DF-24-18010 Litigation Record Search

It took approximately 36 hours to bring the property back inside. By approximately 4:00 a.m., Applicant was physically exhausted and slept outside in a lawn chair to watch the property. At approximately 7:00 a.m., Applicant woke to the same blue Lexus stopped approximately 15 to 20 feet away, with the driver photographing Applicant through an open window using a DSLR camera. This was continued surveillance during physical vulnerability, not ordinary neighborhood activity. XI. BROADER FINANCIAL, LEASE, HEALTHCARE, AND LITIGATION CONTEXT The April 16 event...

EXHIBIT C NO.__________________________________________ APPLICANT § GWENDOLYN LAURA ULIJASZ § EXHIBIT - HEALTHCARE OBSTRUCTION CONTRADICTIONS MATRIX This exhibit is designed for rapid judicial review. Each contradiction identifies the statement, the contradictory record, and why the contradiction matters to the issue of healthcare obstruction and ongoing noncompliance. • False 'receipt upload' pretext used to block HSA access. • Claimed compliance despite nonfunctional or cancelled card access. • Objective system records still showing HSA/FSA waivers aft...

DF-24-18010NO.__________________________________________ THE MARRIAGE OF § § & § PHOTO EXHIBIT M MEDICAL HARM APRIL 2026 — MEDICAL HARM / TRANSACTION- TRIGGERED FINANCIAL ACCESS INTERFERENCE Recurrent staphylococcal infections began after prescribed antibiotic treatment was interrupted in May 2025, when Respondent reported Applicant’s HSA card lost/stolen during Applicant’s six-day hospitalization. Hospital staff restored access to the HSA card for the first time since Respondent locked the card on December 18, 2024, the application against Applicant. Th...

...tes Agency In the event Defendant satisfies these conditions, State will, at the end District 18 of 18 months, move to amend the criminal charge to forfeiture violation. Attorney Months Upon such amendment, amount deposited with Clerk of Court shall be taken as a total payment for this offense. Conditions Condition Time Notes Community 75 Defendant shall perform 75 hours of uncompensated service Hours community service for a not-for-profit agency or organization unrelated to the defendant or any family member, providing proof of such community service to...

the defendant to the District Attorney's office at least thirty (30) days before the expiration of this agreement. Defendant shall provide a copy of this agreement, along with the Criminal Complaint, to any counselor and sign any and all releases necessary to allow the counselor (or agency) to report compliance or lack thereof to the District Attorney's Office. Any assessments done without this agreement and the Criminal Complaint(s) being supplied to the counselor will be considered violations of this agreement and not be accepted. This agreement may be...

...ants, etc.etc. HerHer latestlatest wavewave ofof falsefalse allegationsallegations beganbeganimmediatelyimmediately afterafter II retainedretained aa familyfamily lawlaw attorneyattorney inin earlyearly DecemberDecember 2024.2024. SinceSince then,then, sheshe has:has: •• UsedUseda powera powerof ofattorneyattorneyto tocutcutoffoffmymyfinancialfinancialaccessaccessandandfalselyfalselyreportedreported mymy legallegal retainerretainer paymentpayment asas fraud,fraud, retractingretracting itit andand cancelingcanceling mymy creditcredit card.card. • Made• Mad...

Document Page 2 of 3 pro se, on April 16, 2026 [ECF No. 54].1 In the Motion, the Debtor requests that the Court reconsider its Order Terminating 11 U.S.C. § 362 Automatic Stay (the “Lift Stay Order”) entered on April 9, 2026 [ECF No. 43], in which the Court granted the Skweres Properties LLC’s Motion for Relief from Stay of Action Against Property Pursuant to 11 U.S.C. § 362 Debtor Stay as to Jason Emory McKemie and Co-Debtor Stay as to Gwendolyn Laura Ulijasz, Waiver of Thirty Day Requirement Pursuant to § 362(e), and Request for Hearing in Dallas, Texa...

...T AFFIDAVIT - MANUFACTURED ALLEGATIONS 2. MOTIONS (ALL RESPONDENT MOTIONS & MOTION-LIKE APPLICATIONS) 2025 • 03/14/2025 (Entry 48) — 4 pages — MOTION - AGREED - WITHDRAW ATTORNEY - BRANT WEBB • 03/28/2025 (Entry 51) — 2 pages — NOTICE OF FAILED MEDIATION AND MOTION FOR CONTINUANCE OF APRIL 7th, 2025, PRE-TRIAL HEARING MOTION FOR CONTINUANCE-NOTICE OF FAILED MEDIATION AND OF APRIL 7th, 2025, PRE-TRIAL HEARING • 04/14/2025 (Entry 55) — 5 pages — MOTION TO STRIKE IMPROPER EXPERT DESIGNATIONS AND TO LIMIT TESTIMONY OF OPPOSING COUNSEL • 04/24/2025 (Entry 56)...

• 07/16/2025 (Entry 86) — 75 pages — EMERGENCY M/PRESERVE EVIDENCE AND CONTINUE TRIAL DUE TO PROCEDURAL SABOTAGE AND BREAKDOWN IN JUDICIAL OVERSIGHT • 07/16/2025 (Entry 87) — 4 pages — TO SEEK DISPROPORTIONATE DIVISION OF MARITAL ESTATE NOTICE OF INTENT SEEK DISPROPORTIONATE DIVISION OF • 07/17/2025 (Entry 85) — 5 pages — ORDER GRANTING M/SANCTIONS AND REFERRAL PROPOSED MOTION SANCTION FOR AGGRAVATED PERJURY AND FRAUD UPON THE OCURT AGAINST • 07/17/2025 (Entry 88) — 2 pages — EMERGENCY NOTICE OF COUNSEL MISCONDUCT, PRIOR COMMUNICATIONS, AND DEMAND FOR IM...

• 11/21/2025 (Entry 133) — 6 pages — MOTION FOR DE NOVO DISTRICT JUDGE REVIEW OF PRIOR RULINGS AND EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER MOTION - MISCELLANEOUS • 12/12/2025 (Entry 136) — 25 pages — EMERGENCY MOTION FILING SEEKING IMMEDIATE RELIEF REQUIRING MEDICAL ACCESS • 12/19/2025 (Entry 143) — 26 pages — MOTION TO COMPEL (ENVELOPE #109297794 DOC001) • 12/19/2025 (Entry 145) — 18 pages — EMERGENCY ENFORCEMENT ORDER FOR MEDICAL PRESERVATION ORDER - MISC. • 12/23/2025 (Entry 146) — 2 pages — TEMPORARY RESTRAINING ORDER PROPOSED ORDER/JUD...

• 07/10/2025 (Entry 76) — 1 page — ORDER TO ENFORCE STANDING ORDERS AND PREVENT LITIGATION INTERFERENCE PROPOSED ORDER/JUDGMENT • 07/10/2025 (Entry 77) — 1 page — ORDER GRANTING EMERGENCY MOTION TO STAY EXECUTION OF WRIT OF POSSESSION PROPOSED ORDER/JUDGMENT • 07/10/2025 (Entry 79) — 26 pages — FINANCIAL RELIEF, ENFORCEMENT OF STANDING ORDERS, PROTECTION AGAINST PROCEDURAL ABUSE, AND HEARING ON SPOUSAL SUPPORT, LEGAL FEES, MARITAL DEBT AND EARLY LOAN REPAYMENT DUE TO MEDICAL HARDSHIP – FINANCIAL RELIEF, CONTINUANCE, ENFORCEMENT OF STANDING ORDERS • 07/10...

• 01/14/2026 (Entry 180) — 11 pages — MOTION TO ABATE TRIAL, ENFORCE DISCOVERY ORDERS AND HEALTHCARE REINSTATEMENT • 01/26/2026 (Entry 185) — 5 pages — NOTICE OF PRESERVATION OF WITNESSES, & LARGE DISCOVERY PRODUCTION IN FINAL HOUR NOTICE OF PRESERVATION OF WITNESSES, & LARGE DISCOVERY PRODUCTION IN FINAL HOUR 7. DUE PROCESS / RECORD PRESERVATION / EX PARTE CONCERNS / COURT REPORTER / VERBATIM RECORD 2025 • 04/24/2025 (Entry 56) — 1 page — MOTION FOR NOTICE PRIOR TO ANY DISMISSAL PROPOSED ORDER ON MOTION FOR NOTICE PRIOR TO ANY DISMISSAL • 04/24/2025 (En...

• 08/06/2025 (Entry 104) — 7 pages — EMERGENCY MOTION TO ABATE TRIAL SETTING AND WITHHOLD FINAL ORDERS PENDING RESOLUTION OF OUTSTANDING MOTIONS, PROCEDURAL VIOLATIONS, AND DISCOVERY COLLAPSE • 08/07/2025 (Entry 105) — 11 pages — JUDICIAL NOTICE OF UNRULED MOTIONS REQUIRING DETERMINATION PRIOR TO ANY PRETRIAL HEARING, TRIAL, OR FINAL JUDICIAL NOTICE OF UNRULED MOTIONS • 08/08/2025 (Entry 106) — 4 pages — NOTICE OF PROCEDURAL BAR TO PRETRIAL OR TRIAL SETTING AND PRESERVATION OF OBJECTION • 10/29/2025 (Entry 123) — 3 pages — STANDING REQUEST FOR COURT REPO...

• 01/20/2026 (Entry 184) — 34 pages — RESPONDENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, REQUEST FOR REMOTE APPEARANCE, REQUEST FOR ACCESS TO PERSONAL PROPERTY, REQUEST FOR CONSOLIDATION & HEARING LIMITS, AND CASE MANAGEMENT CLARIFICATION • 01/15/2026 (Entry 182) — 4 pages — RESPONDENT'S MOTION TO ESTABLISH CONDITIONS FOR RE-ENTRY OF COUNSEL AND TO PRESERVE FAIR TRIAL 8. EVICTION / HOUSING STABILITY 2025 • 06/24/2025 (Entry 66) — 8 pages — EMERGENCY MOTION FOR TEMPORARY FINANCIAL RELIEF DUE TO IMMINENT HOUSING LOSS, MEDICAL HARDSHIP EMERGENCY M/...

witness was called, before any exhibit was offered, before any testimony was taken, and before any trial evidence was received. Jason also requested that the recusal be addressed before evidence and objected to any witness being called, exhibit being offered, testimony being taken, or trial evidence being received before the motion was decided or referred. The e-service record reflects that the Motion to Recuse and Request for Referral was served on June 11, 2026 at 1:21:45 p.m. III. RULE 18a STATUS NEEDS TO BE CLARIFIED BEFORE DECREE ACTION Texas Rule o...

UNSWORN DECLARATION OF JASON MCKEMIE My name is Jason McKemie. My date of birth is April 8, 1976. My address is 539 W. Commerce St., Ste. 2010, Dallas, Texas 75208. factual statements in this Emergency Rule 18a Status Notice are true and correct based on my available to me, emails received by me, records reviewed by me, and documents in my possession or accessible to me. As of the filing of this notice, I have not located any written order of recusal, written denial, written referral order, or written/on-record good-cause basis for further decree action...

THE MARRIAGE OF § § AND § PETITIONER’S MOTION TO SIGN AND ENTER FINAL DECREE OF DIVORCE TO THE HONORABLE JUDGE OF SAID COURT: Petitioner, Gwendolyn Ulijasz McKemie, files this Motion to Sign and Enter Final Decree of Divorce and respectfully requests that the Court sign and enter the proposed Final Decree of Divorce submitted on June 11, 2026, and attached to this motion as Exhibit A. In support, Petitioner respectfully shows: I. INTRODUCTION 1. The Court heard the final trial in this matter on June 11, 2026. Petitioner appeared and presented evidence. R...

...CE OF ENTITLEMENT TO FEES 17. Because the pending recusal motion is a tertiary recusal motion, upon its denial the judge hearing it “shall award reasonable and necessary attorney’s fees and costs to the party opposing the motion,” for which “[t]he party making the motion and the attorney for the party are jointly and severally liable.” TEX. CIV. PRAC. & REM. CODE § 30.016(c). Petitioner reserves and intends to pursue her right to such fees and costs. V. PRAYER 18. Petitioner respectfully requests that the Court set this motion for submission or hearing a...

W-2. All Accenture Restricted Stock Units (RSUs), vested and unvested, granted to or held in the name of Wife, including the unvested shares, together with all rights to vesting, dividends, and proceeds thereof. W-3. The Chase Checking account ending in x9259 together with all funds on deposit therein. W-4. The Accenture HSA account, together with all funds on deposit therein. W-5. The BMW automobile, together with all keys, title documents, and equipment, subject to the indebtedness thereon as allocated below. W-6. All clothing, jewelry, electronics, ho...

10. Change of Name The Court finds that Petitioner specifically requested this name change and that GWENDOLYN LAURA ULIJASZ is a name previously used by Petitioner. IT IS ORDERED AND DECREED that the name of Petitioner, GWENDOLYN ULIJASZ-McKEMIE, is changed to GWENDOLYN LAURA ULIJASZ. 11. Court-Ordered Documents; Execution of Instruments; Turnover IT IS ORDERED AND DECREED that each party shall, at the request of the other party or the other party's counsel, execute, acknowledge, and deliver any deed, title, assignment, release, qualified domestic relati...

...s suppression, and the newly surfaced SAPD/writ/property evidence. 3. Deny in full any request by Petitioner, her counsel, experts, vendors, investigators, or agents for attorney fees, costs, sanctions, protective expenses, expert/vendor expenses, or any cost shifting against Jason. Jason McKemie 539 W. Commerce St., Ste. 2010, Dallas, TX 75208 | 214-868-4901 jmckemie@mckemie.net 2 of 19 Copy from re:SearchTX

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...

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...

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...

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...

...itioner's proposed marital timeline is contradicted by sealed in-camera exhibits, joint accounts, joint investments, domestic-partnership documents, reciprocal powers of attorney, beneficiary records, character/relationship witnesses, and a signed Declaration and Registration of Informal Marriage dated September 22, 2023. 9. The Court has been notified that healthcare/HSA/FSA/QLE/COBRA compliance remains disputed and requires third-party source verification before any decree affecting healthcare access is signed or enforced. 10.The Court has been notifie...

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

5. Based on my personal experience, Gwendolyn Laura Ulijasz used legal proceedings and protective-order restrictions in a manner that impaired my ability to speak freely about her conduct, defend myself, communicate with relevant witnesses, or warn others. 6. I am aware that protective-order language or related restrictions have been used or asserted in a way that discourages or prevents me from communicating information about Gwendolyn Laura Ulijasz to third parties. 7. I am willing to testify despite concern that doing so may expose me to retaliation,...

6/12/2026 8:31 AM CLERKTEXAS NOTICE: THIS DOCUMENT CONTAIASBISLAS THE MARRIAGE OF § § & § RESPONDENT'S EMERGENCY OBJECTION TO PROPOSED FINAL DECREE, NOTICE OF PENDING RECUSAL MATTERS, REQUEST TO WITHHOLD SIGNATURE AND ENTRY, AND NOTICE OF MANDAMUS TO THE HONORABLE COURT: Respondent Jason McKemie files this Emergency Notice of Under-Review Filings, Objection to Petitioner's Proposed Final Decree, Request for Recusal Delivery and Referral, Request to Withhold Signature and Entry, Request to Stay Enforcement, and Notice of Mandamus. This filing is made on a...

...'s source-record issues; 10.Respondent's Rule 204 issues; 11.Respondent'sfinancial-stabilizationandaccess-to-counselissues; 12.Respondent'ssanctions,contempt,civil-claim,attorney-misconduct,criminal-referral, and non-waiver issues. Respondent objects to any decree that uses a global catchall denial to dispose of Respondent's recusal objection, medical-incapacity objection, no-bridge objection, de novo request, healthcare/OLE/HSA/FSA issues, source-record issues, stolen-evidence issues, Rule 204 request, financial-relief requests, sanctions requests, civi...

Respondent objects to any decree that rewards Petitioner's theft, evidence theft, hard-drive theft, stolen legal work product, stolen trial materials, stolen healthcare records, stolen financial records, stolen device evidence, and manufactured law-enforcement narratives. Respondent further objects to any decree that permits Gwendolyn Laura Ulijasz, her counsel, experts, vendors, investigators, agents, contractors, or anyone acting with or for her to access, inspect, image, copy, test, review, rely on, use, disclose, control, receive, use derivatively, u...

...ule 204 request and related threshold-discovery objections; 17.rule on Respondent's financial-stabilization, survival-level temporary relief, access-to- counsel, interim attorney-fee, litigation-expense, and parity relief requests; 18.rule on Respondent's sanctions, contempt, fee-shifting, civil-claim, attorney- misconduct, and criminal-referral preservation issues; 19. deny in full any request by Petitioner, counsel, experts, vendors, agents, or anyone acting with or for her for fees, costs, sanctions, expert expenses, vendor expenses, protective expens...

...oes not waive any objection, claim, defense, request, relief, sanctions request, contempt request, mandamus issue, appellate issue, civil claim, criminal-referral issue, attorney-misconduct issue, healthcare-obstruction issue, source-record issue, stolen-evidence issue, financial-sabotage issue, false-reporting issue, digital-intrusion issue, Rule 204 issue, protective-relief issue, reimbursement claim, parent-loan claim, forensic-accounting request, or request for emergency survival-level financial relief, interim attorney's fees, litigation expenses, a...

6. deliver, refer, and address Respondent's verified pre-evidence recusal motion under Rule 18a; 7. rule on Respondent's emergency filings, medical-incapacity objections, no-bridge objections, healthcare objections, stolen-evidence objections, source-record objections, de novo/trial-readiness objections, Rule 204 issues, financial- stabilization requests, access-to-counsel requests, sanctions requests, non-waiver filings, and proposed order; 8 . deny in full any request for fees, costs, sanctions, expert expenses, vendor expenses, protective expenses, di...

44 Jason McKemie 14 of 14 Copy from re:SearchTX

6/11/2026 1:21 PM DALLAS CO., TEXAS NO. DF-24-18010 THE MARRIAGE OF § § & § RESPONDENT'S VERIFIED MOTION TO RECUSE AND REQUEST FOR REFERRAL UNDER TEXAS RULE OF CIVIL PROCEDURE 18a TO THE HONORABLE COURT: Respondent, Jason McKemie, files this Verified Motion to Recuse before any evidence has been offered at the June 11,2026, trial setting, before any witness has been called, before any exhibit has been offered, before any testimony has been taken, and before any trial evidence has been received. This filing is made to invoke the recusal procedure before t...

...l records, trial materials, printer, printer ink, itigation equipment, medications, or device evidence. 6. Denial in full of any request by Petitioner or her counsel for attorney's fees, costs, sanctions, expenses, protective expenses, vendor costs, or any other fee shifting against Respondent. THIS MOTION IS NOT BASED MERELY ON ADVERSE RULINGS This Motion is not based merely on adverse rulings. It is based on the current record, the appearance of prejudgment, and new material developments since the prior recusal proceedings, including evidence theft, st...

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...

UNSWORN DECLARATION OF JASON MCKEMIE My name is Jason McKemie. My date of birth is April 8, 1976. My address is 539 W. Commerce St., Ste. 2010, Dallas, Texas 75208. declare under penalty of perjury that the factual statements in this Verified Motion to Recuse are true and correct based on my personal knowledge, documents, videos, audio, court filings, records reviewed by me, and matters stated on information and belief where the basis for that belief is identified. Executed in Texas on June 11, 2026. Jason McKemie and/or email on June11,2026. Jason McKem...

Jason McKemie Page 7 of 7 Copy from re:SearchTX

6/11/2026 1:26 PM DALLAS CO., TEXAS DF-24-18010 NO. THE MARRIAGE OF § § & § RESPONDENT'S NOTICE OF NON-WAIVER OF SANCTIONS, CONTEMPT, FEE OBJECTIONS, CIVIL CLAIMS, ATTORNEY MISCONDUCT CLAIMS, AND OBJECTION TO TREATING ENGINEERED COLLAPSE AS WAIVER TO THE HONORABLE COURT: Respondent, Jason McKemie, files this Notice before final trial, final orders, or any ruling that could be used to suggest waiver, abandonment, merger, release, adjudication, or consent. From this point forward, Jason McKemie is referred to as Respondent. Respondent does not waive sancti...

...struction 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 obstruction, false representations, fee claims, sanctions exposure, disqualification, disgorgement, disciplinary complaints, and referrals where legally supported; 18. Sanctions, contempt, enforcement, adverse inferences, exclusion,...

UNSWORN DECLARATION OF JASON MCKEMIE My name is Jason McKemie. My date of birth is April 8, 1976. My address is 539 W. Commerce St., Ste. 2010, Dallas, Texas 75208. declare under penalty of perjury that the factual statements in this Notice are true and correct based on my personal knowledge, documents, videos, audio, court filings, records reviewed by me, and matters stated on information and belief where the basis for that belief is identified. Executed in Texas on June11,2026. Jason McKemie and/or email on June 11,2026. Jason McKemie Page 6 of 6 Copy...

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...

Petitioner stole Respondent's Apple TV/device evidence and then used or attempted to use that stolen device to manufacture a false stalking/surveillance narrative with San Antonio Police a false accusation against Department. A device stolen from Respondent was turned into Respondent. Respondent's police reports and report numbers regarding the Dallas theft were stolen from his desk. Respondent has requested open records but has not had time to receive them before today's trial. SOURCE FINANCIAL RECORDS AND HEALTHCARE RECORDS REMAIN UNAVAILABLE The finan...

UNSWORN DECLARATION OF JASON MCKEMIE My name is Jason McKemie. My date of birth is April 8, 1976. My address is 539 W. Commerce St., Ste. 2010, Dallas, Texas 75208. | declare under penalty of perjury that the factual statements in this Verified Emergency Motion are true and correct based on my personal knowledge, documents, videos, audio, court filings, records reviewed by me, and matters stated on information and belief where the basis for that belief is identified. Executed in Texas on June 11,2026. Jason McKemie and/or email on June11,2026. Jason McKe...

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...

Petitioner stole Respondent’s Apple TV/device evidence and then used or attempted to use that stolen device to manufacture a false stalking/surveillance narrative with San Antonio Police Department. A device stolen from Respondent was turned into a false accusation against Respondent. Respondent’s police reports and report numbers regarding the Dallas theft were stolen from his desk. Respondent has requested open records but has not had time to receive them before today’s trial. SOURCE FINANCIAL RECORDS AND HEALTHCARE RECORDS REMAIN UNAVAILABLE The finan...

UNSWORN DECLARATION OF JASON MCKEMIE My name is Jason McKemie. My date of birth is April 8, 1976. My address is 539 W. Commerce St., Ste. 2010, Dallas, Texas 75208. I declare under penalty of perjury that the factual statements in this Verified Emergency Motion are true and correct based on my personal knowledge, documents, videos, audio, court filings, records reviewed by me, and matters stated on information and belief where the basis for that belief is identified. Executed in Texas on June 11, 2026. __________________________________ Jason McKemie and...

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...

...order that blocks third-party source-record verification. 17.The denial, grant, implied grant, carry-forward, reservation, or failure to reject Petitioner's request for attorney's fees, costs, protective expenses, expert/vendor expenses, discovery expenses, or any cost shifting against Jason McKemie. Jason specifically requests that all such fee/protective-expense/cost-shifting requests by DF-24-18010 Request for De Novo Hearing on Respondent's: Motion for Enforcement, Sanctions, Continuance, and Leave to Issue Third-Party Subpoenas! Copy from re:Search...

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...

Jason did not understand in real time that he needed to call himself as a witness immediately. That issue consumed approximately fifteen minutes of the limited time available. Petitioner's counsel then repeatedly objected "hearsay" when Jason attempted to read or identify prior prior representations. Jason was unable to overcome those objections in the compressed setting. Asa result: 1. No meaningful exhibit record was admitted. 2. No Rule 1006 summary chart was admitted and tested. 3. No complete production-gap chart was admitted and tested. 4. No sourc...

Jason objects to entry of any order reducing the Associate Judge's Report into an enforceable order before the referring District Judge conducts de novo review. Jason further objects to any proposed order submitted by Petitioner, Petitioner's counsel, or any person acting for Petitioner that: 1. expands the Associate Judge's Report; 2. adds findings not made at the hearing; 3. converts the denial into a trial-readiness finding; 4. grants or preserves Petitioner's protective order; 5. grants or preserves Petitioner's fees, costs, protective expenses, vend...

...Motion for Protective Order in full to the extent it blocks, restricts, burdens, delays, chills, or prevents source-record verification; 8. DENY Petitioner's request for attorney's fees, court costs, protective expenses, expert/vendor expenses, discovery expenses, or any cost shifting against Jason McKemie in full, with no later prove-up, no reserved entitlement, and no cost shifting; 9. ORDER Petitioner, Jonathan Drake Steele, Rebecca L. Armstrong, Sullivan & Cook, and any attorney who certified, sponsored, presented, defended, relied upon, or attempted...

...r Protective Order in full to the extent it blocks, restricts, delays, burdens, chills, or prevents third-party source-record verification; deny Petitioner's request for attorney's fees, court costs, protective expenses, expert/vendor expenses, discovery expenses, or any cost shifting against Jason McKemie in full, with no later prove-up, no reserved entitlement, and no cost shifting; order Petitioner, Jonathan Drake Steele, Rebecca L. Armstrong, Sullivan & Cook, and any attorney who certified, sponsored, presented, defended, relied upon, or attempted to...

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

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

particular hearing. That questioning created an incomplete and misleading record, because the evidence exists; it simply was not noticed, reached, admitted, fully presented at that hearing. 16. | request denial of Petitioner's protective order, denial of all fees, costs, protective expenses, and cost shifting against me, authorization of third-party subpoenas, sworn counsel certification, trial continuance or abatement, healthcare enforcement, stolen-evidence non-access, non-use, preservation, and return relief, and a sanctions/show-cause hearing. 17. Du...

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

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

In the 254th District Court, Respondent served discovery in good faith. Petitioner's legal team then moved to withdraw and remained absent during the discovery period. With approximately one hour Respondent's discovery, and approximately one hour later declared discovery closed. The same pattern repeated in the 302nd District Court. Respondent served discovery. Petitioner responded that Respondent had to identify and label every defect across thousands of pages of production. Respondent did that work. Petitioner then delayed for approximately two months...

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

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

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

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

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...

...ts work product, including material prepared and communications made in anticipation of litigation or for trial by or for a party or a party's representatives, including attorneys, consultants, investigators, agents, and other representatives. Requests for counsel's files, law-firm billing records, litigation consultants, investigators, security vendors, cyber and OSINT vendors, reputation vendors, and witness-preparation materials are presumptively privilege- sensitive and require heightened protection. See National Union Fire Ins. Co. v. Valdez, 863 S....

...any order adjudicating April 16 theft, spoliation, stay violation, turnover, estate-property damages, property ownership, or forensic relief on the present record. VII. Attorney's Fees, Costs, and Protective Expenses Petitioner requests an award of reasonable attorney's fees, court costs, expenses, and protective expenses incurred in responding to the Motion and prosecuting this Counter-Motion for Protective Order under Texas Rule of Civil Procedure 215.3, the Court's discovery and protective-order authority, and applicable Family Code fee provisions, i...

...marriage and any matters expressly excepted from the automatic stay under 11 U.S.C. § 362(b)(2) proceeding on June 11, 2026 as scheduled; 9. award Petitioner reasonable attorney's fees, court costs, expenses, and protective expenses incurred in responding to the Motion and obtaining protective relief, with the amount reserved for later prove-up if necessary; and 10. grant Petitioner all further relief to which she may be justly entitled. Respectfully submitted, Jonathan D. Steele BEERMANN LLP 161 N. Clark Street, Suite 3000 Chicago, Illinois 60601 ARDC...