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2026-06-15
Respondent / Jason
Motion - Recuse
Page 1
PLEADING_START_FILE_MARKED
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
6/15/2026 9:53 AM IN THE MATTER OF THE MARRIAGE OF GWENDOLYN ULIJASZ-MCKEMIE AND FOR MANDATORY WRITTEN RULING BEFORE RENDITION, SIGNATURE, ENTRY, OR ENFORCEMENT OF ANY FINAL DECREE; AND NOTICE OF ADDITIONAL SOURCE EVIDENCE Notice for the Court: Because the Court is expected to determine whether to sign Petitioner's proposed decree today, Respondent is filing this Supplement immediately rather than delaying submission while exhibits are finalized. Additional supporting exhibits, affidavits, police records, timelines, and documentary evidence referenced he...
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 2
PLEADING_BODY
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
This Supplement does not reurge the same grounds asserted in the prior recusals. Each recusal arose from a distinct escalation point in an increasingly severe pattern of procedural breakdown, discovery obstruction, financial concealment, healthcare interference, and trial-preparation sabotage: e Recusal No. 1 addressed the 254th District Court's failure to hear emergency relief, discovery obstruction, medical collapse, and the procedural trap created when counsel withdrew during discovery and reappeared at the discovery deadline to file blanket objection...
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 3
PLEADING_BODY
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
4.Prohibit Petitioner, her counsel, experts, vendors, investigators, agents, contractors, or anyone acting with or for her from accessing, inspecting, imaging, copying, using, relying on, benefiting from, or receiving any derivative benefit from Jason's stolen hard drives, evidence repositories, trial binders, Apple devices, computers, records, tools, briefcase, passport, medications, or seized litigation materials. 5. Require third-party source verification before any decree is signed or enforced, including healthcare/HSA/FSA/OLE/COBRA records, Accentur...
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 4
PLEADING_BODY
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
ll. THE FIRST RECORDED EVENT IN THIS CASE MATTERS On January 7, 2025, at the protective-order hearing, Donna Tomlinson of Hargrave Family Law appeared and moved to withdraw from representing Petitioner. Judge Sandra Jackson expressed concern because serious allegations had been made, the matter involved a protective order, and a continuance had already been granted. Donna Tomlinson then stated on the record that proceeding forward with her representation of Gwendolyn Ulijasz-McKemie would violate her ethical oath as an officer of the court. That was not...
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 5
PLEADING_BODY
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
Domestic Partnership, joint accounts, joint financial conduct, reciprocal powers of attorney, Ameriprise beneficiary documentation identifying the parties as spouses, and multiple witnesses, including the wedding officiant, confirming the relationship timeline. This evidence destroys the "short marriage" fiction. The decree should not be signed on a Marital timeline contradicted by signed declarations, domestic-partnership documents, powers of attorney, joint investment activity, joint accounts, beneficiary records, and witness testimony. VI. FINANCIAL I...
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 6
EXHIBIT_START
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
Vil. FALSE DESTITUTION, THIRD-PARTY CONTRACTORS, AND SOURCE- RECORD COLLAPSE Petitioner declared destitution while earning extraordinary income. Her February 7, 2026 Amended roa $150,000 signing bonus, a $34,225.57 cash bonus, Inventory and Appraisement ists Accenture equity, Accenture 401(k) value, Ameriprise IRA/Roth IRA balances, alleged loans, a BMW M340xi with a claimed $55,902 balance, and a Glock firearm. The same inventory advances a July 26, 2024 marriage date contradicted by the signed informal-marriage declaration and other relationship eviden...
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 7
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
police-video evidence. IX. HEALTHCARE OBSTRUCTION IS LIFE-SAFETY, NOT ARGUMENT Healthcare is central to this Supplement because a decree signed on the proposed record would leave - Jason homeless, bankrupt, without transportation, without the - a man with congestive heart failure ability to afford COBRA, without functional HSA/FSA access, without surgeries, without reliable medication access, and without the practical ability to rebuild employment. Jason needs spinal surgery and surgery for a torn rotator cuff, ruptured bicep, and torn tendons. He has be...
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 8
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
Xl. SAPD RECORDS SHOW FALSE-REPORTING ESCALATION AND STOLEN-PROPERTY NARRATIVE SAPD Report No. SAPD26106749 records Petitioner attempting to frame Jason's HSA/benefit-access efforts as fraud. The officer told her it did not appear Jason was attempting to impersonate her, that Jason was authorized on the account, and that no criminal conduct appeared from the benefits-access conduct. The same report records that Petitioner then escalated into a statement that Jason drugged and raped her in 2024 while declining to make a sexual-assault report. SAPD Report...
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 9
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
- Two men also appeared and bragged about being paid approximately $500 per hour each approximately $1,000 per hour combined - to monitor or participate in the property event. Jason has their business card. Five hundred dollars would have preserved storage, bodycam, transcripts, or survival property. Petitioner claimed destitution while deploying paid resources at rates Jason could not access to save his own property. This was not ordinary moving. It was a hostile takeover of the residence under the cover of a manufactured writ. Xlill. STOLEN PROPERTY, C...
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 10
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
Those stolen hard drives and evidence repositories are Jason's separate property and stolen evidence. Petitioner, her counsel, experts, vendors, investigators, agents, contractors, and anyone acting with or for her must not be permitted to access, inspect, image, copy, use, rely upon, authenticate, test, review, receive, or benefit from those materials in any way. The only permissible relief is preservation of Jason's rights, categorical non-access, categorical non-use, sequestration away from Petitioner and her agents, and return to Jason. XV. ADDRESS C...
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 11
EXHIBIT_START
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
XVII. FORMER-HUSBAND WITNESS AND ACTIVE WITNESS SUPPRESSION Recent filings from Christopher McNally, Petitioner's former husband and a material witness in this case, show protective-order-extension and fee/body-attachment challenges in Cook County, Illinois. Those filings identify overlapping counsel involvement and the use of protective-order restrictions and coercive relief in a manner that impaired or chilled McNally's ability to communicate or testify. Additional filings state that fees and body-attachment pressure risked impairing his ability to tes...
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 12
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
Jason cannot leave this litigation without enforceable protection against knowingly false criminal allegations, stolen-property-based accusations, healthcare interference, and witness suppression. Without intervention, this does not end. XIX. THE RECORD HAS BEEN SCREAMING FOR EIGHTEEN MONTHS The issue before the Court is no longer whether the parties disagree. The issue is whether this record can honestly be described as ordinary. This record contains more than 120 pleadings, more than 1,400 pages of filings, repeated requests for a court reporter, repea...
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 13
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
evidence needed to defend himself, without computers or tools needed to rebuild income, without access to bodycam/dashcam/transcript proof he cannot afford, with parents pulled into bankruptcy, with a father suffering dementia and deprived of memory-care stability, facing false criminal allegations, and at immediate risk of death from untreated or destabilized congestive heart failure and delayed surgical care. That is not a side issue. That is the emergency. XXI. PROPOSED WRITTEN FINDINGS REQUESTED BEFORE ANY DECREE ACTION testimony was taken, or trial...
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 14
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
...nal decree, fee award, sanctions award, enforcement step, or trial ruling entered before written resolution of Recusal No. 3 and this Supplement. XXII. REQUEST FOR ORDER 15.grantrecusal or refer Recusal No. 3 and this Supplement for decision before any decree action; 16. stay rendition, signature, entry, transmission, enforcement, fee awards, sanctions, and decree action pending written recusal resolution; 17.orderimmediatethird-partysourceverification of healthcare, HSA/FSA, OLE, COBRA, plan elections, and functional benefits access; 18.ordersource-reco...
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 15
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
...inancial records, witness communications, and attached evidence. | declare under penalty of perjury that the foregoing is true and correct. Executed in Texas on June 15, 2026. Jason McKemie 539 W. Commerce St., Ste. 2010, Dallas, TX 75208 | 214-868-4901 jmckemie@mckemie.net 15 of 19 Copy from re:SearchTX
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 16
CERTIFICATE_OF_SERVICE
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
Jason McKemie 539 W. Commerce St., Ste. 2010 Dallas, TX 75208 214-868-4901 jmckemie@mckemie.net Gon. Jason McKemie Jason McKemie 539 W. Commerce St., Ste. 2010, Dallas, TX 75208 | 214-868-4901 jmckemie@mckemie.net 16 of 19 Copy from re:SearchTX
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 17
EXHIBIT_START
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
APPENDIX A UNSWORN DECLARATION OF CHRISTOPHER McNALLY My name is Christopher McNally. I am over eighteen years of age. My address is 228 Millbridge Rd., Riverside, Illinois 60546 and my birthday is August 24,1976. I am of sound mind, competent to make this declaration, and the facts stated below are within my personal knowledge and are true and correct. This declaration is provided only in response to subpoena/court testimony request and is not contact with Gwendolyn Ulijasz. I submit this declaration in response to a subpoena/request for sworn testimony...
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 18
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
...ele / Beermann LLP. I further understand that counsel associated with those proceedings has also appeared or sought to participate in Jason McKemie's Texas divorce case. 15. At or near the time I became relevant as a potential witness in JJason McKemie's case, proceedings involving me included coercive enforcement efforts, including contempt- Jason McKemie 539 W. Commerce St., Ste. 2010, Dallas, TX 75208 | 214-868-4901 jmckemie@mckemie.net 18 of 19 Copy from re:SearchTX
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 19
EXHIBIT_START
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
...going is true and correct. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on June 15, 2026. : [Mel *--Christopher McNally Jason McKemie 539 W. Commerce St., Ste. 2010, Dallas, TX 75208 | 214-868-4901 jmckemie@mckemie.net 19 of 19 Copy from re:SearchTX
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 20
FILING_STAMP_OR_ESERVICE
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
...ules governing Envelope ID: 116127794 Filing Code Description: Motion - Recuse Filing Description: RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL Status as of 6/15/2026 10:43 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jeffrey ECook jcook@sullivancook.com 6/15/2026 9:53:54 AM SENT Rebecca LArmstrong rebecca@armstronglawtexas.com 6/15/2026 9:53:54 AM SENT Terra Aguirre terra@armstronglawtexas.com 6/15/2026 9:53:54 AM SENT Lauren N.Shaw lauren@armstronglawtexas.com 6/15/2026 9:53:54 AM SENT Jason McKemie jmckemie@mckemie.net 6...
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