All topics
Discovery Violations
#199
2026-02-20
Respondent / Jason
Notice Of Filing
Page 1
PLEADING_START_FILE_MARKED
EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL_109EBB73.pdf
...prevent trial on a record that remains legally stayed (bankruptcy posture), procedurally unenforceable (missing written enforcement orders), and factually unverifiable (discovery collapse and ongoing benefits noncompliance). Movant is not asking the Court to accept conclusions on faith. Movant is asking the Court to find out-through written rulings, enforceable deadlines, and limited third-party records-what cannot be reliably established through party-only production. I. THE PRIMARY STOP BUTTON: BANKRUPTCY POSTURE REQUIRES ABATEMENT OF PROPERTY ADJUDIC...
#199
2026-02-20
Respondent / Jason
Notice Of Filing
Page 2
PROPOSED_ORDER_OR_ORDER
EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL_109EBB73.pdf
...4 trial setting and enter trial- readiness orders before any final adjudication affecting the marital estate proceeds. Il. SECOND STOP BUTTON: TRIAL IS NOT READY BECAUSE DISCOVERY NONCOMPLIANCE WAS CONFIRMED INSIDE THE FINAL PRETRIAL WINDOW The procedural posture alone establishes the case is not trial-ready: January 6, 2026: Motion to Compel discovery and HSA-related requests heard. January 9, 2026: Court-ordered production deadline. January 20, 2026: Status hearing to assess compliance. February 5, 2026: Compliance hearing held inside the final pretria...
#199
2026-02-20
Respondent / Jason
Notice Of Filing
Page 3
PLEADING_BODY
EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL_109EBB73.pdf
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...
#199
2026-02-20
Respondent / Jason
Notice Of Filing
Page 4
PLEADING_BODY
EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL_109EBB73.pdf
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...
#199
2026-02-20
Respondent / Jason
Notice Of Filing
Page 5
PROPOSED_ORDER_OR_ORDER
EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL_109EBB73.pdf
...estic Partner Life AD&D e Dependent Child Life/AD&D The same summary reflects HSA/FSA enrollment categories, but the continuing dispute concerns functional access and restoration/funding as ordered, not mere enrollment labels. Relief requested: An immediate enforcement hearing and a cure-steps order that requires verification by plan administrator/benefits vendors (not voluntary compliance alone) and includes replacement/escrow mechanisms sufficient to prevent continued harm. VI. TRANSCRIPT / RECORD DEFECT JANUARY 7 TRANSCRIPT IS NECESSARY FOR TRIAL PREP...
#199
2026-02-20
Respondent / Jason
Notice Of Filing
Page 6
DECLARATION
EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL_109EBB73.pdf
...proposed order). e Exhibit I: Motion to Establish Conditions for Re-Entry of Counsel and Preserve Fair Trial. e Exhibit J: Notice of Repeated Notice of Impossibility of Discovery Compliance via Statements (and deficiency demonstratives). e Exhibit K: Unified Proposed Order drafted at the Associate Judge's direction following the February 5 compliance hearing (pending). Copy from re:SearchTX
#199
2026-02-20
Respondent / Jason
Notice Of Filing
Page 7
CERTIFICATE_OF_SERVICE
EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL_109EBB73.pdf
record and/or parties entitled to notice in accordance with the Texas Rules of Civil Procedure and : Jas6o-McKemie Copy from re:SearchTX
#199
2026-02-20
Respondent / Jason
Notice Of Filing
Page 8
FILING_STAMP_OR_ESERVICE
EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL_109EBB73.pdf
on the date and to the persons listed below. The rules governing Envelope ID: 111545338 Filing Code Description: Notice Of Filing Filing Description: EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL Status as of 2/23/2026 2:22 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 Copy from re:SearchTX
#185
2026-01-26
Respondent / Jason
Notice Of Filing
Page 1
PLEADING_START_FILE_MARKED
NOTICE OF PRESERVATION OF WITNESSES, & LARGE DISCOVERY PRODUCTION IN FINAL HOUR_43CEE77A.pdf
...6 12:00 AM DALLAS CO., TEXAS DF-24-18010 RULES OF CIVIL PROCEDURE AND NO. COURTS INHERENT AUTHORITY MARRIAGE OF § § § NOTICE OF PRESERVATION OF WITNESSES, NOTICE OF LATE DISCOVERY AND FOR CONTINUANCE PRODUCTION, REQUEST FOR FINANCIAL AND MEDICAL STABILIZATION NOTICE IS HEREBY GIVEN: Respondent files this Notice for the limited purposes of (1) preserving Respondent's ability to call identified witnesses; (2) notifying the Court of substantial discovery production occurring on the eve of exhibit deadlines; and (3) requesting a continuance consistent with t...
#185
2026-01-26
Respondent / Jason
Notice Of Filing
Page 2
PLEADING_BODY
NOTICE OF PRESERVATION OF WITNESSES, & LARGE DISCOVERY PRODUCTION IN FINAL HOUR_43CEE77A.pdf
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...
#185
2026-01-26
Respondent / Jason
Notice Of Filing
Page 3
PLEADING_BODY
NOTICE OF PRESERVATION OF WITNESSES, & LARGE DISCOVERY PRODUCTION IN FINAL HOUR_43CEE77A.pdf
...nuary 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 payments. IV. REQUEST FOR CONTINUANCE CONSISTENT WITH PRIOR COURT STATEMENTS At the prior pre-trial hearing, the Court indicated that Respondent would be afforded reasonable time approximately 90 days to prepare for trial once certified financial discovery is complete. Given: e the timi...
#185
2026-01-26
Respondent / Jason
Notice Of Filing
Page 4
PLEADING_BODY
NOTICE OF PRESERVATION OF WITNESSES, & LARGE DISCOVERY PRODUCTION IN FINAL HOUR_43CEE77A.pdf
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
#185
2026-01-26
Respondent / Jason
Notice Of Filing
Page 5
FILING_STAMP_OR_ESERVICE
NOTICE OF PRESERVATION OF WITNESSES, & LARGE DISCOVERY PRODUCTION IN FINAL HOUR_43CEE77A.pdf
...rsons listed below. The rules governing Envelope ID: 110445905 Filing Code Description: Notice Of Filing Filing Description: NOTICE OF PRESERVATION OF WITNESSES, & LARGE DISCOVERY PRODUCTION IN FINAL HOUR Status as of 1/26/2026 12:52 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 1/25/2026 12:00:44 AM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 1/25/2026 12:00:44 AM SENT Copy from re:SearchTX
#183
2026-01-20
Respondent / Jason
Notice Of Filing
Page 1
PLEADING_START_FILE_MARKED
NOTICE OF PRIOR STANDING REQUEST FOR COURT REPORTER_VERBATIM RECORD_BA50ADB4.pdf
...OURT REPORTER / VERBATIM RECORD FOR HEARINGS ON TUES, JAN 20TH & THURS, JAN 22ND (Both @ 9AM) NOTICE IS HEREBY GIVEN: Respondent files this notice as a courtesy reminder to the Court and all parties of Respondent's existing standing request for a court reporter and verbatim record of proceedings, and to confirm that request applies to the upcoming hearings set for January 20, 2026 at 9:00 a.m. (Central) and January 22, 2026 at 9:00 a.m. (Central). Request for Court Reporter for October 31, 2025 Hearing and All Subsequent 2.. That standing request remains...
#183
2026-01-20
Respondent / Jason
Notice Of Filing
Page 2
CERTIFICATE_OF_SERVICE
NOTICE OF PRIOR STANDING REQUEST FOR COURT REPORTER_VERBATIM RECORD_BA50ADB4.pdf
..., 2026, as well as all subsequent proceedings unless the standing request is expressly withdrawn. This notice is provided as a courtesy reminder only and is not intended to modify, expand, or waive any prior request, objection, or right. Respectfully submitted, Jason McKemie Defendant, Pro Se 539 W. Commerce St., Ste. 2010 Dallas, Texas 75208 (214) 868-4901 jmckemie@mckemie.net record, and provided to the Court on January 15, 2026, by electronic filing & email. e JASON MCKEMIE NOTICE OF STANDING REQUIREMENT FOR COURT REPORTER / VERBATIM RECORD OF ALL PRO...
#183
2026-01-20
Respondent / Jason
Notice Of Filing
Page 3
FILING_STAMP_OR_ESERVICE
NOTICE OF PRIOR STANDING REQUEST FOR COURT REPORTER_VERBATIM RECORD_BA50ADB4.pdf
on the date and to the persons listed below. The rules governing Envelope ID: 110187858 Filing Code Description: Notice Of Filing Filing Description: NOTICE OF PRIOR STANDING REQUEST FOR COURT REPORTER/VERBATIM RECORD Status as of 1/22/2026 10:40 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 1/18/2026 7:55:53 AM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 1/18/2026 7:55:53 AM SENT Copy from re:SearchTX
#181
2026-01-15
Respondent / Jason
Notice Of Hearing / Fiat
Page 1
PLEADING_START_FILE_MARKED
NOTICE OF HEARING_2B270165.pdf
...d 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) Enforce Healthcare Reinstatement Through Accenture QLE Records Purpose: Emergency enforcement of existing discovery and healthcare orders; request for authorization to issue third-party subpoenas; notice of automatic stay arising from bankruptcy filing; and request for abatement for federal bankruptcy trustee finding...
#181
2026-01-15
Respondent / Jason
Notice Of Hearing / Fiat
Page 2
PLEADING_BODY
NOTICE OF HEARING_2B270165.pdf
...e 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) submiss...
#181
2026-01-15
Respondent / Jason
Notice Of Hearing / Fiat
Page 3
CERTIFICATE_OF_SERVICE
NOTICE OF HEARING_2B270165.pdf
...ks 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 MCKEMIE CA CON...
#181
2026-01-15
Respondent / Jason
Notice Of Hearing / Fiat
Page 4
FILING_STAMP_OR_ESERVICE
NOTICE OF HEARING_2B270165.pdf
on the date and to the persons listed below. The rules governing Envelope ID: 110118349 Filing Code Description: Notice Of Hearing / Fiat Filing Description: NOTICE OF HEARING (CONSOLIDATED) Status as of 1/21/2026 9:58 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 1/15/2026 5:27:57 PM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 1/15/2026 5:27:57 PM SENT Copy from re:SearchTX
#182
2026-01-15
Respondent / Jason
Motion - Miscellaneous
Page 1
PLEADING_START_FILE_MARKED
MOTION ESTABLISH CONDITIONS FOR RE-ENTRY OF COUNSEL_9FE87EA3.pdf
...ective, neutral conditions that will apply only upon any future re-entry of counsel for Petitioner. This relief is sought to preserve procedural fairness, ensure orderly discovery, and protect the Court's docket from disruption caused by withdrawal and re-entry of counsel around discovery and pretrial deadlines. This Motion does not limit Petitioner's right to counsel. It regulates only the procedural consequences of re-entry to prevent prejudice and ensure a fair trial. Il. FACTUAL BASIS (BRIEF) 1. In this case and in a prior district, Petitioner's coun...
#182
2026-01-15
Respondent / Jason
Motion - Miscellaneous
Page 2
EXHIBIT_START
MOTION ESTABLISH CONDITIONS FOR RE-ENTRY OF COUNSEL_9FE87EA3.pdf
...A. Disclosure & Certification (Automatic) Upon any re-entry of counsel for Petitioner, re-entering counsel shall, within 10 days, certify receipt and review of the full discovery record, all prior orders, and all pending discovery obligations. B. Automatic Continuance (Parity & Preparation) Upon re-entry, all trial and exhibit deadlines shall be automatically continued for 45-60 days (as the Court deems appropriate) to allow: 1. completion and cure of outstanding discovery; 2 supplementation necessitated by prior deficiencies; and 3. orderly trial prepa...
#182
2026-01-15
Respondent / Jason
Motion - Miscellaneous
Page 3
CERTIFICATE_OF_SERVICE
MOTION ESTABLISH CONDITIONS FOR RE-ENTRY OF COUNSEL_9FE87EA3.pdf
...ion Against Strategic Withdrawal After re-entry, any subsequent withdrawal of Petitioner's counsel shall require leave of Court upon a showing of good cause unrelated to discovery or pretrial deadlines. The Court reserves sanctions for any violation of these conditions or renewed withdrawal/re-entry tied to discovery avoidance. V. PRAYER Respondent respectfully requests that the Court grant this Motion and sign the proposed order establishing conditions upon any re-entry of counsel for Petitioner. Respectfully submitted, Jason McKemie Defendant, Pro Se 5...
#182
2026-01-15
Respondent / Jason
Motion - Miscellaneous
Page 4
FILING_STAMP_OR_ESERVICE
MOTION ESTABLISH CONDITIONS FOR RE-ENTRY OF COUNSEL_9FE87EA3.pdf
on the date and to the persons listed below. The rules governing Envelope ID: 110111023 Filing Code Description: Motion - Miscellaneous Filing Description: RESPONDENT'S MOTION TO ESTABLISH CONDITIONS FOR RE-ENTRY OF COUNSEL AND TO PRESERVE FAIR TRIAL PROCEDURES Status as of 1/20/2026 9:16 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 1/15/2026 4:00:53 PM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 1/15/2026 4:00:53 PM SENT Copy from re:SearchTX
#180
2026-01-14
Respondent / Jason
Motion - Miscellaneous
Page 1
PLEADING_START_FILE_MARKED
MOTION TO ABATE TRIAL, ENFORCE DISCOVERY ORDERS AND HEALTHCARE REINSTATEMENT_08FF3A8E.pdf
...NT CONTAINS DF-24-18010 NO. SENSITIVE INFORMATION. MARRIAGE OF § § & § 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) ENFORCE HEALTHCARE REINSTATEMENT THROUGH ACCENTURE QLE RECORDS I. INTRODUCTION AND EMERGENCY NATURE Respondent files this Emergency Motion seeking immediate, limited, and necessary relief to prevent irreparable medical harm, procedural collapse, and fundamental unfairness in these proceedings. This Motion does not se...
#180
2026-01-14
Respondent / Jason
Motion - Miscellaneous
Page 2
PLEADING_BODY
MOTION TO ABATE TRIAL, ENFORCE DISCOVERY ORDERS AND HEALTHCARE REINSTATEMENT_08FF3A8E.pdf
...mpliance Not Substantiated o Although Petitioner has claimed "compliance," she has not demonstrated: « Full funding of HSA/FSA as required; ABATEMENT, ENFORCEMENT COMPEL DISCOVERY/REINSTATE HEALTHCARE/RESTORE STATUS QUO DF-24-18010 2 of 10 Copy from re:SearchTX
#180
2026-01-14
Respondent / Jason
Motion - Miscellaneous
Page 3
PLEADING_BODY
MOTION TO ABATE TRIAL, ENFORCE DISCOVERY ORDERS AND HEALTHCARE REINSTATEMENT_08FF3A8E.pdf
* 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...
#180
2026-01-14
Respondent / Jason
Motion - Miscellaneous
Page 4
PLEADING_BODY
MOTION TO ABATE TRIAL, ENFORCE DISCOVERY ORDERS AND HEALTHCARE REINSTATEMENT_08FF3A8E.pdf
...ing, e dissipation, e and financial reconstruction. Proceeding to trial before completion of trustee findings risks inconsistent rulings, prejudice, and inefficiency. D. Discovery Incompleteness No fair trial may proceed without a complete and accurate financial record. That record does not presently exist and cannot exist absent enforcement and third-party discovery. Requested Relief (Issue One): An Order abating trial settings, exhibit deadlines, and bench trial until: 1. Respondent is medically stabilized; 2. Bankruptcy trustee review is complete; and...
#180
2026-01-14
Respondent / Jason
Motion - Miscellaneous
Page 5
PLEADING_BODY
MOTION TO ABATE TRIAL, ENFORCE DISCOVERY ORDERS AND HEALTHCARE REINSTATEMENT_08FF3A8E.pdf
...hat obscures continuity. Accordingly: Even if Petitioner were to produce every statement in her possession, such production would still not comply with the Court's prior discovery order because the financial record has been rendered non- reconstructable without third-party source data and an account-level production map. C. Necessity of Third-Party Discovery This is not a sanction request. It is a necessity finding. Requested Relief (Issue Two): 1. A finding that Petitioner has not complied with the Motion to Compel; 2. An order requiring production of t...
#180
2026-01-14
Respondent / Jason
Motion - Miscellaneous
Page 6
PROPOSED_ORDER_OR_ORDER
MOTION TO ABATE TRIAL, ENFORCE DISCOVERY ORDERS AND HEALTHCARE REINSTATEMENT_08FF3A8E.pdf
...d for de novo review, but production not stayed. VI. PRESERVATION OF RIGHTS AND DE NOVO REVIEW Respondent expressly preserves all rights to seek: e sanctions, e expanded discovery, e fee shifting, e and additional relief upon de novo review. This Motion seeks only emergency stabilization and enforcement. VII. PRAYER Respondent respectfully requests that the Court grant the relief set forth above and sign the attached proposed orders. Respectfully submitted, ABATEMENT, ENFORCEMENT COMPEL DISCOVERY/REINSTATE HEALTHCARE/RESTORE STATUS QUO DF-24-18010 6 of 1...
#180
2026-01-14
Respondent / Jason
Motion - Miscellaneous
Page 7
CERTIFICATE_OF_SERVICE
MOTION TO ABATE TRIAL, ENFORCE DISCOVERY ORDERS AND HEALTHCARE REINSTATEMENT_08FF3A8E.pdf
...8 (214) 868-4901 jmckemie@mckemie.net record, and provided to the Court on January 12, 2026, by electronic filing & email. 06 JASON MCKEMIE ABATEMENT, ENFORCEMENT COMPEL DISCOVERY/REINSTATE HEALTHCARE/RESTORE STATUS QUO DF-24-18010 7 of 10 Copy from re:SearchTX
#180
2026-01-14
Respondent / Jason
Motion - Miscellaneous
Page 8
PLEADING_BODY
MOTION TO ABATE TRIAL, ENFORCE DISCOVERY ORDERS AND HEALTHCARE REINSTATEMENT_08FF3A8E.pdf
AdvanceER 24 HourEmergency Center Mckemie, Jason 44953-4 4/8/1976 49 yr M 1/14/2026 Kutsen, Michael To Whom It May Concern (or) To the 302nd District Court: | evaluated Jason McKemie in the Emergency Department on January 14th, 2026. He has a known history of congestive heart failure (CHF). During this evaluation, it was determined that Mr. McKemie has been unable to access essential heart-failure medications, including tirzepatide, Carvedilol, Lisinopril, Furosemide, and Potassium supplementation, due to lack of access to his insurance/HSA. In my medica...
#180
2026-01-14
Respondent / Jason
Motion - Miscellaneous
Page 9
PLEADING_BODY
MOTION TO ABATE TRIAL, ENFORCE DISCOVERY ORDERS AND HEALTHCARE REINSTATEMENT_08FF3A8E.pdf
L BaylorScott&White HEALTHTEXAS PROVIDER NETWORK November 26, 2025 BAYLOR SCOTT & WHITE MEDPROVIDER 3417 GASTON AVE SUITE 1100 DALLAS TX 75246 Phone: 469-800-9000 Jason Emory McKemle Fax: 469-800-9010 539 W Commerce St Pmb 2010 Dallas TX 75208 To whom it may concern, | am the primary care provider for Jason McKemie. Mr. McKemie has a history of congestive heart failure and cardiomyopathy. It is medically necessary that he maintain uninterrupted access to his prescribed medications to manage these conditions and to reduce the risk of exacerbation or other...
#180
2026-01-14
Respondent / Jason
Motion - Miscellaneous
Page 10
PLEADING_BODY
MOTION TO ABATE TRIAL, ENFORCE DISCOVERY ORDERS AND HEALTHCARE REINSTATEMENT_08FF3A8E.pdf
L BaylorScott&White HEALTHTEXAS PROVIDER NETWORK September 18, 2025 BAYLOR SCOTT & WHITE MEDPROVIDER 3417 GASTON AVE SUITE 1100 DALLAS TX 75246 Jason Emory McKemle Phone: 469-800-9000 539 W Commerce St Pmb 2010 Fax: 469-800-9010 Dallas TX 75208 To whom it may concern, { am the primary care provider for Jason McKemie. Mr. McKemie has a history of congestive heart failure and cardiomyopathy. It is medically necessary that he remain uninterrupted on his prescription medications to manage his medical conditions and reduce the risk of future complications or...
#180
2026-01-14
Respondent / Jason
Motion - Miscellaneous
Page 11
FILING_STAMP_OR_ESERVICE
MOTION TO ABATE TRIAL, ENFORCE DISCOVERY ORDERS AND HEALTHCARE REINSTATEMENT_08FF3A8E.pdf
on the date and to the persons listed below. The rules governing Envelope ID: 110069888 Filing Code Description: Motion - Miscellaneous Filing Description: Status as of 1/22/2026 8:14 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 1/14/2026 11:40:30 PM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 1/14/2026 11:40:30 PM SENT Copy from re:SearchTX
#173
2026-01-12
Respondent / Jason
Motion - Miscellaneous IN
Page 1
PLEADING_START_FILE_MARKED
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
1/12/2026 2:22 AM DALLAS CO., TEXAS NOTICE: DOCUMENT CONTAINS DF-24-18010 NO. SENSITIVE INFORMATION. MARRIAGE OF § § & § EMERGENCY MOTION TO TEMPORARILY STAY OR, IN THE ALTERNATIVE, IMPOSE PROTECTIVE CONDITIONS ON COURT- AUTHORIZED PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY TO THE HONORABLE JUDGE OF SAID COURT: Jason McKemie respectfully moves for emergency relief to prevent irreparable and irreversible harm arising from a scheduled property retrieval or "clean-out" on January 17th, 2026, while Mr. McKemie is medically incapacitated and anticipating in...
#173
2026-01-12
Respondent / Jason
Motion - Miscellaneous IN
Page 2
PLEADING_BODY
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
...ifying each specific item sought, limited strictly to personal effects. Only items on the list may be removed. 5. DEFINED SCOPE; EXCLUDED CATEGORIES AND AREAS. EMERGENCY MOTION TO TEMPORARILY STAY 2of5 DF-24-18010 Copy from re:SearchTX
#173
2026-01-12
Respondent / Jason
Motion - Miscellaneous IN
Page 3
PLEADING_BODY
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
.... NO ALTERATION TO SECURITY FOOTAGE PROTOCOL UTILIZED DURING THE MARRIAGE The residence is equipped with security cameras that automatically record upon the detection of motion and/or sound. These cameras operated in this manner throughout the marriage and were installed specifically in response to Petitioner's representations that her ex-husband posed a safety risk. No changes have ever been made to the system's configuration, scope, or operation during the marriage. The system remains in the same status quo condition today. Accordingly, there has been...
#173
2026-01-12
Respondent / Jason
Motion - Miscellaneous IN
Page 4
PLEADING_BODY
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
...al hospitalization further unrestricted access creates an unreasonable risk of irreparable harm and necessitates court- imposed structure, supervision, and finality. 14. DISCOVERY OF UNDISCLOSED TRACKING OR MONITORING DEVICES. Following prior court-authorized access periods, Respondent later discovered undisclosed tracking or monitoring devices within the residence. Regardless of intent, the presence of undisclosed devices materially heightens concerns regarding personal safety, privacy, and evidentiary integrity and demonstrates the risks inherent in un...
#173
2026-01-12
Respondent / Jason
Motion - Miscellaneous IN
Page 5
FILING_STAMP_OR_ESERVICE
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
...868-4901 jmckemie@mckemie.net File, and additionally by TX E-FILE, EMAIL (gulijasz@gmail.com), and on January 11th, 2026 at or about 8:30PM CST. Jason McKemie EMERGENCY MOTION TO TEMPORARILY STAY 5 of 5 DF-24-18010 Copy from re:SearchTX
#173
2026-01-12
Respondent / Jason
Motion - Miscellaneous IN
Page 6
PLEADING_BODY
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
NOTICE: DOCUMENT CONTAINS DF-24-18010 NO. SENSITIVE INFORMATION. MARRIAGE OF § (PROPOSED) ORDER ON EMERGENCY MOTION TO TEMPORARILY STAY OR IMPOSE PROTECTIVE CONDITIONS ON PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY On this day, the Court considered Jason McKemie's Emergency Motion to Temporarily Stay or, in the Alternative, Impose Protective Conditions on Court-Authorized Property Retrieval. The Court finds that emergency relief is warranted to prevent irreparable harm, preserve the status quo, and protect the integrity of the proceedings, and that Resp...
#173
2026-01-12
Respondent / Jason
Motion - Miscellaneous IN
Page 7
PLEADING_BODY
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
...rvation of Property. Petitioner shall take no action to remove, destroy, conceal, alter, or transfer any household property pending further order of the Court. EMERGENCY MOTION TO TEMPORARILY STAY 2 of 4 DF-24-18010 Copy from re:SearchTX
#173
2026-01-12
Respondent / Jason
Motion - Miscellaneous IN
Page 8
PLEADING_BODY
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
C. SECURITY CAMERA STATUS QUO 12. No Alteration to Existing Security System. The residence is equipped with security cameras that automatically record upon detection of motion and/or sound. These cameras operated in this manner throughout the marriage and were installed in response to Petitioner's prior safety representations. a. No changes have been made to the system's configuration, scope, or operation. b. The system shall remain in status quo condition. c. No unauthorized surveillance, monitoring, or modification has occurred or is permitted. - D. ES...
#173
2026-01-12
Respondent / Jason
Motion - Miscellaneous IN
Page 9
PLEADING_BODY
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
...NUING JURISDICTION 17.. This Order shall remain in effect until further order of the Court. SIGNED on January » 2026 at : am / pm (Circle One). JUDGE PRESIDING EMERGENCY MOTION TO TEMPORARILY STAY 4 of 4 DF-24-18010 Copy from re:SearchTX
#173
2026-01-12
Respondent / Jason
Motion - Miscellaneous IN
Page 10
FILING_STAMP_OR_ESERVICE
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
on the date and to the persons listed below. The rules governing Envelope ID: 109910231 Filing Code Description: Motion - Miscellaneous IN Filing Description: EMERGENCY MOTION TO TEMORARY STAY OR THE ALTERNATIVE IMPOSE PROTECTIVE CONDITIONS ON COURT-AUTHORIZED PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY Status as of 1/13/2026 4:18 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 1/12/2026 2:22:00 AM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 1/12/2026 2:22:00 AM SENT JASON EMORYMCKEMIE jason@c...
#175
2026-01-12
Respondent / Jason
Motion - Stay
Page 1
PLEADING_START_FILE_MARKED
EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS_BEE80C57.pdf
1/12/2026 3:03 AM DALLAS CO., TEXAS NOTICE: DOCUMENT CONTAINS DF-24-18010 NO. SENSITIVE INFORMATION. MARRIAGE OF § § & § EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS, EXTEND RENT REGISTRY DEADLINE, AND PREVENT IRREPARABLE HARM DUE TO MEDICAL INCAPACITY (NON-MERITS REQUEST) TO THE HONORABLE JUDGE OF SAID COURT: Respondent, Jason McKemie, files this Emergency Motion to Stay Eviction Proceedings, Extend the Rent Registry Deadline, and Prevent Irreparable Harm Due to Medical Incapacity. This motion is temporary, narrowly tailored, and non-merits based. Resp...
#175
2026-01-12
Respondent / Jason
Motion - Stay
Page 2
PLEADING_BODY
EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS_BEE80C57.pdf
...gh later monetary relief, reinstatement, or appeal. IV. INTERACTION WITH PENDING FAMILY-COURT PROCEEDINGS 8. Risk of Procedural End-Run. Respondent has pending emergency motions in family court seeking to preserve property and impose protective conditions governing access to the residence. Eviction during this period would permit unilateral property removal outside court supervision. 9 Court Authority to Preserve Status Quo. This Court has inherent authority to prevent eviction proceedings from undermining parallel court orders or creating inconsistent o...
#175
2026-01-12
Respondent / Jason
Motion - Stay
Page 3
PLEADING_BODY
EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS_BEE80C57.pdf
...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 during hospitalization; 13. Preservation of property, prohibiting removal by Petitioner and directing landlord-controlled inventory and storage if possession changes. VI. EQUITABLE ALLOCATION OF RENT DURING COURT-...
#175
2026-01-12
Respondent / Jason
Motion - Stay
Page 4
PLEADING_BODY
EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS_BEE80C57.pdf
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
#175
2026-01-12
Respondent / Jason
Motion - Stay
Page 5
PROPOSED_ORDER_OR_ORDER
EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS_BEE80C57.pdf
NOTICE: DOCUMENT CONTAINS DF-24-18010 NO. SENSITIVE INFORMATION. MARRIAGE OF § § & § (PROPOSED) ORDER ON EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS, EXTEND RENT REGISTRY DEADLINE, AND PRESERVE PROPERTY On this day, the Court considered Jason McKemie's Emergency Motion to Stay Eviction Proceedings, Extend Rent Registry Deadline, and Prevent Irreparable Harm. The Court finds that emergency relief is warranted to prevent irreparable harm, preserve the status quo, and protect the integrity of the proceedings, and that Respondent's medical incapacity furth...
#175
2026-01-12
Respondent / Jason
Motion - Stay
Page 6
PLEADING_BODY
EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS_BEE80C57.pdf
C. RENT REGISTRY TOLLING AND EQUITABLE ALLOCATION 3. Conditional Impossibility and Tolling. Where Respondent's ability to comply with rent registry requirements is contingent upon receipt of court-ordered funds from Petitioner, any such deadline is TOLLED until those funds are received. 4. Equitable Allocation of Rent During Court-Ordered Payment Delay. Any delay in rent or registry payment caused solely by non-receipt of court-ordered funds from Petitioner shall not constitute a default by Respondent. During such period, any rent or registry amounts acc...
#175
2026-01-12
Respondent / Jason
Motion - Stay
Page 7
FILING_STAMP_OR_ESERVICE
EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS_BEE80C57.pdf
on the date and to the persons listed below. The rules governing Envelope ID: 109910402 Filing Code Description: Motion - Stay Filing Description: EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS Status as of 1/13/2026 8:43 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 1/12/2026 3:03:02 AM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 1/12/2026 3:03:02 AM SENT Copy from re:SearchTX
#171
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 1
PLEADING_START_FILE_MARKED
APPLICATION FOR EMERGENCY TRO_5E6686B8.pdf
...S DOCUMENT CONTAINS SENSITIVE MATERIALS THE MARRIAGE OF § § GWENDOLVN ULIJASZ § 302"? jupiciAL DISTRICT & § APPLICATION FOR EMERGENCY TRO FOR IMMEDIATE TEMPORARY SUPPORT TO PREVENT IMMINENT EVICTION, RESTORE HEALTHCARE ACCESS, AND MAINTAIN STATUS QUO TO THE HONORABLE JUDGE PRESIDING: COMES NOW, Respondent, Jason McKemie, pro se, and files this EMERGENCY APPLICATION FOR TRO FOR URGENT TEMPORARY SUPPORT TO PREVENT EVICTION AND MAINTAIN STATUS QUO, and respectfully shows the Court as follows: l. INTRODUCTION & EMERGENCY NATURE Respondent seeks immediate, te...
#171
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 2
CERTIFICATE_OF_COMPLIANCE
APPLICATION FOR EMERGENCY TRO_5E6686B8.pdf
...however, perfection requires immediate payment of the appeal bond and the first rent- registry deposit. Specifically, Respondent must tender cash, in person, by the statutory deadline: e Appeal Bond: $9,998 e Rent Registry (First Deposit): $4,999 e Total Required to Perfect at This Stage: $14,997 These sums are the minimum required to perfect the appeal at this stage. Absent payment, the appeal is dismissed by operation of law, resulting in immediate loss of possession and homelessness. Respondent's bank account is negative, with no alternative means to...
#171
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 3
PLEADING_BODY
APPLICATION FOR EMERGENCY TRO_5E6686B8.pdf
...EFEATS 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 Signing, by electronic transfer to Re...
#171
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 4
CERTIFICATE_OF_COMPLIANCE
APPLICATION FOR EMERGENCY TRO_5E6686B8.pdf
e Prohibit retaliation or interference related to housing, property, or finances pending the return hearing. e Setan expedited return hearing before the District Judge at the earliest available date. This relief is temporary and narrowly tailored; it does not adjudicate property division, fault, or long-term support. Vl. ENFORCEMENT AND PAYMENT DEADLINES A. IMMEDIATE COMPLIANCE DEADLINE. Petitioner shall fully comply with these Orders by 2:00pm on the Date of Signing. Compliance includes tender of the required funds and filing written proof of compliance...
#171
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 5
PLEADING_BODY
APPLICATION FOR EMERGENCY TRO_5E6686B8.pdf
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...
#171
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 6
DECLARATION
APPLICATION FOR EMERGENCY TRO_5E6686B8.pdf
...GROUNDS FOR EX PARTE RELIEF The harm will occur before notice and hearing can be completed; it is irreversible once eviction occurs; and the requested relief is limited to preserving the status quo for a short bridge period. X. PRAYER Respondent prays the Court grant the Temporary Restraining Order as requested and set an expedited return hearing. Respectfully submitted, Jason McKemie Respondent, Pro Se 539 W. Commerce St., Suite 2010 Dallas, Texas 75208 (214) 868-4901 jmckemie@mckemie.net EXHIBITS: e Exhibit A: Eviction judgment/notice (deadlines) e Ex...
#171
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 7
PLEADING_BODY
APPLICATION FOR EMERGENCY TRO_5E6686B8.pdf
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...
#171
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 8
PLEADING_BODY
APPLICATION FOR EMERGENCY TRO_5E6686B8.pdf
2. Within (24) hours of the signing of this Order, deposit the remaining balance so that the total deposit equals $20,643.56 into joint account ending XX6893 ("Coverage Preservation Judgment"). B. Petitioner shall provide written notice (email is sufficient) within the same twenty-four (24) hours stating Petitioner is proceeding under Option B. C. After the required funds are deposited under Option B, Respondent is authorized to elect and activate COBRA continuation coverage immediately to preserve medical access. Il, NO WAIVER A. Any COBRA election by R...
#171
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 9
PLEADING_BODY
APPLICATION FOR EMERGENCY TRO_5E6686B8.pdf
favor of Respondent in an amount equivalent to two (2) weeks of Petitioner's total grassA compensation, including base'salary, bonuses, cash'incentives, equity compensation, deferred compensation, and employer-provided remuneration of any Rind. Petitioner shall deposit that amount into joint ascount ending XX6893within seventy-two (72) hours of the noncompliance trigger. !f not deposited on time, a coercive fine of $1,000 per day shall accrue until paid in full. D. Future interference The same remedies apply to any future interference with Respondent's a...
#171
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 10
EXHIBIT_START
APPLICATION FOR EMERGENCY TRO_5E6686B8.pdf
...132.001) My name is Jason McKemie. My date of birth is April 8, 1976. My address is 539 W. Commerce St., | have #2010, Dallas, Texas 75208. | am of sound mind, competent to make this declaration, and personal knowledge of the facts stated herein. | am evicted before that deadline, the loss of possession perfect my appeal expires Monday. If and resulting harm cannot be undone. | have a serious shoulder injury 2. | am medically compromised and physically unable to relocate. requiring surgical intervention, including a fully torn rotator cuff, ruptured bice...
#171
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 11
EXHIBIT_CONTINUATION
APPLICATION FOR EMERGENCY TRO_5E6686B8.pdf
...not immediately accessible will not prevent eviction because the appeal and rent-registry deadlines expire before further judicial review is available. | will be unable to stabilize housing or obtain necessary medical care without emergency relief. 8. Ability to Comply / Scale of Available Funds. Petitioner has the ability to comply with immediate temporary support, and any claim of "lack of funds" is not credible. Even without addressing Petitioner's ongoing salary, bonuses, or broader estate issues, there are discrete, identifiable funds already discl...
#171
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 12
EXHIBIT_CONTINUATION
APPLICATION FOR EMERGENCY TRO_5E6686B8.pdf
...of Dec. 31, 2025 o VEIP balance would have fully vested immediately o Approximately $195,000 would be immediately accessible o Community portion approximately $97,500 e Total Identifiable Funds from Only These 3 Recent Events (Excluding Over $600,000 in Additional Marital Assets & Forms of Compensation) e Minimum identifiable assets: « (Sign-on $300,000 + Settlement $148,000 + VEIP $100,000) » Total: $548,000 Community Portion: $274,000 e More likely identifiable assets: « (Sign-on $300,000 + Settlement $148,000 + VEIP $195,000) Total: $643,000 » Commun...
#171
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 13
EXHIBIT_START
APPLICATION FOR EMERGENCY TRO_5E6686B8.pdf
EXHIBIT C Overview Ustad Agee?Vek Total Cams feng Dey Change $495,434.00 $7,772.02 #5799 56 / D.0d%e pee bead! =r J OTT OE Pell deerea Account Summary ashe Late me ame rad:: PE pee Be eae eo Cash & Investments & Verify your Information vile BOOS LO | TidyChere cero ore ip accurate mau Wares Vee Tas Coy Change 0000 5234 $126 Quick Actions OORG Sd layout Pore ae!| Quali 02512 beep Hake aonelime transfer a Undate account nicktames Portfolia Progress September 2025 : : : ramet planner Henney pou DF-24-18010 Copy from re:SearchTX
#171
2026-01-12
Respondent / Jason
Application - Temporary Restraining Order
Page 14
FILING_STAMP_OR_ESERVICE
APPLICATION FOR EMERGENCY TRO_5E6686B8.pdf
on the date and to the persons listed below. The rules governing Envelope ID: 109910548 Filing Code Description: Application - Temporary Restraining Order Filing Description: EMERGENCY Status as of 1/13/2026 4:24 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 1/12/2026 3:42:37 AM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 1/12/2026 3:42:37 AM SENT Copy from re:SearchTX
#176
2026-01-12
Respondent / Jason
Affidavit
Page 1
PLEADING_START_FILE_MARKED
AFFIDAVIT ON PUBLIC STORAGE THEFT ACCUSATIONS AND PETITIONERS ACQUISITION OF WEAPON DURING PROCEEDIN_D8FEF4AC.pdf
...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 May 30th, 2025, separated the personal property located within the parties' Public Storage facility in accordance with prior written communications and discussions between myself and Petitioner. All items identified as belonging to Petitioner were placed into one designa...
#176
2026-01-12
Respondent / Jason
Affidavit
Page 2
PLEADING_BODY
AFFIDAVIT ON PUBLIC STORAGE THEFT ACCUSATIONS AND PETITIONERS ACQUISITION OF WEAPON DURING PROCEEDIN_D8FEF4AC.pdf
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...
#176
2026-01-12
Respondent / Jason
Affidavit
Page 3
EXHIBIT_START
AFFIDAVIT ON PUBLIC STORAGE THEFT ACCUSATIONS AND PETITIONERS ACQUISITION OF WEAPON DURING PROCEEDIN_D8FEF4AC.pdf
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...
#176
2026-01-12
Respondent / Jason
Affidavit
Page 4
EXHIBIT_CONTINUATION
AFFIDAVIT ON PUBLIC STORAGE THEFT ACCUSATIONS AND PETITIONERS ACQUISITION OF WEAPON DURING PROCEEDIN_D8FEF4AC.pdf
...ch 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 2 940.20(2) Commission Wardens H Read In Responsible Official Prosecuting Agency Prosecuting Attorney Defense Attorney Diltz, Peter District Attorney Korb, Joan M. Meier, Rick B. Defendant Defendant Name Date of Birth Sex Race! Stathoulopoulos, Gwendolyn L 05-27-1978 Female Caucasian Address Address Updated On 1512...
#176
2026-01-12
Respondent / Jason
Affidavit
Page 5
EXHIBIT_CONTINUATION
AFFIDAVIT ON PUBLIC STORAGE THEFT ACCUSATIONS AND PETITIONERS ACQUISITION OF WEAPON DURING PROCEEDIN_D8FEF4AC.pdf
...full time work, school or combination of the / School two, providing written proof within 30 days of the expiration of this agreement. Prohibitions Commit no further law violations during the period of this agreement. Consume no alcohol beverages or controlled substances. No entry into bars or taverns. Not to possess drug paraphernalia. Defendant will not drive any motor vehicle unless or until her license has been reinstated. Other Defendant will, on or before January 1, 2014, send a written and signed letter of apology, minimum 500 Attorney's office. U...
#176
2026-01-12
Respondent / Jason
Affidavit
Page 6
EXHIBIT_CONTINUATION
AFFIDAVIT ON PUBLIC STORAGE THEFT ACCUSATIONS AND PETITIONERS ACQUISITION OF WEAPON DURING PROCEEDIN_D8FEF4AC.pdf
...k 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 revoked or the defendant may have to complete a new assessment. Alcohol Complete an Alcohol and/or Other Drug Abuse (AODA) assessment Assessment with a certified Alcohol and Drug Abuse Counselor, at an appropriate counseling or treatment center and willingly cooperate in any recommended counseling or treatment. The d...
#176
2026-01-12
Respondent / Jason
Affidavit
Page 7
EXHIBIT_CONTINUATION
AFFIDAVIT ON PUBLIC STORAGE THEFT ACCUSATIONS AND PETITIONERS ACQUISITION OF WEAPON DURING PROCEEDIN_D8FEF4AC.pdf
Case Details for 2013CF000126 in Door County originated. 7 of 7 Page 4 of 4 Generated on 03-19-2014 at 11:08 amCopy from re:SearchTX
#176
2026-01-12
Respondent / Jason
Affidavit
Page 8
FILING_STAMP_OR_ESERVICE
AFFIDAVIT ON PUBLIC STORAGE THEFT ACCUSATIONS AND PETITIONERS ACQUISITION OF WEAPON DURING PROCEEDIN_D8FEF4AC.pdf
on the date and to the persons listed below. The rules governing Envelope ID: 109910688 Filing Code Description: Affidavit Filing Description: AFFIDAVIT ON PUBLIC STORAGE THEFT ACCUSATIONS AND PETITIONERS ACQUISITION OF WEAPON DURING PROCEEDINGS Status as of 1/12/2026 3:43 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 1/12/2026 4:12:09 AM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 1/12/2026 4:12:09 AM SENT Copy from re:SearchTX
#174
2026-01-12
Respondent / Jason
Affidavit
Page 1
PLEADING_START_FILE_MARKED
AFFIDAVIT - MANUFACTURED ALLEGATIONS_4D770C9D.pdf
...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, Gwendolyn Ulijasz was permitted access to the marital residence for the limited purpose of retrieving certain personal belongings. 3. Prior to her arrival, Ms. Ulijasz sent a text message stating that she would take only her work- related items and cloth...