DF-24-18010 Litigation Record Search

8. At 4:28 p.m. on June 11, 2026, Petitioner sent a proposed Final Decree of Divorce to Respondent and the Court for the Court’s signature. the proposed decree (June 12, 2026) and recusal “supplements” (June 15 and June 16, (No. 05-26-00854-CV) on June 12, 2026. On June 15, 2026, the Court of Appeals returned and rejected five of the ten documents Respondent submitted in connection with that filing. No court has stayed these proceedings. III. ARGUMENT AND AUTHORITIES A. Respondent’s pending motion to recuse is a tertiary recusal motion, and Texas Civil P...

B. The motion to recuse is also untimely. 14. Independently, Respondent’s motion to recuse is untimely. It was electronically submitted at 1:21 p.m. on June 11, 2026 — nine minutes before the 1:30 p.m. trial setting, and long after “the tenth day before the date set for trial.” TEX. R. CIV. P. 18a(b)(1). Nothing indicates Respondent neither knew nor reasonably should have known of any asserted ground before that date. C. No stay is in effect; the mandamus filing does not divest this Court of authority. 15. The filing of a petition for writ of mandamus do...

THE MARRIAGE OF GWENDOLYN ULIJASZ-MCKEMIE AND JASON MCKEMIE FINAL DECREE OF DIVORCE On June 11, 2026, the Court heard this cause. 1. Appearances Petitioner, GWENDOLYN ULIJASZ-McKEMIE ("Wife"), appeared in person and through her attorneys of record, Jonathan D. Steele and Rebecca Lee Armstrong, announced ready for trial, and proved up her case on Petitioner's pleading and supersedes all prior petitions, including the December 2024 original pleading. Respondent, JASON EMORY McKEMIE (“Husband”), previously appeared and answered pro se. The Court finds this...

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...

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...

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...

evidence theft, hard-drive theft, trial-material theft, false reporting, source-record concealment, and refusal to restore the conditions necessary for trial. Respondent is the party fighting to survive and obtain a fair trial; he is not the source of the obstruction. Respondent files this Motion despite the known risk because the new evidence and current posture do not merely warrant recusal - they demand it. There is no possibility of fair trial when the opposing party violated mutual injunctions, unlawfully entered the residence, stole the hard drives...

A reasonable person could question impartiality where the case is forced to final trial despite known structural impossibility, stolen evidence repositories, stolen hard drives, stolen trial materials, unavailable source financial records, unresolved healthcare/OLE records, unresolved de novo/trial- readiness issues, rejected or unresolved adequate-trial-time requests, and Respondent's present inability to safely appear or present evidence. NEW MATERIAL FACTS SINCE THE PRIOR RECUSAL PROCEEDINGS Since the prior recusal proceedings, Petitioner unlawfully e...

Petitioner siphoned approximately $650,000 from marital accounts, declared destitution, and eft Respondent carrying approximately $25,000 per month in marital-estate obligations while Petitioner earned approximately $125,000 per month and Respondent had no income, no counsel, no access to survival funds, and was recovering from spinal surgery. Petitioner then committed perjury through false sworn statements suggesting financial helplessness, while concealing substantial resources and spending heavily on counsel, vendors, investigators, and third-party li...

Respondent was involved in a car wreck last week. Respondent's vehicle is unsafe for extended travel. Respondent is also currently living in his vehicle, without stable housing, without working phone service, and without the ability to call for emergency help if his condition worsens during travel. Respondent has diverted from attempting to travel to Dallas and is presently in or near Bryan, Texas, where Respondent is being taken for emergency medical evaluation and/or hospital treatment for congestive-heart-failure symptoms. Respondent cannot safely dri...

Respondent requests immediate remote-access information by email so Respondent may make every possible effort to appear remotely by Zoom, Webex, Teams, telephone alternative, email link, or any available Wi-Fi method from the hospital, emergency-care setting, or available internet connection. Respondent's phone service is disconnected. Respondent requests that all remote-access information be sent by email to jmckemie@mckemie.net. IV. TRIAL SHOULD NOT PROCEED IN RESPONDENT'S ABSENCE Respondent objects to any trial proceeding, evidence presentation, witne...

Respondent has repeatedly informed this Court that Petitioner obstructed Respondent's healthcare access, including medical coverage, HSA access, FSA access, medication access, surgery access, and related benefits. Petitioner obstructed Respondent's healthcare access beginning no later than December 18, 2024. Petitioner caused or participated in a false divorce-based OLE that cut off Respondent's healthcare on October31, 2025, despite no divorce decree existing on that date. Petitioner has repeatedly represented compliance while Respondent contests functi...

2. Fraudulent protective-order applications, false protective-order evidence, and abuse of protective-order process; 3. Fraudulent evidence submissions, fabricated evidence, altered evidence, false exhibits, and use or attempted use of stolen evidence; 4. Perjury, aggravated perjury, coordinated aggravated perjury, false sworn testimony, false declarations, and false representations to the Court; 5. Malicious prosecution, malicious use of process, and malicious continuation of proceedings, where legally available; 6. Abuse of process, itigation abuse, pr...

15. Financial sabotage, financial strangulation, concealment or dissipation of marital assets, source-record concealment, account wipeouts, disguised transfers, false characterization of equity/investment compensation, and obstruction of estate reconstruction; 16. Manufactured eviction, concealed lease buyout, landlord/lease-buyout concealment, county court, bankruptcy, or civil remedies; 17.Attorneymisconduct,counselparticipation,former-counselparticipation,current-counsel participation, pro hac vice counsel conduct, law-firm conduct, discovery obstruct...

NO WAIVER OF STOLEN-EVIDENCE CLAIMS Respondent does not waive any claim, objection, sanction request, contempt request, exclusion request, preservation request, or civil claim arising from Petitioner's theft of Respondent's hard drives, evidence repositories, binders, paper files, legal work product, printer, printer ink, trial materials, medications, device evidence, Apple evidence, financial records, medical records, and itigation equipment. This was theft. No softer label applies. Petitioner unlawfully entered a residence she was barred from entering,...

4. Do not treat Respondent's medical collapse, lack of transportation, no phone service, homelessness, no gas money, unsafe vehicle, lack of parking funds, broken laptop screen, hospitalization, inability to physically appear, or need to seek emergency medical care as waiver, abandonment, failure to prosecute, consent to trial, or consent to final orders. 5. Order that all proceedings occur on the record with a court reporter and that no off-record trial-readiness, de novo, recusal, healthcare, financial, or evidence-theft matters be resolved without a v...

THIS 1S A AMANUFACTURED COLLAPSE, NOT LATE NOTICE Petitioner and her counsel will say this is late. That is false. Respondent has warned the Court for seventeen months that Petitioner was using false reports, protective-order narratives, healthcare obstruction, financial strangulation, discovery obstruction, housing sabotage, digital access, third- party vendors, and court process to destroy his ability to survive and defend himself. The record already includes repeated requests for emergency financial relief, healthcare enforcement, HSA/FSA access, cour...

and Jason Parro. Those matters are relevant because this case follows the same pattern: false narratives, police involvement, protective-order weaponization, financial strangulation, reputational destruction, healthcare interference, and itigation used as a method of control and destruction. Respondent told law enforcement that he feared for his safety and future because he had discovered extensive documentation showing a long pattern of malicious litigation and that Petitioner was going to file false police reports and a false protective order against h...

4. Do not treat Respondent’s medical collapse, lack of transportation, no phone service, homelessness, no gas money, unsafe vehicle, lack of parking funds, broken laptop screen, hospitalization, inability to physically appear, or need to seek emergency medical care as waiver, abandonment, failure to prosecute, consent to trial, or consent to final orders. 5. Order that all proceedings occur on the record with a court reporter and that no off-record trial-readiness, de novo, recusal, healthcare, financial, or evidence-theft matters be resolved without a v...

THIS IS A MANUFACTURED COLLAPSE, NOT LATE NOTICE Petitioner and her counsel will say this is late. That is false. Respondent has warned the Court for seventeen months that Petitioner was using false reports, protective-order narratives, healthcare obstruction, financial strangulation, discovery obstruction, housing sabotage, digital access, third- party vendors, and court process to destroy his ability to survive and defend himself. The record already includes repeated requests for emergency financial relief, healthcare enforcement, HSA/FSA access, court...

and Jason Parro. Those matters are relevant because this case follows the same pattern: false narratives, police involvement, protective-order weaponization, financial strangulation, reputational destruction, healthcare interference, and litigation used as a method of control and destruction. Respondent told law enforcement that he feared for his safety and future because he had discovered extensive documentation showing a long pattern of malicious litigation and that Petitioner was going to file false police reports and a false protective order against...

evidence-theft, protective-order, and sanctions issues. Il. SPECIFIC ISSUES PRESENTED FOR DE NOVO REVIEW Under Texas Family Code § 201.015(b), Jason specifically requests de novo review of the following issues: 1. The denial of Respondent, Jason McKemie's, Motion for Enforcement, 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...

lacking traceable funding, account entry, repayment history, and community-purpose proof. 9. The denial or failure to address sanctions, show-cause relief, adverse inferences, fee shifting against Petitioner and responsible counsel, counsel certification, forensic accounting from third-party financial source records, estate reconstitution under Texas Family Code § 7.009, and disproportionate division under Texas Family Code § 7.001. 10.The denial or failure to enforce healthcare, HSA/FSA, prescription, reimbursement, benefits-card, benefits-portal, QLE,...

Petitioner be denied in full, with no later prove-up, no reserved entitlement, and no cost shifting against Jason. 18.The denial or failure to address witness-protection issues involving Christopher McNally and Jonathan Drake Steele. 19.The denial or failure to address trial-readiness defects created by incomplete financial production, blocked source-record subpoenas, missing/stolen evidence repositories, unresolved healthcare access, lack of functional litigation infrastructure, and unresolved witness-protection issues. 20.Any finding, conclusion, recom...

evidence-theft, protective-order, and sanctions issues. II. SPECIFIC ISSUES PRESENTED FOR DE NOVO REVIEW Under Texas Family Code § 201.015(b), Jason specifically requests de novo review of the following issues: 1. The denial of Respondent, Jason McKemie’s, Motion for Enforcement, 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...

lacking traceable funding, account entry, repayment history, and community-purpose proof. 9. The denial or failure to address sanctions, show-cause relief, adverse inferences, fee shifting against Petitioner and responsible counsel, counsel certification, forensic accounting from third-party financial source records, estate reconstitution under Texas Family Code § 7.009, and disproportionate division under Texas Family Code § 7.001. 10. The denial or failure to enforce healthcare, HSA/FSA, prescription, reimbursement, benefits-card, benefits-portal, QLE,...

Petitioner be denied in full, with no later prove-up, no reserved entitlement, and no cost shifting against Jason. 18. The denial or failure to address witness-protection issues involving Christopher McNally and Jonathan Drake Steele. 19. The denial or failure to address trial-readiness defects created by incomplete financial production, blocked source-record subpoenas, missing/stolen evidence repositories, unresolved healthcare access, lack of functional litigation infrastructure, and unresolved witness-protection issues. 20. Any finding, conclusion, re...

• A person genuinely seeking protection does not report a legal retainer as fraud, cut off access to counsel, and then escalate into protective-order litigation. • A person 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. • A person genuinely seeking protection does not report a Health Savings Account card lost or stolen while the other party is hospitalized and actively seeking medical treatment. • A person genuin...

• The Court should reject that frame. • This is not an abuse case. • This is not a stalking case. • This is a fraud case. • 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...

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...

DF-24-18010NO.________________________________ THE MARRIAGE OF § § AND § ORDER GRANTING LEAVE TO ISSUE THIRD-PARTY SUBPOENAS FOR FINANCIAL, LEASE, QLE, BENEFITS, AND ESTATE SOURCE RECORDS On this day, the Court considered Jason McKemie’s Motion for Enforcement, Sanctions, Continuance, and Leave to Issue Third-Party Subpoenas. After considering the motion, any response, the record, and argument, the Court ORDERS: 1. Leave to issue third-party subpoenas and nonparty discovery is GRANTED. 2. Jason McKemie may issue subpoenas and nonparty discovery for sourc...

SIGNED on MAY ______, 2026. ___________________________________ JUDGE PRESIDING DF-24-18010 Motion for Enforcement, Sanctions, Continuance, & Leave Page 2 of 2

DF-24-18010NO.________________________________ THE MARRIAGE OF § § AND § ORDER RESERVING SANCTIONS, FEE SHIFTING, ESTATE RECONSTITUTION, ADVERSE INFERENCES, AND HEALTHCARE ENFORCEMENT FOR FURTHER HEARING On this day, the Court considered Jason McKemie’s Motion for Enforcement, Sanctions, Continuance, and Leave to Issue Third-Party Subpoenas. After considering the motion, any response, the record, and argument, the Court ORDERS: 1. The Court reserves without prejudice all issues concerning sanctions, fee shifting, adverse inferences, estate reconstitution...

NO DF-24-18010 THE MARRIAGE OF § § AND § ORDER GRANTING LEAVE TO ISSUE THIRD-PARTY SUBPOENAS FOR FINANCIAL, LEASE, OLE, BENEFITS, AND ESTATE SOURCE RECORDS On this day, the Court considered Jason McKemie's Motion for Enforcement, Sanctions, Continuance, and Leave to Issue Third-Party Subpoenas. After considering the motion, any response, the record, and argument, the Court ORDERS: 1. Leave to issue third-party subpoenas and nonparty discovery is GRANTED. 2. Jason McKemie may issue subpoenas and nonparty discovery for source records concerning financial a...

SIGNED on MAY .2026. JUDGE PRESIDING DF-24-18010 Motion for Enforcement, Sanctions, Continuance, & Leave Page 2 of 2 Copy from re:SearchTX

NO DF-24-18010 THE MARRIAGE OF § § AND § ORDER RESERVING SANCTIONS, FEE SHIFTING, ESTATE RECONSTITUTION, ADVERSE INFERENCES, AND HEALTHCARE ENFORCEMENT FOR FURTHER HEARING On this day, the Court considered Jason McKemie's Motion for Enforcement, Sanctions, Continuance, and Leave to Issue Third-Party Subpoenas. After considering the motion, any response, the record, and argument, the Court ORDERS: 1. The Court reserves without prejudice all issues concerning sanctions, fee shifting, adverse inferences, estate reconstitution, reimbursement, offsets, health...

• A person genuinely seeking protection does not report a legal retainer as fraud, cut off access to counsel, and then escalate into protective-order litigation. • A person 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. • A person genuinely seeking protection does not report a Health Savings Account card lost or stolen while the other party is hospitalized and actively seeking medical treatment. • A person genuin...

• The Court should reject that frame. • This is not an abuse case. • This is not a stalking case. • This is a fraud case. • 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...

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...

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...

February noncompliance without attaching obligations, and proof of signed orders establishing exact obligations. violation. "No source records" 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, payr...

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...

Il. IMMEDIATE CASH STABILIZATION 5. Respondent requests immediate cash stabilization. 6. Non-monetary relief will not prevent immediate harm. Respondent is homeless, without reliable food, without reliable medication access, without stable transportation, without stable phone/utility access, without working trial-preparation infrastructure, and without funds to retain counsel. 7. Nothing short of immediate cash will restore the minimum ability to eat, obtain medication, travel, print, communicate, preserve property, protect evidence, and prepare for tria...

17. Petitioner shall not interfere with Respondent's healthcare, prescriptions, benefits, HSA, FSA, reimbursement rights, benefits cards, administrator access, portal access, pharmacy access, medical equipment, or access to care. 18. Within 12 hours of the Court's order, Petitioner shall provide Respondent all information and access necessary for immediate, independent use of any HSA, FSA, health-benefit card, benefits portal, reimbursement system, COBRA portal, pharmacy-benefit portal, and administrator contact process associated with Respondent's cover...

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,...

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Ill. WHY RELIEF IS REQUESTED NOW This request arises from the convergence of: 1. unresolved discovery noncompliance carried forward through recusal and transfer; 2. unresolved healthcare enforcement issues; 3. the April 16, 2026 execution, entry, cleanout, and property-removal event that materially disrupted Respondent's evidence repositories, litigation materials, office systems, and trial-preparation capacity; 4. ongoing bankruptcy, eviction, transportation, utility, healthcare, and communication instability; and 5. the current trial setting now approa...

VI. OBJECTION TO PRO HAC VICE ADMISSION Respondent objects to pro hac vice admission. The objection is not based on counsel being out of state. The objection is based on Respondent's prior objection already on file, including counsel's prior participation in these proceedings, witness-related misconduct, ethical concerns, and the risk of further prejudice if Petitioner is permitted to expand her litigation apparatus before the Court addresses emergency stabilization, healthcare enforcement, parity, discovery compliance, and trial capacity. Respondent req...

IX. REQUESTED RELIEF Respondent respectfully requests that the Court enter immediate interim orders: 1. ordering Petitioner to deposit $ (Requesting Min. $25,000) in emergency stabilization funds by direct Chase-to-Chase transfer or through the registry of the Court with immediate release authority; 2. enforcing the December 17, 2025, 24hr emergency healthcare reinstatement order with functional, third-party verification (separate from emergency stabilization); 3. requiring Petitioner to restore or verify all healthcare, HSA, FSA, card, reimbursement, po...

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...

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...

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...

Respectfully Submitted, [Son € Jason McKemie 539 W Commerce St., Ste 2010 Dallas, TX 75208 214-868-4901 jmckemie@mckemie.net NOTICE OF FORTHCOMING SUPPLEMENT TO OBJECTION TO PRO HAC VICE ADMISSION 20f 3 DF-24-18010 Copy from re:SearchTX

4/6/2026 8:34 AM DALLAS CO., TEXAS MARRIAGE OF § § & § NOTICE OF SUPPLEMENTAL FILING TO BE SUBMITTED TODAY AND MOTION FOR LEAVE Jason McKemie files this Notice and Motion and respectfully states: morning (April 6th, 2026). 2. The supplemental filing remains in active preparation. Respondent anticipates filing it later today, but respectfully requests a brief 24-hour extension if needed to submit the finalized pleading. This the prior objection. 3 The remaining work reflects final assembly, issue narrowing, and formatting necessary to present a focused an...

gulijasz@gmail.com and gwendolyn.ulijasz@accenture.com [Son Jason McKemie NOTICE OF FORTHCOMING SUPPLEMENT TO OBJECTION TO PRO HAC VICE ADMISSION 3 of 3 DF-24-18010 Copy from re:SearchTX

4. The undersigned is licensed to practice law in the following jurisdictions and is an active member in good standing in each: a. The Supreme Court of Illinois (ARDC Registration No. 6308171; admitted May 10, 2012); and b. The United States District Court for the Northern District of Illinois. 5. The undersigned has not been the subject of any disciplinary action in any jurisdiction within the preceding five years. 6. The undersigned has not been denied admission to any court within the preceding five years. 7. The undersigned is familiar with the State...

WHEREFORE, the undersigned respectfully requests that this Court grant permission for Jonathan Drake Steele to appear and participate as counsel for Gwendolyn Ulijasz-McKemie in the above-captioned cause, and for such other and further relief to which the undersigned may be justly entitled. Respectfully submitted, 'Jonathan Drake Steele Illinois ARDC No. 6308171 Beermann LLP 161 North Clark Street, Suite 3000 Chicago, Illinois 60601 Telephone: (312) 621-9700 Email: jsteele@beermannlaw.com Attorneyfor Gwendolyn Ulijasz-McKemie VERIFICATION Swom Motion to...

ATTORNEY REGISTRATION AND DISCIPLINARY COMMISSION of the SUPREME COURT OF ILLINOIS Wwwiardc.org One Prudential Plaza 3161 West White Oaks Drive, Suite 301 130 East Randolph Drive, Suite 1500 Springfield, IL 62704 Chicago, Illinois 60601-6219 (217) 546-3523 (800) 252-8048 (312) 565-2600 (800) 826-8625 Fax (217)546-3785 Fax (312) 565-2320 Jonathan Drake Steele Beermann LLP 161 North Clark Street Suite 3000 Chicago, IL 60601-3243 Chicago Friday, March 13, 2026 In re: Jonathan Drake Steele Admitted: 05/10/2012 Attorney No. 6308171 To Whom It May Concern: We...

Respondent has requested identification of third-party vendors and individuals whose actions Petitioner relies upon in support of her claims, including but not limited to security vendors, investigative contractors, technology consultants, and entities such as Jetty Partners. Petitioner has not provided complete identifying information sufficient for subpoena issuance. Respondent reserves the right to call such individuals upon disclosure and/or upon receipt of subpoenaed records. Respectfully Submitted, [Son Jason McKemie 539 W Commerce St., Ste 2010 Da...

2/23/2026 7:45 AM DALLAS CO., TEXAS No. DF-24-18010 THE MARRIAGE OF § § & § RESPONDENT'S FINAL TRIAL WITNESS LIST Respondent, Jason McKemie, files this Final Trial Witness List for purposes of preserving the ability to call witnesses at the bench trial set for February 24, 2026. This list is non-exclusive and may be supplemented for rebuttal or impeachment as permitted by the Texas Rules of Civil Procedure and Rules of Evidence. I. PARTY WITNESS e Gwendolyn Ulijasz-McKemie Il. MATERIAL FACT WITNESSES Christopher McNally James McKemie Elizabeth Bender Dan...

gulijasz@gmail.com and gwendolyn.ulijasz@accenture.com [Son Jason McKemie RESPONDENT'S FINAL WITNESS LIST 3 of 3 DF-24-18010 Copy from re:SearchTX

6. Petitioner's exclusive and immediate control of the HSA/FSA account in her name, and revocation of the Respondent's access to that account. 6. No domain names or email addresses referencing the opposing party will be owned by either party, specifically but not limited to those currently owned by the Respondent via Ionos company. Those currently owned domain names and addresses will be relinquished and proof of such action sent to a neutral Third Party within three days. 8. Confirmation that Respondent's access to Petitioner's employer-sponsored health...

2/23/2026 2:54 PM DALLAS CO., TEXAS Petitioner's Amended Proposed Property Division Gwendolyn Laura Ulijasz, Petitioner V. Jason Emory McKemie, Respondent PETITIONER'S AMENDED PROPOSED PROPERTY DIVISION Petitioner files this Amended Proposed Property Division and would respectfully show the Court: 2025. 2. Petitioner does not seek affirmative monetary recovery from Respondent and requests entry of a final decree of divorce consistent with the items below. 3. Petitioner requests confirmation of her separate property as reflected in her Feb 2026 updated In...

on the date and to the persons listed below. The rules governing Envelope ID: 111598723 Filing Code Description: Notice Of Filing Filing Description: PETITIONER'S AMENDED PROPOSED PROPERTY DIVISION Status as of 2/24/2026 8:57 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 2/23/2026 2:54:14 PM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 2/23/2026 2:54:14 PM SENT Gwendolyn Ulijasz gulijasz@gmail.com 2/23/2026 2:54:14 PM SENT JASON EMORYMCKEMIE jason@callvital.com 2/23/2026 2:54:14 PM SENT Copy f...

hearing on the January 12, 2026 Order Compelling Production of Certified Financials, held on February 5, 2026, at which Petitioner was again found noncompliant. When Petitioner requested that Movant's disclosed witness be struck based on generalized safety concerns, the Court made clear, in substance, that courtroom security measures were more than adequate to address any safety concerns and that generalized allegations do not justify striking a properly disclosed witness from testifying when called. 4. Relevance of testimony to credibility, timeline, an...

Movant requests that the Court grant this Motion, authorize Christopher McNally to testify remotely by videoconference at the February 24, 2026, bench trial, confirm that Petitioner may not strike or exclude this properly disclosed witness based solely on Petitioner's third-party protective order, and grant all further relief the Court deems just. Respectfully Submitted, Jason McKemie 539 W Commerce St, Ste 2010 Dallas, TX 75208 214-868-4901 jmckemie@mckemie.net MOTION TO CONFIRM REMOTE APPEARANCE OF DECLARED NONPARTY TRIAL WITNESS AND 3 of 4 FOR CLARIFY...

2/23/2026 8:23 AM DALLAS CO., TEXAS No. DF-24-18010 THE MARRIAGE OF § § & § MOTION FOR REMOTE TESTIMONY OF WITNESS CHRISTOPHER McNALLY BY VIDEOCONFERENCE AND TO OVERRULE WITNESS-STRIKE OBJECTIONS BASED ON THIRD-PARTY PROTECTIVE ORDER TO THE HONORABLE JUDGE OF SAID COURT: Movant, Jason McKemie, requests an order permitting the testimony of Christopher McNally to be taken by videoconference at the bench trial set before the Court at 9:00 a.m. on Tuesday, February 24, 2026, and further requests an order overruling any attempt to exclude this properly disclo...

A. Respondent shall not reference, describe, or play any audio or video recordings involving Petitioner unless and until such recordings were: i. Marked as exhibits by the deadline passed (2/17/2026); ii. Properly disclosed; iii. Authenticated; and iv. Specifically ruled admissible by the Court. B. Any request to introduce such recordings shall be addressed outside the flow of testimony, at the Court's discretion. 5. No Prejudgment Requested Petitioner does not ask the Court to determine the admissibility, legality, or weight of any recordings at this ti...

2/20/2026 4:59 PM DALLAS CO., TEXAS IN THE MATTER OF THE MARRIAGE OF GWENDOLYN ULIJASZ-MCKEMIE AND JASON MCKEMIE Petitioner's Motion in Limine Regarding Audio and Video Recordings TO THE HONORABLE JUDGE OF SAID COURT: COMES NOW Petitioner, Gwen Ulijasz ("Petitioner"), appearing pro se, and files this Motion in Limine Regarding Audio and Video Recordings, and respectfully shows the Court as follows: 1. Purpose of Motion Petitioner files this Motion in Limine for the limited and procedural purpose of ensuring an orderly, efficient, and fair trial. This mot...

on the date and to the persons listed below. The rules governing Envelope ID: 111545342 Filing Code Description: Notice Of Filing IN LIMINE REGARDING Filing Description: PETITIONER'S MOTION AUDIO AND VIDEO RECORDING Status as of 2/23/2026 2:25 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 2/20/2026 4:59:43 PM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 2/20/2026 4:59:43 PM SENT Gwendolyn Ulijasz gulijasz@gmail.com 2/20/2026 4:59:43 PM SENT JASON EMORYMCKEMIE jason@callvital.com 2/20/2026 4:59...

A. The January 6 ruling is not being challenged On January 6, 2026, the Associate Judge heard Movant's Motion to Compel discovery and requests regarding HSA. The Associate Judge's written report reflects that: 1. The Court granted Movant's request that financial documents be turned over by January 9, 2026; and 2. The HSA card was noted as provided at the time of the hearing. Movant does not seek de novo review of that ruling. Movant does not ask the Court to overturn, rehear, or modify it. Movant does not contend the Associate Judge erred. B. The issue n...

upon the Court. These are not technical errors; they prevent valuation and invert the proceeding by forcing Movant to reconstruct continuity from curated fragments. Objective indicators include: e Missing continuity across months and missing transaction-detail pages, preventing reconciliation across statement cycles; e Substitution of non-statement exports/snapshots for institution-issued monthly statements, eliminating certification and uninterrupted coverage; e Inaccessible production mechanics (e.g., restricted links / password mechanics) impairing ti...

VIII. PRAYER For the foregoing reasons, Movant respectfully requests that the Court grant the Relief Requested, continue or abate the February 24, 2026 bench trial setting, enter written trial-readiness orders, and grant all other relief to which Movant is justly entitled. VERIFIED UNSWORN DECLARATION (TEX. CIV. PRAC. & REM. CODE § 132.001) My name is Jason McKemie. My date of birth is April 8,. 1 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 tru...

Respectfully Submitted, Pawnee - Jason McKemie 539 W. Commerce St., Ste. 2010 Dallas, TX 75208 | . 214-868-4901 jmckemie@mckemie.net Document Page 1ofi CLERK, U.S. BANKRUPTCY COURT NORTHERN DISTRICT OF TEXAS ENTERED THE DATE OF ENTRY IS ON THE COURT'S DOCKET The following constitutes the ruling of the court and has the force and effect therein described Signed February 18, 2026 United States Bankruptcy Judge IN THE UNITED STATES BANKRUPTCY COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION IN RE: § § CASE NO. 26-30161-MVL JASON EMORY MCKEMIE, § (Ch...

2/18/2026 2:32 PM NOTICE: THIS FILING Co., TEXAS NO. THE MARRIAGE OF & RESPONDENT'S NOTICE OF BANKRUPTCY AUTOMATIC STAY 1. Defendant Jason McKemie files this Notice to inform the Court that his Chapter 7 Bankruptcy Case pending in the United States Bankruptcy Court for the Northern District of Texas, Dallas Division, Case No. 26-30161-MVL, has been reinstated following a brief administrative dismissal caused by a document deficiency during a recent hospitalization. 2. On February 18, 2026, the Bankruptcy Court entered an Order Granting Motion to Vacate D...

on the date and to the persons listed below. The rules governing Envelope ID: 111412461 Filing Code Description: Notice Of Bankruptcy Filing Description: RESPONDENT'S NOTICE OF BANKRUPTCY AUTOMATIC STAY Status as of 2/19/2026 10:23 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 2/18/2026 2:32:25 PM SENT Gwendolyn Ulijasz gulijasz@gmail.com 2/18/2026 2:32:25 PM SENT Copy from re:SearchTX

2 MetLife MSA $0 $0 $0 $0 0% 100% 3 sccenture Inspi $0 $0 0° 100% MOTOR VEHICLES, BOATS, AIRPLANES, CYCLES, ETC. 1 2023 BMW M340xi $68,710 -$11,000 -$11,000 $0 -$11,000 0% 100% 2 2018 Jaguar F-Pace -$5,000 -$5,000 -$5,000 $0 100% 0% OTHER TANGIBLE PERSONAL PROPERTY Hospitech solutions LLC. x At&t pension x Domain names x lonos acccount - Domains and email addresses x Storage Unit x Personal property at Dallas house - see attached Exhibit A x CLUB MEMBERSHIPS/TRAVEL AWARD BENEFITS 1 Gwen Airline Miles $200 $200 $0 $200 0% 100% 2 Sam's Club and Costco $0 $...

ATTORNEY'S FEES IN THIS CASE 1 Gwen's Fees 34 0% 100% 2_ Jason's Fees x 100% 0% OTHER LIABILITIES NOT OTHERWISE LISTED 1 SoFi Loan $22,533 $22,533 $0 $22,533 0% 100% 2 Pam & Clint Woodman Loan 1 - Gwen Fees $30,000 $30,000 $0 $30,000 0% 100% 3 Pam & Clint Woodman Loan 2 - Gwen Fees $29,000 $29,000 $0 $29,000 0% 100% 4 Jason Oil Loan $35,000 $35,000 $35,000 $0 100% 0% 5 Gwen Lightstream Loan $24,204 $24,204 $0 $24,204 0% 100% 6 Jason American Express Personal Loan x1001 $3,422 $3,422 $3,422 $0 100% 0% Totals $74,612 $274,623 $349,235 $74,612 $274,623 21%...

2/17/2026 10:21 PM DALLAS CO., TEXAS Value Used for Percent to Percent to Note Description His Value Her Value To Husband To Wife Division Husband Wife COMMUNITY ASSETS REAL PROPERTY (including Mineral Interests) 1 Secur ty Deposit for Pet's current Residence $3,800 $3,800 $3,800 $0 0% 100% CASH AND ACCOUNTS WITH FINANCIAL INSTITUTIONS (including Brokerage and Mutual Funds) Chase Checking x6893 $536 ~$428 -$428 $0 -$428 0% 100% 2 Chase Checking x9259 $8,203 $8,203 $0 $8,203 0% 100% 3 Chase Checking x7496 $82 $82 $0 $82 0% 100% 4 Chase GLU Checking x8627...

allow him to remain in the marital residence, and maintain his healthcare during divorce proceedings, including up to six months post-divorce or until Respondent returns to W-2 employment. Respondent repeatedly states that he does not feel safe and demands immediate reinstatement of his legal retainer and restoration of financial access. Petitioner simultaneously claims they are in severe financial distress, that they are at risk of bouncing their utility payment, and asserts she has no attorney and cannot begin interviewing attorneys until] at least Dec...

MONDAY, DECEMBER 16, 2024 - The Procedural Theft of Petitioner Status On Monday, Petitioner's counsel (Donna Tomlinson) files an Ex Parte Petition for a Protective Order and a Petition for an Annulment of Marriage based on false allegations, thereby preempting Respondent's pending divorce filing and procedurally securing petitioner status, despite Respondent having retained counsel first and while Respondent remained medically incapacitated and without functional access to financial or legal resources. PROCEDURAL IMPACT Since the inception of these proce...

first contacted law enforcement. On that date, Respondent called 911 after discovering documentation reflecting prior instances of false police reporting, improper protective order filings, and other related litigation measures. that call, Respondent advised that he was about to retain divorce counsel During and expressed that he felt that there was a significant probability that Petitioner would respond by initiating false police reports and ultimately seeking a protective order against him. (See Exhibit A) Within 3 days, multiple police contacts were i...

This Notice is not submitted for the purpose of delay, nor to seek immediate adjudication of disputed factual claims. Rather, it is offered to assist the Court in evaluating objections, safety assertions, and procedural posture against the full evidentiary record, particularly where decisions made at this juncture will materially shape the remainder of the proceedings. 1. ELEVATED RISK OF IMMINENT SAFETY-BASED ALLEGATIONS AT THIS PROCEDURAL INFLECTION POINT Respondent respectfully notifies the Court that, based on prior conduct and documented timing patt...

physicians as associated with prolonged interruption of prescribed medications following the termination of health coverage. These hospitalizations occurred during the period in which the Court had ordered Petitioner to reinstate Respondent's healthcare. Although nominal coverage was only recently restored, current benefits summaries from the plan administrator reflect that HSA contributions have been reduced to de minimis levels, the FSA was terminated, and other policies (including Life, AD&D, and Critical IlIness/Critical Care) in which Respondent was...

persistent problems and have not been reliably corrected despite repeated efforts, including Respondent referencing the issue in at least one subsequent filing. These irregularities have resulted in filings not appearing on the docket as expected, not being reliably available in the Court's working set at the time of hearings, and requiring resubmission or repeated efforts to restore visibility. Respondent contends that additional critical submissions remain absent or not reliably accessible for Court review despite ongoing efforts to correct the issue....

will require subpoenas to third parties. Proceeding toward trial without complete records is not "moving the case forward"; it is moving forward blind. E. Federal Bankruptcy Trustee Review Overlaps with the Marital Estate shifting, alleged fraudulent reporting of legal/medical charges, and related issues that overlap directly with relief sought in this case. Proceeding in state court without allowing the trustee process to stabilize will cause inconsistent rulings and irreparable prejudice. lil. ARGUMENT A. Abatement is Required to Prevent Irreparable Ha...

2. QLE/BENEFITS SUBPOENAS (ACCENTURE/BUSINESSOLVER): Authorize issuance of narrow third-party subpoenas to Accenture/Businessolver for QLE/eligibility administrative record and recordings; 3. SANCTIONS AND INTERIM MAKE-WHOLE RELIEF (LIFE-SAFETY / FUNCTIONAL ACCESS): Order sanctions and interim make-whole relief based on materially false and irreconcilable representations to the Court and continued noncompliance with healthcare/HSA orders, including immediate relief sufficient to restore functional access to critical medications and healthcare without req...

2/2/2026 11:52 PM NOTICE: THIS DOCUMENT DALLAS CO., TEXAS MARRIAGE OF § § & § EMERGENCY MOTION TO ABATE ALL PROCEEDINGS, PRESERVE LIFE- SAFETY, COMPEL A WRITTEN RECORD, AND AUTHORIZE THIRD-PARTY SUBPOENAS FOR ADMINISTRATIVE RECORDS QLE/HEALTHCARE TO THE HONORABLE JUDGE OF SAID COURT: Movant, Jason McKemie, appears pro se due to financial deprivation and medical incapacity, and files this Emergency Motion to prevent irreparable harm and preserve due process. This Motion is I. EMERGENCY NATURE AND RELIEF REQUESTED This Court is currently being asked to pro...

Il. PRESERVATION OF ABILITY TO CALL WITNESSES Respondent provides the following non-exclusive witness list to preserve the ability to call witnesses as discovery is completed. This list may be supplemented as additional discovery, third-party subpoenas, and trustee findings are finalized. A. Material Witnesses Pam Woodman Christopher McNally Elizabeth Bender Dr. Kathy Spangenberg Wynn E. Pott B. Third-Party / Professional Witnesses Jason Paru Detective Vidal (San Antonio Police Department) Detective Carnivally (San Antonio Police Department) Detective We...

information remains outstanding and is required for subpoena issuance and trial preparation, including but not limited to: e Security, investigative, surveillance, and contractor vendors (e.g., Jetty Partners); e The three off-duty police officers present at the marital residence on January 2, 2024; e Individuals and companies involved in surveillance of Respondent's residence; e The individual or vendor who inspected Petitioner's vehicle and reported discovery of a tracking device; e The cybersecurity vendor receiving approximately $2,700 per month in p...

Respondent respectfully requests that the Court: 1. Acknowledge this notice preserving Respondent's ability to call witnesses; 2. Take notice of late and ongoing discovery production; and 3. Grant a continuance consistent with the Court's prior guidance to allow completion of discovery, subpoena returns, trustee findings, and medical stabilization. Respectfully Submitted, - Pane Jason McKemie Respondent, Pro Se DF-24-18010 4of4 Copy from re:SearchTX

and incorporates it by reference. Petitioner is not aware of any unmet court-ordered obligation regarding healthcare coverage or HSA access. IV. REQUEST FOR ACCESS TO PERSONAL AND SEPARATE PROPERTY Respondent again respectfully requests written authority to retrieve her personal belongings. This request is not for division of property or adjudication of ownership and does not depend on a divorce decree. Certain items Petitioner seeks to retrieve are clearly documented separate property, supported by bills of lading from her May 2023 move to Texas that pr...

Exhibit A: 2™confirmation from Petitioners attorney confirming discovery completion and Production Inventory produced Copy from re:SearchTX

1/17/26, 1:40 PM Gmail - Fwd: Discovery (214) 520-7494 escroaains@sullivancock.com Thank you, Gwen Ulijasz Thank you, Gwen Ulijasz 3 attachments 2025-10-09 Exhibit A - Discovery Log.xIsx Dec 2024 Page 3.pdf 1139K Page 3.pdf = Nov1139K2024 https://mail.google.com/mail/u/0/7ik=546a93Ocb5&view=pt&search=all&permthid=thread-f: 8538906906 | 8699987%7Cmsp-f: 1853963 133834107797&simpl=msg-... 2/2 Copy from re:SearchTX

The matters set for hearing on January 20, 2026 include the following: 1. Enforcement of the existing order compelling the production of complete and previously unproduced discovery documentation; 2. Enforcement of the order reinstatement of healthcare existing requiring insurance coverage, including HSA and FSA access; 3. Enforcement of the Court's oral order directing the reestablishment of the status quo; 4. Request for authorization to issue third-party subpoenas, including but not limited to: a. Accenture, regarding Qualifying Life Event (QLE) submi...

1/15/2026 5:27 PM DALLAS CO., TEXAS NOTICE: DOCUMENT CONTAINS DF-24-18010 NO. SENSITIVE INFORMATION. MARRIAGE OF § § GWENDOLYN ULUASZ-MCKEMIE § 302" DISTRICT & § NOTICE OF HEARING (CONSOLIDATED) NOTICE IS HEREBY GIVEN: Please take notice that the matters have been set for before the Court as following hearing outlined below. I. HEARING SET FOR TUESDAY, JANUARY 20, 2026 at 9am: Motions: Respondent's Emergency Motion To: (1) Abate Trial, Exhibit Deadlines, And Bench Trial, (2) Enforce Discovery Orders and Authorize Necessary Third-Party Subpoenas, And (3)...

This motion seeks prospective, neutral procedural conditions applicable only upon any future re-entry of counsel for Petitioner and is intended to preserve procedural fairness, orderly discovery, and docket integrity. This consolidated notice is provided in accordance with the Texas Rules of Civil Procedure. Govern yourself accordingly. Respectfully, Jason McKemie Respondent, Pro Se 539 W. Commerce St., Ste. 2010 Dallas, TX 75208 (214) 868-4901 jmckemie@mckemie.net record, and provided to the Court on January 15, 2026, by electronic filing & email. JASON...

Date - Event Type Comments Documents Pages 12/31/2024 Filing NOT NOTICE OF COURT PROCEEDING-REQUEST FOR TEMPORA NOTICE OF HEARING.pdf : 3 12/31/2024 Filing AMDPT FIRST AMENDED COUNTERPETITION FOR DIVORCE & FIRST AMEND CONTERPETITION.pdf 31 : 12/27/2024 Filing NOT REQUEST FOR TEMPORARY ORDERS NOTICE OF COURT PROCEEDING - REQUEST FOR TEM... 3 : 12/20/2024 Filing NPO AMENDED TEMPORARY EX PARTE ORDER & PROPOSED AMENDED TEMPORARY EX PARTE ORDE... : 9 12/20/2024 Filing NPO PETITIONER AMENDED EMERGENCY EX PARTE TEMPORAR & PROPOSED AMENDED EMERGENCY EX PARTE TRO...

Events 166 Page 9 Search Events Even Type Q ® Expect To See More Filings? Date - Event Type Comments Documents Pages 12/18/2024 Filing ITPO & ISSUE TEMPORARY PROTECTIVE ORDER - GW... : 2 12/18/2024 Filing TRO AMEND EMERGENCY EX PARTE TRO AND SETTING HE • ORDER - TEMPORARY RESTRAINING ORDER.pdf : 12/18/2024 Service TEMPORARY PROTECTIVE ORDER - 12/18/2024 Service TRO / NOTICE - NCF-F No Documents 12/16/2024 Filing Filing ORP & ORIGINAL PETITION TO ANNUL MARRIAGE.pdf 8 12/16/2024 : 161 to 166 of 166

Date - Event Type Comments Documents Pages Hearing BENCH TRIAL2/24/2026 1/12/2026 Filing ASSOCIATE JUDGE'S REPORT ASSOCIATE JUDGE'S REPORT.pdf : 1 1/12/2026 Filing DOCKET SHEET DOCKET SHEET.pdf : 1 Filing AFFIDAVIT ON PUBLIC STORAGE THEFT ACCUSATIONS AN AFFIDAVIT ON PUBLIC STORAGE THEFT ACCUSATION... 1/12/2026 AFFIDAVIT : 8 1/12/2026 Filing MOTION - STAY EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS EMERGENCY MOTION TO STAY EVICTION PROCEEDIN... : 1/12/2026 Filing PROPOSED ORDER/JUDGMENT PROPOSED ORDER ON EMERGENCY MOTION TO STAY EV & PROPOSED ORDER ON E...

1. Medical Emergency o Respondent has documented congestive heart failure and is currently undergoing emergency-level medical treatment requiring uninterrupted access to prescribed medications. 2. Existing Healthcare Order o The Court previously ordered full reinstatement of healthcare, including functional access to HSA/FSA benefits. 3. Ongoing Noncompliance with Healthcare Order o Despite the Order, Respondent has experienced: » Nearly one year without HSA card access; « Presentation of a deactivated HSA card by Petitioner at the Motion to Compel heari...

* Functional card and PIN access; « Portal/login access to benefits; « Issuance of a card in Respondent's name; « A lawful basis for healthcare termination. 7. Discovery Noncompliance o Financial discovery remains materially incomplete: « The Court-ordered production map was not produced; « Party production is fragmented across multiple accounts, cards, and payment cycles; « Produced materials contain internal inconsistencies and missing data; « Even full production of party-held statements would not permit accurate reconstruction of the marital financia...

Proceeding with trial preparation under these conditions is medically impossible and risks irreversible harm. B. Healthcare Severance Risk Proceeding to divorce at this juncture would terminate dependent healthcare, creating an imminent risk that is: e foreseeable, « documented, e and directly attributable to Petitioner's delay and interference. The Court cannot force Respondent into a procedural posture that itself triggers life-threatening harm. C. Bankruptcy Preemption and Fair Trial Concerns The bankruptcy trustee's investigation necessarily overlaps...

No separate HSA portal is available for dependents to the best of Petitioner's knowledge. A portal and a password is not required to utilize the physical HSA card for qualified expenses, whether in person or online. To ensure proper documentation and avoid tax and penalties, Respondent may submit receipts for qualified medical expenses by email to Petitioner, consistent with the process previously used by the parties but in a timely manner. Petitioner requests the Court's awareness that this has been an issue in the past resulting in tax and penalities....

Exhibit A1: and clarification from Accountability Petitioner's HR Re: (employer) Respondent's Insurance issue Copy from re:SearchTX

Exhibit AdProof of Employer Insurance responsibility; no retro gap in coverage; and 2/24/26 Respondent coverage end. Ulijasz, Gwen From: Pott, Wynn E. Sent: Friday, December 19, 2025 1:35 PM To: Ulijasz, Gwen Subject: Benefits Coverage Hi Gwen. As we discussed, your husband (Jason McKemie) was mistakenly dropped from coverage due to a misunderstanding at our Benefits Center. It appears they thought your husband was no longer eligible for coverage, so contrary to your wishes, they terminated coverage. | have directed them to reinstate coverage, with no ga...

No separate HSA portal is available for dependents to the best of Petitioner's knowledge. A portal and a password is not required to utilize the physical HSA card for qualified expenses, whether in person or online. To ensure proper documentation and avoid tax and penalties, Respondent may submit receipts for qualified medical expenses by email to Petitioner, consistent with the process previously used by the parties but in a timely manner. Petitioner requests the Court's awareness that this has been an issue in the past resulting in tax and penalities....

Exhibit A1: and clarification from Accountability Petitioner's HR Re: (employer) Respondent's Insurance issue Copy from re:SearchTX

Exhibit AdProof of Employer Insurance responsibility; no retro gap in coverage; and 2/24/26 Respondent coverage end. Ulijasz, Gwen From: Pott, Wynn E. Sent: Friday, December 19, 2025 1:35 PM To: Ulijasz, Gwen Subject: Benefits Coverage Hi Gwen. As we discussed, your husband (Jason McKemie) was mistakenly dropped from coverage due to a misunderstanding at our Benefits Center. It appears they thought your husband was no longer eligible for coverage, so contrary to your wishes, they terminated coverage. | have directed them to reinstate coverage, with no ga...

IV. IRREPARABLE HARM & WHY DELAY DEFEATS RELIEF Immediate eviction before judicial review would cause irreparable harm. Respondent's medical instability amplifies the danger of displacement and inability to move safely. Relief that is not immediately accessible will not prevent eviction because statutory deadlines expire before further review is available. A narrow TRO is necessary to preserve the status quo now. V. RELIEF REQUESTED Respondent respectfully requests that the Court: A. Compel immediate direct payment of $21,497 by 2:00pm on the Date of Sig...

CONDITIONAL FINDING OF BAD FAITH AND OBSTRUCTION The Court finds that Respondent's sworn affidavit establishes that Respondent is medically incapacitated, unable to relocate, and at risk of homelessness absent timely receipt of funds acknowledged or conceded as belonging to Respondent. In the event the opposing party fails to timely comply with a court-ordered payment obligation without good cause, and such failure foreseeably places Respondent at risk of homelessness or irreparable harm, the Court may deem such noncompliance evidence of bad faith, obstr...

DF-24-18010 THE MARRIAGE OF § § & ON EMERGENCY REINSTATEMENT OF HEALTHCARE On this day, the Court considered Jason McKemie's (Respondent's) Emergency Motion regarding reinstatement of healthcare coverage. The Court finds immediate relief is necessary to prevent medical har : IT1S RDERED: |. COMPLIANCE PATH (PETITIONER MUST CHOSE AND COMPLETE ONE PATH) 1. Within twenty-four (24) hours of the signing of this Order, Petitioner shall complete one of the following two compliance paths and provide Respondent written proof of completion (email is sufficient). O...

I. GOOD-FAITH COOPERATION AND NARROWED REQUEST D. WILLINGNESS TO COOPERATE UNDER STRUCTURE. e Mr. McKemie is willing to cooperate with a lawful retrieval of specifically identified items through a controlled, neutral process. If permitted by the Court, Mr. McKemie further offers to facilitate retrieval by staging approved items in a neutral location (e.g., a garage) pursuant to a court-ordered protocol. Ill. RELIEF REQUESTED (TEMPORARY STAY OR PROTECTIVE CONDITIONS) Mr. McKemie respectfully requests that the Court enter one of the following: - E. PRIMARY...

Retrieval shall expressly exclude andnopersonmayremove documents, computers, electronics, storage media, safes, records, tools, office contents, fixtures, or any item not listed. Jason McKemie will move any and all of Petitioner's remaining belongings which were in the downstairs office into an area for retrieval. No entry into OFFICES ON FLOOR 1 OR 2 as they will be used to store Mr. McKemie's artifacts only. 6. NO SEARCH; NO DEVICES; NO RECORDING. No searching, rummaging, or opening of drawers or cabinets beyond what is reasonably necessary to retrieve...

removal, inventory, or storage of property be conducted solely by the landlord or a neutral third party under lawful authority, with written inventory and preservation pending further order of the Court. IV. ESSENTIAL LIVING PROPERTY (EXPRESS EXCLUSION) 13. Mr. McKemie is currently medically compromised and lacks access to funds or credit. To prevent irreparable harm, any property retrieval shall expressly exclude essential living items necessary for Respondent's daily survival and medical needs, including but not limited to: a bed and bedding, mattress,...

IV. IRREPARABLE HARM & WHY DELAY DEFEATS RELIEF Immediate eviction before judicial review would cause irreparable harm. Respondent’s medical instability amplifies the danger of displacement and inability to move safely. Relief that is not immediately accessible will not prevent eviction because statutory deadlines expire before further review is available. A narrow TRO is necessary to preserve the status quo now. V. RELIEF REQUESTED Respondent respectfully requests that the Court: A. Compel immediate direct payment of $21,497 by 2:00pm on the Date of Sig...

CONDITIONAL FINDING OF BAD FAITH AND OBSTRUCTION The Court finds that Respondent’s sworn affidavit establishes that Respondent is medically incapacitated, unable to relocate, and at risk of homelessness absent timely receipt of funds acknowledged or conceded as belonging to Respondent. In the event the opposing party fails to timely comply with a court-ordered payment obligation without good cause, and such failure foreseeably places Respondent at risk of homelessness or irreparable harm, the Court may deem such noncompliance evidence of bad faith, obstr...

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3. Registry Compliance Is Contingent on Court-Ordered Funds. Respondent's ability to tender rent or comply with any rent registry requirement is contingent upon receipt of court-ordered funds from Petitioner currently pending before another court. 4. Unresolved Accounting Issues Are Not Before This Court. There are unresolved payment and accounting issues related to the tenancy that cannot be adjudicated on an emergency basis. Respondent does not ask this Court to resolve those disputes here. 5. Conditional Impossibility and Tolling. Until court-ordered...

Respondent respectfully requests that the Court grant one or more of the following temporary, non- merits forms of relief: 10. Temporary stay of eviction proceedings, including issuance or execution of any writ of possession, during Respondent's medical incapacitation and for a short, defined period thereafter; 11. Extension of the rent registry deadline for a reasonable period to allow medical stabilization and receipt of court-ordered funds; OR, IN THE ALTERNATIVE 12. Stay of execution as to possession and personal property only, prohibiting removal du...

WHEREFORE, PREMISES CONSIDERED, Respondent respectfully requests that the Court grant this Emergency Motion and such other and further relief as justice requires. Respectfully submitted, Jason McKemie Respondent, Pro Se 539 W. Commerce St., Suite 2010 Dallas, Texas 75208 21 868-4901 jmckemie@mckemie.net DF-24-18010 4 of 4 Copy from re:SearchTX

Il. THE COURT ORDERED HEALTHCARE/HSA ACCESS; PETITIONER CLAIMS COMPLIANCE; FUNCTIONAL ACCESS REMAINS BLOCKED HSA access has been restored, and that Respondent can comply by uploading receipts to a portal without needing credentials. Respondent disputes those compliance claims because they conflict with objective administrator confirmations and the system's own behavior. Il]. OBJECTIVE DISCREPANCIES: PETITIONER'S "COMPLIANCE" CANNOT BE RELIED UPON A. Coverage Termination Processed as a QLE (COBRA / Decree-Upload Logic) 7. Respondent was informed by plan/e...

13. Petitioner's compliance representations are materially inconsistent with objective administrator/system facts; 14. Respondent cannot comply with Petitioner's demanded portal/receipt process because it is technically impossible without access controlled and withheld by Petitioner; and 15. Respondent has suffered actual medical harm requiring emergency preservation relief. These findings are necessary to prevent future prejudice, prevent reliance on inaccurate narratives, and support interim relief pending third-party production. V. EMERGENCY MAKE-WHOL...

Vill. EXPRESS PRESERVATION OF LIABILITY AND CIVIL/ERISA CLAIMS 24. Respondent expressly preserves all claims and remedies against any responsible party, including Petitioner, the employer, the ERISA plan administrator, benefits vendors, and any third-party service providers. 25. Nothing in this Motion constitutes a waiver, election of remedies, admission of fault, or release of claims. IX. RELIEF REQUESTED Respondent requests the Court: A. Medical Preservation / Functional Access 1. Order immediate restoration of functional healthcare and prescription ac...

IV. IRREPARABLE HARM & WHY DELAY DEFEATS RELIEF Immediate eviction before judicial review would cause irreparable harm. Respondent's medical instability amplifies the danger of displacement and inability to move safely. Relief that is not immediately accessible will not prevent eviction because statutory deadlines expire before further review is available. A narrow TRO is necessary to preserve the status quo now. V. RELIEF REQUESTED Respondent respectfully requests that the Court: A. Compel immediate direct payment of $21,497 by 2:00pm on the Date of Sig...

CONDITIONAL FINDING OF BAD FAITH AND OBSTRUCTION The Court finds that Respondent's sworn affidavit establishes that Respondent is medically incapacitated, unable to relocate, and at risk of homelessness absent timely receipt of funds acknowledged or conceded as belonging to Respondent. In the event the opposing party fails to timely comply with a court-ordered payment obligation without good cause, and such failure foreseeably places Respondent at risk of homelessness or irreparable harm, the Court may deem such noncompliance evidence of bad faith, obstr...

DF-24-18010 THE MARRIAGE OF § § & ON EMERGENCY REINSTATEMENT OF HEALTHCARE On this day, the Court considered Jason McKemie's (Respondent's) Emergency Motion regarding reinstatement of healthcare coverage. The Court finds immediate relief is necessary to prevent medical har : IT1S RDERED: |. COMPLIANCE PATH (PETITIONER MUST CHOSE AND COMPLETE ONE PATH) 1. Within twenty-four (24) hours of the signing of this Order, Petitioner shall complete one of the following two compliance paths and provide Respondent written proof of completion (email is sufficient). O...

II. THE COURT ORDERED HEALTHCARE/HSA ACCESS; PETITIONER CLAIMS COMPLIANCE; FUNCTIONAL ACCESS REMAINS BLOCKED HSA access has been restored, and that Respondent can comply by uploading receipts to a portal without needing credentials. Respondent disputes those compliance claims because they conflict with objective administrator confirmations and the system’s own behavior. III. OBJECTIVE DISCREPANCIES: PETITIONER’S “COMPLIANCE” CANNOT BE RELIED UPON A. Coverage Termination Processed as a QLE (COBRA / Decree-Upload Logic) 7. Respondent was informed by plan/e...

13. Petitioner’s compliance representations are materially inconsistent with objective administrator/system facts; 14. Respondent cannot comply with Petitioner’s demanded portal/receipt process because it is technically impossible without access controlled and withheld by Petitioner; and 15. Respondent has suffered actual medical harm requiring emergency preservation relief. These findings are necessary to prevent future prejudice, prevent reliance on inaccurate narratives, and support interim relief pending third-party production. V. EMERGENCY MAKE-WHOL...

VIII. EXPRESS PRESERVATION OF LIABILITY AND CIVIL/ERISA CLAIMS 24. Respondent expressly preserves all claims and remedies against any responsible party, including Petitioner, the employer, the ERISA plan administrator, benefits vendors, and any third-party service providers. 25. Nothing in this Motion constitutes a waiver, election of remedies, admission of fault, or release of claims. IX. RELIEF REQUESTED Respondent requests the Court: A. Medical Preservation / Functional Access 1. Order immediate restoration of functional healthcare and prescription ac...

IV. IRREPARABLE HARM & WHY DELAY DEFEATS RELIEF Immediate eviction before judicial review would cause irreparable harm. Respondent's medical instability amplifies the danger of displacement and inability to move safely. Relief that is not immediately accessible will not prevent eviction because statutory deadlines expire before further review is available. A narrow TRO is necessary to preserve the status quo now. V. RELIEF REQUESTED Respondent respectfully requests that the Court: A. Compel immediate direct payment of $21,497 by 2:00pm on the Date of Sig...

CONDITIONAL FINDING OF BAD FAITH AND OBSTRUCTION The Court finds that Respondent's sworn affidavit establishes that Respondent is medically incapacitated, unable to relocate, and at risk of homelessness absent timely receipt of funds acknowledged or conceded as belonging to Respondent. In the event the opposing party fails to timely comply with a court-ordered payment obligation without good cause, and such failure foreseeably places Respondent at risk of homelessness or irreparable harm, the Court may deem such noncompliance evidence of bad faith, obstr...

DF-24-18010 THE MARRIAGE OF § § & ON EMERGENCY REINSTATEMENT OF HEALTHCARE On this day, the Court considered Jason McKemie's (Respondent's) Emergency Motion regarding reinstatement of healthcare coverage. The Court finds immediate relief is necessary to prevent medical har fe<4 : IT 1S'ORDERED: |. COMPLIANCE PATH (PETITIONER MUST CHOSE AND COMPLETE ONE PATH) 1. Within twenty-four (24) hours of the signing of this Order, Petitioner shall complete one of the following two compliance paths and provide Respondent written proof of completion (email is suffici...

6. | have not tampered with, removed, altered, or accessed any items within either storage unit | have not returned to the facility for any reason. since the date the property was separated. 7- Any suggestion or implication that personal property from the residence was removed and placed into storage is inaccurate and inconsistent with both the parties' prior agreements and the objective third-party records maintained by Public Storage. 8. Public Storage access records and video surveillance conclusively establish that the contents | have not accessed th...

15. DOCUMENTED HISTORY INVOLVING PETITIONER. A certified copy of the relevant Wisconsin Circuit Court records is attached hereto as [Exhibit A]. This exhibit is provided solely to ensure accurate safety context where allegations of danger or the asserted need for armed protection are raised, and to document that such assertions are inconsistent with my history and the publicly documented record. DECLARATION | declare under penalty of perjury that the foregoing is true and correct. Executed on January 11, 2026 At 9:30pm CST son Ja McKemie PATTERN OF FALSE...

Wisconsin Circuit Court Access (WCCA) State of Wisconsin vs. Gwendolyn L Stathoulopoulos Door County Case Number 2013CF000126 Filing Date Case Type Case Status - 09-10-2013 Criminal Open Deferred judgt./prosecute Defendant Date of Birth Address 05-27-1978 1512 W Chicago Ave Apt 4, Chicago, IL 60642 DA Case Branch Id Number 2 2013D0000772 Charge(s) Count Statute Description Severity Disposition No. Deferred Prosecution 1 946.41(1) Resisting an Officer Misd A or Sentence Battery to Law Enforcement Officers, Fire Fighters or Felony Charge Dismissed but 2 94...

7. After entering my office, Ms. Ulijasz went up to a security camera and accused me of recording her against her will while speaking directly into a camera. This accusation was made notwithstanding the fact that the security cameras were operating in the same manner they had throughout the marriage and remained active at her own suggestion to provide transparency and reassurance. 8. Upon my return to the residence, I found this camera pulled from the wall and shattered on the floor. It appeared to have been thrown at the ground and stepped on. 9. Severa...

Executed on January 11, 2026 At 10:30pm CST o J McKemie Exhibit A1 (Private Stream) Gwen Ulijasz Alleging Inappropriate Surveillance after Breaking into Locked Office Exhibit A2 (Download) Gwen Ulijasz Alleging Inappropriate Surveillance after Breaking into Locked Office Exhibit B Text Message Prior to Her Return to Residence a7 BU Dfifice stuff to work and my :::::::::::::::::::::::: lothes. I'll leave you everything :::::::::::: we can sort things out in ingmonthe. ing I'm putting in the ca Gwen, I'm not trying to lock you out of the house can have all...

1/12/2026 4:38 AM CO TEXAS NOTICE: DOCUMENT CONTAINS DF-24-18010 NO. SENSITIVE INFORMATION. MARRIAGE OF § § & § MANUFACTURED ALLEGATIONS STATE OF TEXAS | COUNTY OF DALLAS BEFORE ME, the undersigned authority, on this day personally appeared Jason McKemie, who, being duly sworn, stated under oath as follows: | am the Respondent in 1. My name is Jason McKemie and my Date of Birth is April 8th, 1976. mind, competent to make this affidavit, and all statements herein are based on my personal knowledge and are true and correct. 2. On December 18, 2024, Gwendol...

s Il. WHAT PETITIONER ASKS FOR (AND WHY IT'S NOT "LIMITED"') Petitioner requests leave to issue three subpoenas: e Amazon: itemized purchase history and shipping info for Aug. 1, 2023-Dec. 31, 2025. e Apple: itemized purchase history/subscriptions/hardware purchases/payment methods for the same period. e PhysicalAddress.com: digital scan images of packages/envelopes for mail addressed to Petitioner (individually or jointly) for calendar years 2024 and 2025. Petitioner further asks that each subpoena include a custodian affidavit to streamline admissibili...

"neutral business records," this is a sweeping request that captures far more than what would be necessary for a fair inventory of household items and invites collateral disputes and trial distraction. D. The "December 24 cutoff" explanation underscores lack of diligence, not good cause Petitioner states the discovery cutoff "fell on December 24, 2025" and offers travel/work obligations and a healthcare-related dispute as "context." That context does not justify reopening discovery after the deadline, particularly where the motion already set to address...

1/8/2026 12:37 PM s DALLAS CO., TEXAS NOTICE: DOCUMENT CONTAINS DF-24-18010 NO. SENSITIVE INFORMATION. MARRIAGE OF § § & § NOTICE OF VOLUNTARY COMPLIANCE & OBJECTION TO PREMATURE, POST-CUTOFF, THIRD-PARTY SUBPOENA REQUEST WITHOUT A SINGLE PRIOR PRODUCTION REQUEST Jason McKemie files this Notice of Voluntary Compliance and Objection to Petitioner's "Motion for Leave to Conduct Limited Post-Cutoff Discovery." Petitioner seeks leave to issue post-cutoff subpoenas to Amazon, Apple, and PhysicalAddress.com. I. SUMMARY OF OBJECTION (THE "WHY THIS IS IMPROPER"...

6. Petitioner was excluded from accessing the 5609 La Foy, Dallas TX marital residence and its contents by order of the court. Petitioner was blocked by the Respondent to accessing the storage locations and private mailboxes where hundreds of Amazon and Apple packages were received. Petitioner therefore cannot independently identify or inventory property acquired during the above period. 7. Petitioner is now self-represented and, in preparing for trial, has identified a small and discrete set of third-party records essential to fair trial preparation. II...

9. Each proposed subpoena requests production with a custodian of records affidavit to streamline admissibility at trial. IV. GOOD CAUSE FOR LEAVE OF COURT 10. Good cause exists to permit this limited discovery because: a. The records were previously requested but not produced; b. Petitioner was excluded from access to the underlying accounts, records, and residence; c. A substantially similar subpoena covering calendar year 2024 was previously authorized by the 254th Court and complied with by the same mailbox provider; d. The requested discovery is pro...

1/5/2026 12:00 AM DALLAS CO., TEXAS PETITIONER'S MOTION FOR LEAVE TO CONDUCT LIMITED POST-CUTOFF DISCOVERY IN THE MATTER OF THE MARRIAGE OF GWENDOLYN ULIJJASZ, Petitioner and JASON McKEMIE, Respondent TO THE HONORABLE JUDGE OF SAID COURT: Petitioner, Gwendolyn Ulijasz, appearing pro se, respectfully moves the Court for leave to conduct limited, targeted discovery after the discovery cutoff established in the Court's Pre- Trial Order and, in support, states as follows: I. PROCEDURAL BACKGROUND 1. This matter is set for final trial on February 24, 2026. 2....

6. McKemie expressly withholds consent to any off-the-record proceeding and preserves objection to being required to proceed without an official record. Any participation under those circumstances is involuntary and undertaken solely to avoid default, waiver, or other prejudice. 7. fan official record cannot be provided for a scheduled setting, McKemie respectfully requests the Court continue/reset the setting to the earliest date when an official record can be made. 1l. STATUTORY RIGHT TO A RECORD & THE COURT'S AUTHORITY TO ENSURE IT 8. Tex. Gov't Code...

VI. REQUEST REGARDING FEES / COSTS OF THE RECORD 15. To the extent any fees are required to produce or copy the official record or transcript (including under Tex. Gov't Code § 52.047), McKemie requests the Court order that such fees be: a taxed to Petitioner, and/or b. paid from community/marital funds as a case-administration expense, subject to later reallocation as the Court deems just. VII. INABILITY TO PREPAY (iF REQUIRED) 16. If the Court requires any prepayment as a condition of obtaining the record or a copy of an official ca Statement of record...

10/29/2025 1:13 PM DALLAS CO., TEXAS NOTICE: DOCUMENT CONTAINS DF-24-18010 NO. SENSITIVE INFORMATION. MARRIAGE OF § § & § STANDING FOR COURT REPORTER FOR REQUEST OCT. 31, 2025 HEARING AND ALL SUBSEQUENT PROCEEDINGS I, Jason McKemie, Respondent, appearing pro se, respectfully request that a licensed court reporter be present to record the following proceeding and all future hearings and trial in this cause pursuant to Texas Rule of Appellate Procedure 13.1(a). Requested Proceeding e Date: Friday, October 31, 2025 e Time: 9:30 a.m. e Judge: Hon. Tamika Bha...