motion to Recuse Pleading History discovery disputes, and case-management failures. Notice to Petitioner and counsel regarding discovery deficiencies, Exhibit B Discovery Email missing records, and requests for compliance. Demonstrates Respondent's financial condition, expenses, inability to Exhibit C Sworn Budget absorb continued delay, and need for relief. High Liquidity While Declaring Contradicts claims of finan...

...Enforcement, Sanctions, Continuance, and Leave to Issue Third-Party Subpoenas and respectfully shows the Court as follows: I. RELIEF REQUESTED Trial is set for June 1 1, 2026. This motion requests multiple forms of relief, but the threshold issue for the June 1 hearing is trial readiness: No source records, no estate reconstruction. No estate reconstruction, no final trial. Movant requests that the Court: 1. Continue the June 11, 2026 trial setting; 2. Grant leave to issue third-party subpoenas for source records concerning financial accounts, VEIP/equit...

...reconstitution of the estate when actual or constructive fraud on the community has occurred, including appropriate legal and equitable relief. Texas Rule of Evidence 1006 permits summary charts and calculations for voluminous records. Movant intends to attach a visual production-gap chart as a Rule 1006 summary exhibit, with underlying records identified and made available as required. Ill. WHY THIS MOTION IS NECESSARY: SYSTEMIC NONCOMPLIANCE This is not a routine discovery dispute. These proceedings are now in their third district, and the discovery r...

...t was an obvious refusal to provide reliable source records. In the 302nd District Court, Cca motion to compel was granted or reflected as granted on or about January 6, 2026. Petitioner was then found noncompliant on or about January 9, January 20, and February 5, 2026. Each time, Petitioner represented with increasing force that she was finally compliant. Between January 6 and February 5, Respondent did not receive a single additional page that cured the defects. Respondent was instructed to draft a proposed order to bring these proceedings to an exped...

3. Credit-card balances paid off multiple times per month; 4. Significant overpayments to cards; 5. At least one card with approximately $67,000 in overpayments; 6. No reliable way to determine payment source from party-produced statements; 7. No reliable way to determine whether overpayments generated refunds, credits, transfers, or concealed liquidity; 8. No reliable account-lineage records connecting old card numbers, new card numbers, reissued cards, replacement cards, or linked accounts; 9. No single account with contiguous statements from August 20...

6.. Payroll deductions; 7.. Employer reimbursements; 8. VEIP/equity investment activity; 9. Tax withholding versus equity contribution classification; 10. IRS/tax payments; 11. Loan origination and funding; 12. San Antonio housing reimbursement; 13. Lease payoff/buyout records; 14. Legal retainer payment sources; 15.Third-partycontractorpaymentsources; or 16.April 16 theft chain of custody. Only third-party source records can do that. If Petitioner has been fully forthcoming and compliant with discovery, then this will be a simple and painless process. T...

...tax emails, or screenshots. It requires employer-origin, payroll-origin, equity-plan-origin, tax-origin, and bank-origin source records. VII. VISUAL GAP CHART / RULE 1 006 SUMMARY Movant intends to attach a visual summary showing missing account-statement continuity and production gaps. The exhibit should be treated as: - Exhibit A Rule 006 Summary Chart of Financial Production Gaps The chart is offered to show the Court the structural record problem: no account has contiguous source-record coverage from August 2023 through present. Movant will make the...

1. The accounts cannot be mapped; 2. Account numbers cannot be tied to replacement cards; 3. Payments cannot be sourced; 4. Overpayments cannot be traced; 5. Credits/refunds cannot be located: 6. Loans cannot be authenticated; 7. Tax claims cannot be verified; 8. Employer reimbursements cannot be traced; 9. Legal and contractor spending cannot be allocated; and 10.The estate cannot be reconstructed. No source records, no estate reconstruction. No estate reconstruction, no final trial. IX. SAN ANTONIO HOUSING / RENT / EXPENSE REPORTS Petitioner's San Anto...

X. DISSIPATION, WASTE, AND ADD-BACKS REQUIRING SOURCE RECORDS Movant requests third-party source-record discovery concerning dissipation, waste, reimbursement, and add-back issues, including: A. Elective Cosmetic Surgery e Petitioner pursued elective cosmetic surgery despite objection from Movant and Movant's prior counsel. Movant requests invoices, payment records, financing records, loan documents, card payments, bank payments, and any related communications so those amounts can be added back, reimbursed, offset, or charged to Petitioner's side of the...

13. Risk-mitigation firms; 14. Reputational-defense vendors; 15. Due-diligence vendors; 16. Employment-interference vendors; 17. Investigators; 18.All My Sons; 19. Merritt McClayton; 20. Movers, storage providers, booking entities, and third-party payers; and 21.Anyentitypaidtoinvestigate,package,transmit,publish, or support claims against Movant. e Legal fees and legal-adjacent expenditures should be traced and allocated. Movant requests that legal fees be subject to 50% reimbursement/add-back where community funds were used, and that third-party contra...

...shares requiring preservation, tracing, and third-party verification: Category Calculation Amount Sign-on bonus 1/2 of $300,000 $150,000 Cognizant settlement 1/2 of $156,045 $78,022.50 VEIP/equity 1/2 of $195,000 $97,500 DF-24-18010 Motion for Enforcement, Sanctions, Continuance, & Leave Page 10 of 17 Copy from re:SearchTX

Category Calculation Amount Salary 1/2 of $390,000 $195,000 Annual bonus 1/2 of $49,893 $24,946.50 Rent reimbursement / lease guarantor issue reimbursement claimed $30,000 Additional dissipation / add-backs to be traced TBD Movant also asserts that approximately $650,000 went missing before the divorce proceedings and requires source-record reconstruction. These figures are not the full estate calculation. They are minimum categories proving why the estate cannot be tried without third-party records. Xil. APRIL 16 THEFT IS PART OF THE SAME PATTERN The Ap...

7. Technical work; 8. Network designs; 9. Presentations; 10.Talking points; 11.Research: 12. Music/studio materials; 13. Professional records; and 14. Data necessary to rebut Petitioner's false non-contributor narrative. Before April 16, party production was already impossible as a cure. But Movant at least had his own records. Now he has nothing. Petitioner stole the records Movant built to reconstruct the estate, prove contribution, respond to discovery, and prepare for trial. She should not be permitted to steal the evidence, obstruct third- party rec...

13. Bodycam/dashcam/open-records custodians; 14. Jetty Partners; 15. Decisive Resources; 16.Anycontractorinvolvedinplanning,funding,booking,executing,transporting,receiving, storing, accessing, using, or concealing stolen property; and 17.Any person or entity with records concerning stolen hard drives, devices, GPUs, network storage, music studio equipment, medication, financial records, litigation records, safes, briefcases, or other stolen property. The purpose is source verification, chain of custody, preservation, and trial readiness. XIV. VEIP FRAUD...

XV. THIS DIVORCE SHOULD HAVE ENDED LONG AGO This divorce should have ended in March 2025. It did not end because Petitioner's obstruction, false financial narratives, discovery gamesmanship, healthcare obstruction, lease/eviction manipulation, late production, source-record concealment, and April 16 theft kept expanding the dispute. Petitioner has wasted Movant's time, the Court's time, and the resources of everyone forced into this itigation. Petitioner has also caused severe harm to Movant and his parents through financial ambush, manufactured instabil...

...Court to address financial source records first. XVIII. PRAYER Movant respectfully requests that the Court grant this Motion and enter orders: 1. Continuing the June 11, 2026 trial setting; 2. Granting leave to issue third-party subpoenas; 3. Modifying discovery deadlines for source-record discovery; 4. Authorizing subpoenas concerning financial, VEIP/equity, tax, loan, San Antonio housing, lease/payoff, OLE/benefits, healthcare, Accenture, legal-retainer, contractor, and April 16 theft records; 5. Setting a status hearing after subpoena returns; 6. Rese...

Jason McKemie 539 W. Commerce St., #2010 Dallas, Texas 75208 214-868-4901 jmckemie@mckemie.net DF-24-18010 Motion for Enforcement, Sanctions, Continuance, & Leave Page 16 of 17 Copy from re:SearchTX

VERIFICATION / UNSWORN DECLARATION My name is Jason McKemie. | am over eighteen years of age, of sound mind, and competent to make in this Motion, and they are true and this declaration. have personal knowledge the facts stated correct to the best of my knowledge. | declare under penalty of perjury that the foregoing is true and correct. JasonJobeMcKemie JasonJobeMcKemie DF-24-18010 Motion for Enforcement, Sanctions, Continuance, & Leave Page 17 of 17 Copy from re:SearchTX

...: Motion - Mod/Enf Other (Sapcr) (Oca Pja) Filing Description: MOTION FOR ENFORCEMENT, SANCTIONS, CONTINUANCE, AND LEAVE TO ISSUE THIRD-PARTY SUBPOENAS Status as of 5/28/2026 11:47 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Kim Jones kjones@sullivancook.com 5/26/2026 11:59:10 PM SENT Tiffany Castenada tcastenada@sullivancook.com 5/26/2026 11:59:10 PM SENT William CCook wcook@sullivancook.com 5/26/2026 11:59:10 PM SENT Rebecca LArmstrong rebecca@armstronglawtexas.com 5/26/2026 11:59:10 PM SENT Terra Aguirre terra@armstronglawtexas...

5/29/2026 3:42 PM DALLAS CO., TEXAS NO. DF-24-18010 THE MARRIAGE OF GWENDOLYN ULIJASZ-MCKEMIE JASON MCKEMIE PETITIONER'S RESPONSE TO RESPONDENT'S MOTION FOR ENFORCEMENT, SANCTIONS, CONTINUANCE, AND LEAVE TO ISSUE THIRD-PARTY SUBPOENAS, AND COUNTER-MOTION FOR PROTECTIVE ORDER AND FOR OTHER APPROPRIATE RELIEF TO THE HONORABLE JUDGE OF SAID COURT: Petitioner Gwendolyn Ulijasz-McKemie ("Petitioner" or "Gwen") files this Response to Respondent Jason McKemie's May 26, 2026 Motion for Enforcement, Sanctions, Continuance, and Leave to Issue Third-Party Subpoenas...

subpoenas because he says the records he wants are not in his hands today. He asks to reserve sanctions, adverse inferences, estate reconstitution, property-return remedies, and April 16 remedies because he says those issues should be revisited after subpoena returns that do not yet a continuance exist. A party who sat on the discovery tools available to him cannot manufacture by pointing to the discovery he chose not to pursue. Granting the Motion would transform a final-trial setting into a new third-party investigation, without proposed subpoenas, wit...

1. continue the June 11, 2026 trial setting; 2. grant leave to issue third-party subpoenas for financial accounts, VEIP/equity, tax records, loans, San Antonio housing/rent, lease payoff, QLE/benefits, Accenture records, legal retainers, third-party contractors, April 16 theft, movers, security contractors, All My Sons, Merritt McClayton, Decisive Resources, Jetty Partners, and all related custodians; 3. modify the discovery deadline for third-party source-record discovery and related follow- up discovery; 4. enforce alleged prior discovery rulings and o...

...ted within 18, 2024. This case has now been pending for roughly eighteen months and has moved through multiple settings and courts. It is set for final trial on June 11, 2026. A marriage of roughly five months has generated roughly eighteen months of litigation. The discovery period has run its course. Rather than try the case on the developed record, Respondent's May 26 Motion seeks to reopen discovery and reset the trial so he can begin a new third-party investigation, without proposed subpoenas, without custodian-specific requests, and without the dil...

...ds" slogan Petitioner has produced records. Respondent's Reject slogan; require complaint is alleged incompleteness, not zero chart and underlying production. The Rule 1006 chart referenced in records before any Rule the Motion is not a substitute for authenticated 1006 reliance. underlying records. VEIP/equity theory No custodian declaration, CPA opinion, Treat as trial merits issue, forensic accounting report, payroll-origin not continuance predicate record, equity-plan-origin record, or tax-origin record attached supporting the alleged gain or lestate...

it, the cause of failure, that the testimony cannot be obtained from any other source, the witness's name and residence if the continuance is based on an absent witness, the expected testimony, and that the continuance is not sought for delay. Tex. R. Civ. P. 252. Diligence is the heart of the inquiry. A party who failed to use the discovery tools available during the discovery period has not shown the diligence Rule 252 requires, and a continuance motion that does not set forth the evidence sought, its materiality, and the due diligence used to obtain i...

...al Gas Corp. v. Powell, 811 S.W.2d 913, 917-18 (Tex. 1991); Chrysler Corp. v. Blackmon, 841 S.W.2d 844, 849 (Tex. 1992); Cire v. Cummings, 134 $.W.3d 835, 839-42 (Tex. 2004). Newkirk Logistics reaffirms the same proportionality framework for discovery sanctions. In re Newkirk Logistics, Inc., 718 S.W.3d 240 (Tex. 2025). Spoliation and adverse-inference relief require an evidentiary record and are not appropriate on conclusory allegations. Brookshire Bros., Ltd. v. Aldridge, 438 S.W.3d 9, 23-26 (Tex. 2014). Forensic imaging is intrusive and requires a pre...

...umber alone. Those orders include an order terminating the automatic stay to permit the landlord to pursue eviction remedies; an order entered the afternoon of April 16, 2026 reinstating the automatic stay and directing that writ enforcement cease; and a later order extending Respondent's move-out deadline and expressly reserving claims for rent, expenses, damages, and automatic-stay violations for separate motion or adversary proceeding. The Bankruptcy Code excepts certain domestic-relations matters from the automatic stay, including dissolution proceed...

spoliation, turnover, stay violations, damages, or ownership of allegedly removed estate property on Respondent's conclusory record. V. Argument A. The continuance should be denied because discovery is closed and Respondent was not diligent. The dispositive point is the simplest one. Discovery closed. During the discovery period, Respondent could have served Rule 205 notices and applied to this Court for leave to subpoena any bank, Accenture, the taxing authorities, the landlord, the moving company, or any other custodian he now claims he needs. Nothing...

...a Level 3 or custom discovery-control order changing the deadline, default Level 2 discovery in a Family Code suit ends thirty days before trial. With trial set June 11, 2026, Respondent's May 26 request is facially outside ordinary nonparty-discovery timing. Petitioner is confirming whether a September 8, 2025 302nd District Court pretrial order modified the default schedule; either way, Respondent has not supplied the proposed subpoenas or the diligence record required to reopen discovery on the eve of trial. The interest of justice does not favor reop...

...ions at this hearing, Petitioner objects on grounds including foundation, authentication, hearsay, relevance, Rule 403, and lack of competent source proof. E. The Rule 1006 chart reference is not proof. The Motion states that Respondent "intends" to attach a visual summary or that the chart "should be treated" as Exhibit A. A missing or unsupported chart is not evidence. Even a proper Rule 1006 summary requires underlying records to be made available and a sponsoring witness competent to explain the summary. The Court should not continue a final trial be...

...k for themselves. One order terminated the automatic stay to permit the landlord to pursue forcible-detainer remedies. A second order, entered the afternoon of April 16, 2026, reinstated the automatic stay and directed that writ enforcement cease. A third order extended Respondent's move-out deadline and expressly reserved claims for rent, expenses, damages, and automatic-stay violations for separate motion or adversary proceeding. No bankruptcy order adjudicated theft, spoliation, stay violation, damages, property ownership, or turnover against Petition...

H. Sanctions, adverse inference, reconstitution, and related remedies are premature. Respondent asks to reserve sanctions, fee shifting, adverse inferences, estate reconstitution, reimbursement, offsets, healthcare enforcement, property return, and April 16 remedies pending subpoena returns and further hearing. That request concedes that the current record is not the record on which those remedies can be decided. The Court should deny those requests without prejudice to properly noticed, evidence-supported motion practice if a proper record is later deve...

motions to quash, motions for protection, privilege and work-product claims, confidentiality objections, cost and proportionality objections, and bankruptcy-estate objections are preserved. B. Litigation-vendor and law-firm protection. No subpoena should issue to any opposing counsel, law firm, legal-retainer custodian, litigation consultant, investigator, security vendor, communications vendor, reputation vendor, OSINT or cyber vendor, witness-preparation participant, consulting expert, or litigation-support vendor absent prior leave of Court, a specifi...

...mount be determined by further submission or hearing. VIII. Prayer Petitioner respectfully requests that the Court: 1. deny Respondent's request to continue the June 11, 2026 trial setting; 2. deny Respondent's request for leave to issue third-party subpoenas; 3. deny Respondent's request to modify discovery deadlines; 4. deny Respondent's request to enforce alleged prior discovery rulings absent signed orders, exact obligations, service, deadlines, and proof of violation; 5. deny Respondent's requests for sanctions, fee shifting, adverse inferences, est...

8A.in the alternative, if the Court determines that the property division portion of the June 11, 2026 trial requires coordination with the Chapter 7 trustee or further bankruptcy-court action, sever and reserve the property division portion only, with the dissolution of marriage and any matters expressly excepted from the automatic stay under 11 U.S.C. § 362(b)(2) proceeding on June 11, 2026 as scheduled; 9. award Petitioner reasonable attorney's fees, court costs, expenses, and protective expenses incurred in responding to the Motion and obtaining prot...

By: /s/ Jonathan D. Steele JONATHAN D. STEELE Page 17 of 17 Copy from re:SearchTX

...texas.com Envelope ID: 115516576 Filing Code Description: Response Filing Description: TO MOTION FOR ENFORCEMENT AND COUNTER MOTION FOR PROTECTIVE ORDER Status as of 6/1/2026 10:16 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Kim Jones kjones@sullivancook.com 5/29/2026 3:42:21 PM SENT Jeffrey ECook jcook@sullivancook.com 5/29/2026 3:42:21 PM SENT Tiffany Castenada tcastenada@sullivancook.com 5/29/2026 3:42:21 PM SENT William CCook wcook@sullivancook.com 5/29/2026 3:42:21 PM SENT Rebecca LArmstrong rebecca@armstronglawtexas.com 5/29...

DF-24-18010 NO. THE MARRIAGE OF § § § RESPONDENT'S REPLY IN SUPPORT OF ENFORCEMENT, SANCTIONS, CONTINUANCE, AND LEAVE; OBJECTION TO PETITIONER'S BAD-FAITH PROTECTIVE ORDER AND FEE REQUEST; AND REQUEST FOR SANCTIONS, SHOW-CAUSE, COUNSEL CERTIFICATION, FEE SHIFTING, FORENSIC ACCOUNTING, ESTATE RECONSTITUTION, DISPROPORTIONATE DIVISION, AND SOURCE-RECORD VERIFICATION TO THE HONORABLE JUDGE OF SAID COURT: Jason McKemie files this Reply in Support of his Motion for Enforcement, Sanctions, Continuance, and Leave to Issue Third-Party Subpoenas, and objects to P...

e Ascreenshot is not a source record. e Atax email is not an IRS transcript. e A family note is not a funded loan. e A"fraud/no access" claim is not a financial disclosure. Il. THIS IS NOT PETITIONER'S "ABUSE" OR "STALKING" CASE.ITISA FRAUD CASE DISGUISED AS A VICTIM NARRATIVE. Petitioner wants this Court to evaluate this case through the frame she created: abuse, stalking, fear, and victimhood. That frame is not the case. It is the mechanism used to divert attention away from the financial records. The issue before this Court is not whether Jason McKemi...

e Apperson genuinely seeking protection does not report a legal retainer as fraud, cut off access to counsel, and then escalate into protective-order litigation. e Aperson genuinely seeking protection does not testify that she has not and will not interfere with healthcare and then submit a Qualifying Life Event terminating coverage before a scheduled surgery. e Aperson genuinely seeking protection does not report a Health Savings Account card ost or stolen while the other party is hospitalized and actively seeking medical treatment. e Aperson genuinely...

e The Court should reject that frame. e This is not an abuse case. e This is not a stalking case. e This is a fraud case. e And counsel are now inside it. Jonathan Drake Steele voluntarily placed his review and certification process at issue through his affidavit. He did not identify a single complete continuous institution-origin account. He did not identify complete payroll records. He did not identify complete VEIP records. He did not identify complete myHoldings records. He did not identify complete tax records. He did not identify complete loan-fund...

...er 23, 2025 Motion for Leave and Proposed Order Granting Leave to Serve Subpoenas; December 29, 2025 - Supplemental Submission in Support of Motion to Compel; January 8, 2026 - Proposed Order on Motion to Compel; January 20, 2026 - noncompliance concerning certified financial production; February 2, 2026 - Motion to Compel Complete Financials; February 5, 2026 - repeated noncompliance concerning certified financial production; February 10, 2026 - proposed verification/status orders; May 26, 2026 - present Motion for Enforcement, Sanctions, Continuance, a...

That is the litigation strategy Petitioner has used from the beginning: obstruct, accuse, delay, manufacture collapse, then blame Jason for the collapse Petitioner created. IV. STEELE'S AFFIDAVIT DOES NOT PROVE COMPLIANCE. IT CERTIFIES THE FALSEHOOD. Jonathan Drake Steele voluntarily placed counsel review and certification directly at issue. His affidavit states that he was actively involved in the preparation and review of Petitioner's discovery production. He identifies a production index and Bates range. He does not identify a single complete continuo...

Jason expressly seeks sanctions against Petitioner, Jonathan Drake Steele, Rebecca L. Armstrong, Sullivan & Cook, and any attorney who certified, sponsored, presented, defended, relied upon, or attempted to shield materially incomplete financial production from verification. V. PETITIONER'S PROTECTIVE ORDER IS BAD-FAITH DISCOVERY OBSTRUCTION. in n full. Petitioner's protective order should be denied Petitioner is not asking the Court to protect privileged communications. She is asking the Court to protect missing source records from being tested. She wan...

That is why she seeks protection. VI. THE VEIP / "EXTRA TAX WITHHOLDING" ISSUE IS FRAUD, NOT CONFUSION. Petitioner labeled or allowed equity investment activity to be treated as "extra tax withholding." That is fraud. The Accenture compensation record shows the compensation structure was not ambiguous. Petitioner's compensation included salary, sign-on bonuses, annual bonus, VEIP/equity deductions, RSUs, taxable RSU activity, and equity-plan benefits. VEIP is not "extra tax withholding." VEIP is an elective stock-purchase/equity program. RSU share withho...

spending, then the alleged hardship underlying the claimed loan did not exist. If the hardship did exist, then the equity purchases and elective expenditures become evidence of dissipation and waste. Either way, absent source records proving the loan was actually funded, received, and used for a legitimate community purpose, the alleged obligation fails as a credible community debt claim. e Aclaimed loan is not a loan because Petitioner says so. e Apromissory note without traceable funding is not proof of a loan. e Atax "prediction" email is not a tax tr...

They contained 17 months of exhibits, financial reconstruction work, discovery materials, trial preparation, Accenture contribution evidence, professional records, music/studio materials, technical work, and evidence necessary to rebut Petitioner's false non-contributor narrative. Petitioner then attempted to transform her possession of Jason's stolen property into a victim narrative. She stole devices and property from Jason's residence, took them to her own residence or into her control, and then treated the presence/location of Jason's devices as evid...

Petitioner now asks the Court to shift fees, costs, protective expenses, and litigation expenses against Jason. That request is offensive. Petitioner has stretched this divorce across 17 months of financial concealment, discovery obstruction, healthcare obstruction, false narratives, protective-order gamesmanship, late production, source- record concealment, housing destabilization, forced bankruptcy pressure, and April 16 theft. e Jason is homeless. e Jason has been denied functional healthcare access. e Jason has been blocked from heart medication and...

10. litigation conduct designed to convert missing records into trial advantage. Jason further requests that the Court require sworn counsel certification within three calendar days identifying: 1. every financial account known to Petitioner or counsel; 2. every account number, replacement account number, replacement card number, closed account, successor account, and related account lineage; 3.. every month for which a complete institution-origin statement was produced; 4. every month missing or incomplete; 5 every document Petitioner claims is a source...

9. healthcare enforcement; 10. stabilization relief; 11. neutral court-appointed forensic accounting; 12. source-record subpoenas; 13.trial continuance or abatement until the estate can be reconstructed. The forensic accountant must be court-appointed and neutral, but the accountant's work must be limited to third-party source records, Petitioner's financial production, institutional records, payroll records, equity records, tax records, bank records, loan records, lease records, and vendor/payment records. Nothing in this request permits Petitioner, cou...

...ecord custodians; 5. MODIFY discovery deadlines for the limited purpose of third-party source-record verification and related follow-up; 6. CONTINUE or ABATE the June 11,2026trial setting until the marital estate can be reconstructed from complete, continuous, source-verifiable records; 7. ORDER Petitioner, Jonathan Drake Steele, Rebecca L. Armstrong, Sullivan & Cook, and any counsel who certified, sponsored, presented, defended, relied upon, or attempted to shield Petitioner's financial production to appear and show cause why sanctions should not issue;...

14. ENFORCE healthcare/HSA/FSA functionality and stabilization relief necessary to prevent further medical and financial harm; 15. REQUIRE written rulings on every item granted, denied, or reserved; 16. GRANT all other relief to which Jason McKemie is entitled. XVI. SUPPLEMENTAL UNSWORN DECLARATION OF JASON MCKEMIE is 539 W. Commerce My name is Jason McKemie. My date of birth is April 8, 1976. My address St., Suite 2010, Dallas, Texas 75208. | declare under penalty of perjury that the following is true in this filing. and correct based on my personal kno...

...hearing. Jason McKemie 539 W. Commerce St., Suite 2010 Dallas, Texas 75208 214-868-4901 jmckemie@mckemie.net accordance with the Texas Rules of Civil Procedure on June .2026. Cf Jason McKemie 16 of 110 DF-24-18010 Reply in Support of Enforcement, Sanctions, Continuance, and Leave Copy from re:SearchTX

EXHIBIT INDEX Exhibit Title Purpose Procedural history demonstrating repeated filings, unresolved motions, - Exhibit A Motion to Recuse Pleading History discovery disputes, and case-management failures. Notice to Petitioner and counsel regarding discovery deficiencies, Exhibit 8 Discovery Email missing records, and requests for compliance. Demonstrates Respondent's financial condition, expenses, inability to Exhibit C Sworn Budget absorb continued delay, and need for relief. High Liquidity While Declaring Contradicts claims of financial hardship by showi...

...rcement of the Court's December 17 Reinstatement of Healthcare Order which orders the reactivation of all of Respondent's benefits which were terminated on October 31st, 2026, through the submission of a false Qualifying Life Event (QLE) and a sworn attestation affirming that divorce proceedings had been finalized and that a divorce decree had been signed by a Judge of this Court. No such decree exists. This order, if enforced by the District Judge, will provide Respondent with access back to critically needed Healthcare services & Prescription's which h...

If those structural defects are remedied through written rulings and enforceable compliance mechanisms, Respondent will proceed. If they are not remedied, then there exists no procedural pathway to a fair adjudication, and recusal becomes mandatory to preserve due process. Court decline to cure the structural failures outlined below. I. PRIOR RECUSAL & STRUCTURAL DISCOVERY COLLAPSE IN DISTRICT 254 This case arrived in District 302 after a judicial recusal in District 254 precipitated by structural discovery failure. In District 254: Respondent served dis...

...was not my courtroom," and directed Ethan Scroggins to release the certified financials. Counsel agreed. Respondent relied upon that representation. Ill. ON OCTOBER 31, 2026, RESPONDENT APPEARED BEFORE ASSOCIATE JUDGE TAMIKA ABENDROTH SEEKING REIMBURSEMENT FOR FINANCIAL BURDENS IMPOSED THROUGH FALSE FINANCIAL REPRESENTATIONS AND RELATED PROCEEDINGS. At that hearing, Respondent informed the Court that Petitioner had produced less than fifteen percent of the necessary certified financial documentation. Respondent further stated that if he withdrawal were...

e Oral directives are binding; e Withdrawal prior to compliance would nullify enforcement; e There was no path to a fair trial without third-party custodian subpoena authority; e Statement-only production cannot reconstruct accounts involving layered transfers and rotating credit facilities; e Aneutral forensic tracing mechanism remained necessary. The Associate Judge permitted withdrawal. No complete certified financial production followed. Il. WHAT OCCURRED AFTER THE NINETY-DAY ASSURANCE What followed was not compliance with a directive for complete, c...

e Accounts have been rotated, renamed, and layered; e Funds conceded in mediation were not escrowed; e Healthcare enforcement remains incomplete; e Anactive bankruptcy stay exists under Trustee oversight. These facts are extensively documented and; Proceeding to trial under these conditions would: e Convert discovery collapse into adjudication; e Freeze dissipation into final division; e Render third-party verification impossible; e Permanently impair Respondent's ability to challenge false or incomplete production. V. CONDITIONAL NATURE OF THIS MOTION R...

My name is Jason McKemie. My date of birth is April 8th, 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 true and correct based on my personal knowledge and review of the documents referenced herein. Cums< Jason McKemie 539 W. Commerce St., Suite 2010 Dallas, TX 75208 214-868-4901 jmckemie@mckemie.net on all counsel of record and/or parties entitled to notice in accordance with the Texas Jason McKemie VERIFIED MOTION TO RECUSE DF-24-18010 6 oF69F 1...

...it D: Credit Card Over Payment Exhibit E: Signed Order to Reinstate Healthcare Exhibit F: Motion to Compel Docket Sheet Exhibit G: Benefits Summary generated February 2, 2026, reflecting multiple coverages waived Exhibit H: Motion to Obtain Certified Transcript of January 7, 2025 Hearing (with proposed order). Exhibit I: Motion to Establish Conditions for Re-Entry of Counsel and Preserve Fair Trial. Exhibit K: Unified Proposed Order drafted at the Associate Judge's direction following the February 5 compliance hearing (pending). VERIFIED MOTION TO RECUSE...