DF-24-18010 Litigation Record Search

...e and that any remaining retrieval had to occur through a neutral process. II. TIMELINE OF KNOWN APRIL 16, 2026, EVENTS 2:37 p.m. — Applicant left the residence to go to court after identifying defective service and attempting to stop the writ. Applicant closed the garage before leaving. 2:39 p.m. — Petitioner’s security personnel backed into the rear driveway. The garage was opened from inside. 2:39 p.m. — Security cameras began being disabled, including cameras being ripped from walls. Fifteen cameras on one system were disabled before Petitioner arriv...

...she had chosen this path over the relationship. That was not an accident. It was a statement. And it spoke volumes about the psychological distance that had taken hold. TRANSCRIPT [00:00:01] Gwen McKemie: (inaudible) ...(The SSRI’s…)…. was you know obviously impacting our relationship hugely for you know, I don't know if it was a month or whatever. And you know that there are contributors on my side to this because it takes two people to have something get toxic. And I'll just I'll tell you, Jason, that her advice to me that I was just, like, sitting on...

...VATED PERJURY AND FRAUD UPON THE OCURT AGAINST • 07/17/2025 (Entry 88) — 2 pages — EMERGENCY NOTICE OF COUNSEL MISCONDUCT, PRIOR COMMUNICATIONS, AND DEMAND FOR IMMEDIATE COURT ACTION • 07/24/2025 (Entry 91) — 8 pages — RESPONDENT VERIFIED M/RECUSE • 07/24/2025 (Entry 97) — 1 page — RESPONDENT'S EMERGENCY MOTION FOR CONTINUANCE PROPOSED ORDER/JUDGMENT • 07/24/2025 (Entry 96) — 3 pages — ERRONEOUS PUBLIC FILING AND EMERGENCY MOTION TO SEAL PREVIOUSLY SUBMITTED DECLARATION • 07/24/2025 (Entry 97) — 1 page — RESPONDENT'S EMERGENCY MOTION FOR CONTINUANCE PROP...

...es — MOTION TO ABATE TRIAL, ENFORCE DISCOVERY ORDERS AND HEALTHCARE REINSTATEMENT 6. DISCOVERY OBSTRUCTION / COMPEL / SUBPOENA REQUESTS 2025 RESPONDENT’S WARNINGS TO THE COURT, AND REQUESTS FOR RELIEF/STABILIZATION 10 of 14DF-24-18010

...OVERY 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 (Entry 60) — 3 pages — MOTION TO DESIGNATE PRO SE REPRESENTATION AND REQUEST FOR EQUAL ACCESS • 04/24/2025 (Entry 57) — 4 pages — MOTION FOR NOTICE PRIOR TO ANY DISMISSAL NOTICE PRIOR TO ANY DISMISSAL • 0...

...025 (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 REPORTER FOR OCTOBER 31, 2025 HEARING AND ALL SUBSEQUENT PROCEEDINGS REQUEST FOR COURT REPORTER FOR HEARING AND ALL SUBSEQUENT PROCEEDINGS • 10/29/2025 (Entry 121) — 6 pages — MOTION TO OBTAIN CERTIFIED TRANSCRIPT FOR JANUARY 7, 2025, HEARING AND REQUEST FOR PAYMENT FROM • 11/04/2025 (Entry 125) — 8 pages — EMERGENCY OBJECTION TO MOTION TO WITHDRAW AS COUNSEL AND REQUEST FOR EXPEDI...

...cord that Jason acquiesced in decree action while the pending verified recusal remained unresolved or unclear. VII. REQUESTED RELIEF Jason respectfully requests that the Court: denied, granted, or referred; 2. direct the Clerk to deliver the pending verified recusal, this notice, the emergency supplement, and the supplemental exhibit map to the respondent judge and regional presiding judge; 3. withhold rendition, signature, entry, transmission, enforcement, or approval of any final decree until Rule 18a status is clarified; 4. if the Court contends it ma...

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...

...imately $25,000 in property unless estate funds are released. He needs approximately $444 for bodycam footage from the writ and expects the combined writ bodycam/dashcam records to cost approximately $1,000. He has repeatedly requested transcripts and records needed to prove what occurred. Without funds, the record itself is being starved. This is why the stolen-property issue is procedural, not merely economic. Petitioner's theft and destruction of property stripped Jason of evidence, tools, hardware, clothing, computers, records, and the means to defen...

...s, healthcare interference, and witness suppression. Without intervention, this does not end. XIX. THE RECORD HAS BEEN SCREAMING FOR EIGHTEEN MONTHS The issue before the Court is no longer whether the parties disagree. The issue is whether this record can honestly be described as ordinary. This record contains more than 120 pleadings, more than 1,400 pages of filings, repeated requests for a court reporter, repeated requests for transcripts, repeated requests for source records, repeated requests for third-party verification, more than seventy emergency...

...is not a side issue. That is the emergency. XXI. PROPOSED WRITTEN FINDINGS REQUESTED BEFORE ANY DECREE ACTION testimony was taken, or trial evidence was received. 7. The Court has been notified that Jason's trial readiness was materially impaired by stolen hard drives, stolen evidence repositories, stolen trial materials, stolen Apple devices, stolen paper records, stolen work product, stolen or destroyed computers, stolen tools, stolen client hardware, stolen passport/medication-related items, and destruction of property. 8. The Court has been notified...

14.The Court has been notified that Jason objects to any final decree, fee award, sanctions award, enforcement step, or trial ruling entered before written resolution of Recusal No. 3 and this Supplement. XXII. REQUEST FOR ORDER 15.grantrecusal or refer Recusal No. 3 and this Supplement for decision before any decree action; 16. stay rendition, signature, entry, transmission, enforcement, fee awards, sanctions, and decree action pending written recusal resolution; 17.orderimmediatethird-partysourceverification of healthcare, HSA/FSA, OLE, COBRA, plan ele...

...ion, and the facts stated in this Supplement are true and correct based on my personal knowledge, my review of records, filings, police reports, recordings, transcripts, court orders, medical records, benefit records, photographs, location records, financial records, witness communications, and attached evidence. | declare under penalty of perjury that the foregoing is true and correct. Executed in Texas on June 15, 2026. Jason McKemie 539 W. Commerce St., Ste. 2010, Dallas, TX 75208 | 214-868-4901 jmckemie@mckemie.net 15 of 19 Copy from re:SearchTX

1. signed/unsigned decree status; 2. docket entry and re: SearchTX status; 3. admitted exhibit ist; 4. court reporter transcript; 5. no-bridge emails; 6. bodycam/video records; 7. Apple/Find My records; 8. SAPD property-chain records; 9. SAPD reports and bodycam; 10.Dallas police/constable records; 1 healthcare/HSA/FSA records; 12.EBSA/DOL records; 13.sourcefinancial records; 1 Accenture/Businessolver/Aetna/HSA/FSA records; 15.lease-buyout, writ, eviction, mover, U-Haul, payment, vendor, and chain-of-custody records; 16.declarations, exhibits, screenshot...

...., 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 trial evidence begins and to...

...to Recuse; 2. Respondent's Verified Emergency Motion to Abate, Stay, or Continue Trial; 3. Respondent's request for remote appearance; 4. Respondent's request for court reporter; 5. Respondent's request that medical incapacity not be treated as waiver; 6. Respondent's request for healthcare preservation; 7. Respondent's request for de novo/trial-readiness hearing before trial; 8. Respondent's request for protection of stolen hard drives, stolen evidence repositories, stolen legal work product, stolen trial materials, stolen printer, stolen printer ink,...

...testified she would not obstruct healthcare. The healthcare order remains functionally noncomplied with. NO WAIVER OF MANDAMUS, APPEAL, DE NOVO, RECUSAL, DUE PROCESS, OR COURT-REPORTER COMPLAINTS Respondent does not waive mandamus, emergency appellate relief, appeal, de novo complaints, recusal complaints, due-process complaints, trial-readiness complaints, court-reporter complaints, discovery complaints, source-record complaints, healthcare complaints, stolen-evidence complaints, or complaints based on inadequate trial time. Respondent objects to any fi...

...TE, STAY, OR CONTINUE TRIAL; REQUEST FOR REMOTE APPEARANCE; REQUEST FOR DE NOVO TRIAL-READINESS HEARING; REQUEST FOR HEALTHCARE PRESERVATION, TEMPORARY FINANCIAL RELIEF, COURT REPORTER, NON-WAIVER, AND PROTECTION OF STOLEN EVIDENCE TO THE HONORABLE COURT: Respondent, Jason McKemie, files this Verified Emergency Motion before any final trial evidence is taken on June 11,2026. From this point forward, Jason McKemie is referred to as Respondent. This is not a request for delay. It is an emergency request to stop a final trial from being conducted after a ma...

...ergency 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 verbatim record. 6. Preserve healthcare and prevent any final order, trial event, or decree from terminating, impairing, waiving, or rewarding obstruction of Respondent's medical coverage, HSA, FSA, critical illness coverage, life insurance, AD&D...

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...

...tion and that Petitioner was going to file false police reports and a false protective order against him. Respondent asked that the warning be documented in the official record and told law enforcement that if officers were dispatched to his residence, they should be informed that he would not be armed. Respondent then hired counsel. While Respondent was recovering from spinal surgery, counsel reviewed the documentation and advised Respondent that he was in serious danger and needed to transfer enough money to provide survival funds for approximately thr...

...ng in separate civil litigation, but the collapse of two generations is relevant to the severity, foreseeability, and scope of Petitioner's financial sabotage and to the Court's assessment of temporary relief, fee denial, sanctions, trial readiness, and due process. HEALTHCARE OBSTRUCTION, FALSE QLE, SOURCE RECORDS, AND INABILITY TO STABLIZE IF TRIAL CONTINUES Healthcare is not a collateral issue. It is a life-safety issue. Petitioner has obstructed Respondent's access to healthcare since at least December 18, 2024. Respondent has been repeatedly hospita...

...concealed lease buyout with the landlord while she was the financial guarantor on the lease. Respondent left the residence only because of improper service and emergency court proceedings. Respondent would never have voluntarily eft during an eviction without securing his hard drives, medications, paper files, evidence, trial materials, printer, music studio, and personal property. Within minutes of Respondent leaving, Petitioner arrived at the residence despite living approximately five hours away. She had coordinated resources, a moving operation, and...

...r records. DE NOVO AND TRIAL-READINESS ISSUES MUST BE HEARD BEFORE TRIAL Respondent timely requested de novo review and trial-readiness relief. Respondent objects to the Court treating de novo/trial-readiness issues as a brief pretrial argument immediately before a few-hour trial. Respondent requests an actual de novo/trial-readiness hearing before trial evidence begins, including the ability to present testimony and evidence on the specified issues. The specified issues include stolen hard drives, stolen evidence repositories, stolen legal work product,...

...transportation impossibility - not waiver. Respondent preserves mandamus, appeal, de novo, recusal, due-process, discovery, healthcare, source-record, financial-relief, court-reporter, stolen-evidence, and trial-readiness complaints. REQUEST Respondent requests that the Court grant the relief requested above, abate, stay, or continue trial, preserve healthcare, preserve stolen evidence, prohibit Petitioner and her agents from accessing or benefiting from stolen evidence, authorize source-record subpoenas, permit remote appearance, deny all fee shifting...

...are 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 McKemie Page 9 of 9 Copy from re:SearchTX

on the date and to the persons listed below. The rules governing Envelope ID: 116028476 Filing Code Description: Motion - Miscellaneous Filing Description: VERIFIED EMERGENCY MOTION TO ABATE, STAY OR CONTINUE TRIAL Status as of 6/12/2026 8:58 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Rebecca LArmstrong rebecca@armstronglawtexas.com 6/11/2026 1:17:47 PM SENT Terra Aguirre terra@armstronglawtexas.com 6/11/2026 1:17:47 PM SENT Lauren N.Shaw lauren@armstronglawtexas.com 6/11/2026 1:17:47 PM SENT Jason McKemie jmckemie@mckemie.net 6/...

...TE, STAY, OR CONTINUE TRIAL; REQUEST FOR REMOTE APPEARANCE; REQUEST FOR DE NOVO TRIAL-READINESS HEARING; REQUEST FOR HEALTHCARE PRESERVATION, TEMPORARY FINANCIAL RELIEF, COURT REPORTER, NON-WAIVER, AND PROTECTION OF STOLEN EVIDENCE TO THE HONORABLE COURT: Respondent, Jason McKemie, files this Verified Emergency Motion before any final trial evidence is taken on June 11, 2026. From this point forward, Jason McKemie is referred to as Respondent. This is not a request for delay. It is an emergency request to stop a final trial from being conducted after a m...

...ergency 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 verbatim record. 6. Preserve healthcare and prevent any final order, trial event, or decree from terminating, impairing, waiving, or rewarding obstruction of Respondent’s medical coverage, HSA, FSA, critical illness coverage, life insurance, AD&D...

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...

...tion and that Petitioner was going to file false police reports and a false protective order against him. Respondent asked that the warning be documented in the official record and told law enforcement that if officers were dispatched to his residence, they should be informed that he would not be armed. Respondent then hired counsel. While Respondent was recovering from spinal surgery, counsel reviewed the documentation and advised Respondent that he was in serious danger and needed to transfer enough money to provide survival funds for approximately thr...

...ng in separate civil litigation, but the collapse of two generations is relevant to the severity, foreseeability, and scope of Petitioner’s financial sabotage and to the Court’s assessment of temporary relief, fee denial, sanctions, trial readiness, and due process. HEALTHCARE OBSTRUCTION, FALSE QLE, SOURCE RECORDS, AND INABILITY TO STABLIZE IF TRIAL CONTINUES Healthcare is not a collateral issue. It is a life-safety issue. Petitioner has obstructed Respondent’s access to healthcare since at least December 18, 2024. Respondent has been repeatedly hospita...

...concealed lease buyout with the landlord while she was the financial guarantor on the lease. Respondent left the residence only because of improper service and emergency court proceedings. Respondent would never have voluntarily left during an eviction without securing his hard drives, medications, paper files, evidence, trial materials, printer, music studio, and personal property. Within minutes of Respondent leaving, Petitioner arrived at the residence despite living approximately five hours away. She had coordinated resources, a moving operation, and...

...r records. DE NOVO AND TRIAL-READINESS ISSUES MUST BE HEARD BEFORE TRIAL Respondent timely requested de novo review and trial-readiness relief. Respondent objects to the Court treating de novo/trial-readiness issues as a brief pretrial argument immediately before a few-hour trial. Respondent requests an actual de novo/trial-readiness hearing before trial evidence begins, including the ability to present testimony and evidence on the specified issues. The specified issues include stolen hard drives, stolen evidence repositories, stolen legal work product,...

...transportation impossibility - not waiver. Respondent preserves mandamus, appeal, de novo, recusal, due-process, discovery, healthcare, source-record, financial-relief, court-reporter, stolen-evidence, and trial-readiness complaints. REQUEST Respondent requests that the Court grant the relief requested above, abate, stay, or continue trial, preserve healthcare, preserve stolen evidence, prohibit Petitioner and her agents from accessing or benefiting from stolen evidence, authorize source-record subpoenas, permit remote appearance, deny all fee shifting...

...are 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 June 11, 2026. __________________________________ Jason McKemie Page 9 of 9

on the date and to the persons listed below. The rules governing Envelope ID: 116028476 Filing Code Description: Motion - Miscellaneous Filing Description: VERIFIED EMERGENCY MOTION TO ABATE, STAY OR CONTINUE TRIAL Status as of 6/12/2026 8:58 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Rebecca LArmstrong rebecca@armstronglawtexas.com 6/11/2026 1:17:47 PM SENT Terra Aguirre terra@armstronglawtexas.com 6/11/2026 1:17:47 PM SENT Lauren N.Shaw lauren@armstronglawtexas.com 6/11/2026 1:17:47 PM SENT Jason McKemie jmckemie@mckemie.net 6/...

...E NOVO HEARING; OBJECTIONS TO ASSOCIATE JUDGE'S REPORT; REQUEST TO STAY ENTRY AND EFFECT OF REPORT PENDING DE NOVO REVIEW; REQUEST FOR EMERGENCY SETTING BEFORE REFERRING COURT; AND REQUEST FOR ADEQUATE EVIDENTIARY TIME, COURT REPORTER, EXHIBIT ADMISSION, WITNESS TESTIMONY, AND WRITTEN RULINGS TO THE HONORABLE JUDGE OF SAID COURT: Respondent, Jason McKemie, files this Request for De Novo Hearing under Texas Family Code § 201.015 and objects to the Associate Judge's June 1, 2026, Report. This request is timely. The hearing occurred on June 1,2026. Jason re...

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

...ief concerning Jason McKemie's stolen hard drives, evidence repositories, source files, litigation materials, and derivative materials. 14.The denial or failure to order preservation of all external chain-of-custody evidence concerning the April 16 theft, including communications, photographs, videos, inventories, booking records, dispatch records, payment records, location records, storage records, possession records, vendor records, mover records, security records, landlord records, constable-related records, and records identifying where Jason's stole...

...ated ground. Ill. WHY DE NOVO REVIEW IS REQUIRED a fair merits record. The June 1 hearing did not produce Jason was delayed by an accident/travel emergency on the way to court and appeared under compressed conditions. The hearing time was then cut short. Jason was given only a severely limited opportunity to present issues that involve seventeen months of financial concealment, discovery obstruction, source-record nonproduction, healthcare interference, stolen evidence repositories, missing trial materials, third-party subpoena necessity, sanctions, and...

...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 source-record deficiency chart was admitted and tested. 5. No witness testimony was fully developed. 6. No complete offer of proof was made. 7. No merits adjudication occurred on the actual source-record issues. 8. No merits adjudication occurred...

...and written rulings; 13.testimony and records concerning trial-readiness collapse; 14.anyotherevidence necessary to determine the specified issues. Jason also requests a court reporter, an official verbatim record for the de novo hearing and all related proceedings. V. NO ORDER SHOULD BE ENTERED ON THE ASSOCIATE JUDGE'S REPORT BEFORE DE NOVO REVIEW DF-24-18010 Request for De Novo Hearing on Respondent's: Motion for Enforcement, Sanctions, Continuance, and Leave to Issue Third-Party Subpoenas! Copy from re:SearchTX

...ve order; 5. grants or preserves Petitioner's fees, costs, protective expenses, vendor expenses, expert expenses, or cost-shifting requests; 6. blocks third-party source-record verification; 7. restricts Jason's ability to obtain financial source records; 8. restricts Jason's ability to obtain QLE/benefits/HSA/FSA/healthcare source records; 9. restricts Jason's ability to obtain April 16 chain-of-custody records; 10. allows Petitioner, counsel, experts, vendors, contractors, agents, or anyone acting for her to access, use, inspect, image, copy, review, d...

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

...tive 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 to shield Petiti...

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

...rce-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-protection, healthcare- enforcement, source-record verification, or trial-readiness issue was not reached by the Associate Judge's Report, Jason requests that the Court set those issues for a separate emergency evidentiary hearing before the June 11,2026 trial setting. Jason does not waive those issues by requesting de n...

...ibits, hear witness testimony, decide the specified issues on the merits, and enter written rulings. 14. | was also unable to present critical evidence necessary for the Court to evaluate due process, trial readiness, source-record verification, stolen evidence, healthcare enforcement, and the prejudice created by forcing this case toward trial without complete records. 15. Opposing counsel repeatedly demanded "yes or no" answers to questions asking whether | had presented evidence about events or issues not noticed for that DF-24-18010 Request for De No...

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...

...nces, 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 Exhibit 6 Petitioner's Response to Respondent's Motion for Enforcement, Sanctions, Continuance, And Lea...

...ipping and tracing obstacles. Annual Snapshots Without Inflows or Illustrates production of summary balances without underlying Exhibit L Outflows transactional support. Court findings, procedural histery, and prior discovery-related Exhibit M Associate Judge's Report determinations. Gwen Financial Discovery Compliance Visual compliance chart showing discovery requests, deficiencies, Exhibit N Matnx missing records, and production failures. Analysis of excessive card overpayments, missing statement periods, Exhibit J Overpayments / Missing Statements and...

...TEXAS NO DF-24-1801 re) THE MARRIAGE OF § § AND § MOTION FOR ENFORCEMENT, SANCTIONS, CONTINUANCE, AND LEAVE TO ISSUE THIRD-PARTY SUBPOENAS TO THE HONORABLE JUDGE OF SAID COURT: Jason McKemie files this Motion for Enforcement, Sanctions, Continuance, and Leave to Issue Third-Party Subpoenas and respectfully shows the Court as follows: I. RELIEF REQUESTED Trial is set for June 1 1, 2026. This motion requests multiple forms of relief, but the threshold issue for the June 1 hearing is trial readiness: No source records, no estate reconstruction. No estate re...

Il. PROCEDURAL AUTHORITY Texas Rule of Civil Procedure 190.5 authorizes the Court to modify a discovery-control plan at any time and requires modification when the interest of justice requires. This rule is directly implicated because new and materially changed circumstances now prevent trial readiness without third-party source records. Texas Rules of Civil Procedure 1 176 and 205.3 authorize third-party subpoenas and nonparty production of documents and tangible things. Texas Rules of Civil Procedure 215.2 and 215.3 authorize sanctions, fee shifting, a...

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...

...but different monthly headers. a remedy. A further deadline for Petitioner to self-produce is not It is procedural cover. V. PARTY PRODUCTION IS IMPOSSIBLE AS A CURE The Court should not give Petitioner more time to produce financials. That remedy is impossible. It cannot cure the defect. No additional party-controlled production deadline can reconstruct: 1. Account continuity; 2. Replacement-card lineage; 3. Payment-source tracing; 4. Overpayment treatment; 5. Refund and credit history; DF-24-18010 Motion for Enforcement, Sanctions, Continuance, & Leave...

...holding versus equity contribution classification; 10. IRS/tax payments; 11. Loan origination and funding; 12. San Antonio housing reimbursement; 13. Lease payoff/buyout records; 14. Legal retainer payment sources; 15.Third-partycontractorpaymentsources; or 16.April 16 theft chain of custody. Only third-party source records can do that. If Petitioner has been fully forthcoming and compliant with discovery, then this will be a simple and painless process. The source records will confirm her position quickly. If she has not, the source records are the only...

...tement continuity and production gaps. The exhibit should be treated as: - Exhibit A Rule 006 Summary Chart of Financial Production Gaps The chart is offered to show the Court the structural record problem: no account has contiguous source-record coverage from August 2023 through present. Movant will make the underlying statements, productions, and available records supporting the summary available for inspection as required by Texas Rule of Evidence 1006. The chart is not a substitute for source records. It proves why source records are necessary. Vill....

...nnot be verified; 8. Employer reimbursements cannot be traced; 9. Legal and contractor spending cannot be allocated; and 10.The estate cannot be reconstructed. No source records, no estate reconstruction. No estate reconstruction, no final trial. IX. SAN ANTONIO HOUSING / RENT / EXPENSE REPORTS Petitioner's San Antonio housing records require third-party verification. Movant requests subpoenas to Accenture, benefits/payroll custodians, expense-report custodians, the landlord, property manager, landlord-side bank/payment custodians, and related entities t...

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...

...community funds were used, and that third-party contractors used against Movant be added back 100% to Petitioner's side of the estate unless Petitioner proves by source records that the expenditure was disclosed, necessary, non-wasteful, and beneficial to the community. C. San Antonio Rent / Employer-Paid Housing e If San Antonio rent was work-paid or reimbursed by Accenture, those funds must be traced and reimbursed 100% to the estate or offset against Petitioner. D. Loans Petitioner paid off 100% of her loans before leaving the marriage, then took out...

...ient to verify tax claims, tax liabilities, tax payments, withholding, refunds, or the alleged tax treatment of VEIP/equity. e Emails and printouts are not enough. e The Court should authorize subpoenas for IRS transcripts, tax preparer records, employer payroll/tax records, bank-origin tax payments, and records sufficient to determine whether tax claims were legitimate or used to obscure equity investments and estate value. F. Gross Overpayments to Cards e Credit-card overpayments must be traced to determine whether they created refunds, credits, hidden...

...0,000 Additional dissipation / add-backs to be traced TBD Movant also asserts that approximately $650,000 went missing before the divorce proceedings and requires source-record reconstruction. These figures are not the full estate calculation. They are minimum categories proving why the estate cannot be tried without third-party records. Xil. APRIL 16 THEFT IS PART OF THE SAME PATTERN The April 16 writ event is more of the same pattern. Petitioner repeatedly requested access to the residence. Those requests were not granted in the manner she sought. Mova...

...steal the evidence, obstruct third- party records, and then demand trial before the theft can be addressed. XIII. THE APRIL 1 16 THIRD-PARTY SUBPOENAS ARE NECESSARY The Court should authorize subpoenas to all third parties involved in the April 16 theft, including: 1. All My Sons; 2. Merritt McClayton; 3. Moving-company booking entities; 4. Third-party payers; 5. Security contractors; 6. Bodyguards; 7. Storage providers; 8. Landlord; 9. Property manager; 10. Landlord-side agents; 11. Locksmith/access vendors; 12. Constable-related custodians; DF-24-1801...

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

...ruction, 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, and repeated emergency conditions. Parent-loan issues will be addressed in a separate filing, but the Court should recognize that this litigation posture has imposed collateral financial harm beyond or...

XVII. REQUEST TO SEQUENCE THE JUNE 1 HEARING Movant urgently needs healthcare enforcement. However, Movant requests that the Court first address financial trial readiness because trial is set for June 11. The June 1 hearing should first decide: 1. Whether trial can proceed without third-party source records; N Whether subpoenas should issue; Whether discovery deadlines should be modified; Whether trial should be continued; and a Whether sanctions and healthcare enforcement should be reserved or set for immediate follow-up. Movant does not waive healthcar...

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

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

on the date and to the persons listed below. The rules governing Envelope ID: 115362137 Filing Code Description: Motion - Mod/Enf Other (Sapcr) (Oca Pja) Filing Description: MOTION FOR ENFORCEMENT, SANCTIONS, CONTINUANCE, AND LEAVE TO ISSUE THIRD-PARTY SUBPOENAS Status as of 5/28/2026 11:47 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Kim Jones kjones@sullivancook.com 5/26/2026 11:59:10 PM SENT Tiffany Castenada tcastenada@sullivancook.com 5/26/2026 11:59:10 PM SENT William CCook wcook@sullivancook.com 5/26/2026 11:59:10 PM SENT Re...

...SANCTIONS, CONTINUANCE, AND LEAVE TO ISSUE THIRD-PARTY SUBPOENAS, AND COUNTER-MOTION FOR PROTECTIVE ORDER AND FOR OTHER APPROPRIATE RELIEF TO THE HONORABLE JUDGE OF SAID COURT: Petitioner Gwendolyn Ulijasz-McKemie ("Petitioner" or "Gwen") files this Response to Respondent Jason McKemie's May 26, 2026 Motion for Enforcement, Sanctions, Continuance, and Leave to Issue Third-Party Subpoenas (the "Motion") and this Counter-Motion for Protective Order, and respectfully shows the Court as follows: I. Preliminary Statement Discovery in this case is closed. Resp...

...rensic relief, or bankruptcy-related property remedies. The discovery period has run. This five-month marriage has consumed eighteen months of litigation across multiple courts. It is time to try the case on June 11 on the record the parties developed during the discovery period, and the Motion should be denied. Petitioner does not oppose mutual preservation of relevant records. She opposes the continuance. She opposes blanket subpoena leave. She opposes any order that would authorize new nonparty discovery on the eve of trial, because any such discovery...

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

...on or about June 22, 2024. The parties separated within 18, 2024. This case has now been pending for roughly eighteen months and has moved through multiple settings and courts. It is set for final trial on June 11, 2026. A marriage of roughly five months has generated roughly eighteen months of litigation. The discovery period has run its course. Rather than try the case on the developed record, Respondent's May 26 Motion seeks to reopen discovery and reset the trial so he can begin a new third-party investigation, without proposed subpoenas, without cu...

...dent expressly seeks reservation Deny present relief reconstitution pending subpoena returns and further hearing; without prejudice. predicate evidence is not before the Court. Bankruptcy / April 16/ Chapter 7 is pending; trustee is Areya Holder; No family-court findings property-return the bankruptcy orders attached as exhibits on stay violation, theft, reserve rent, expense, damage, and stay- spoliation, estate-property violation issues; estate-property rights are not damages, turnover, or before this Court for adjudication on June 1. property return n...