DF-24-18010 Litigation Record Search

...MERGENCY MOTION FOR TEMPORARY FINANCIAL RELIEF DUE TO IMMINENT HOUSING LOSS, MEDICAL HARDSHIP EMERGENCY M/FINANCIL • 06/27/2025 (Entry 67) — 4 pages — MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPEL DISCOVERY RESPONSES MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPELL DISCOVERY RESPONSES • 06/27/2025 (Entry 69) — 5 pages — OBJECT IN MATERIAL DISCOVERY NOTICE OF MATERIAL DISCOVERY NOTICE OF MATERIAL DISCOVERY • 07/10/2025 (Entry 70) — 1 page — FINANCIAL RELIEF, ENFORCEMENT OF STANDING ORDERS, PROTECTION AGAINST PROCEDURAL ABUSE, AND HEARING ON SPOUSAL SUPPOR...

...ATIVE, IMPOSE PROTECTIVE CONDITIONS ON COURT-AUTHORIZED PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY • 01/12/2026 (Entry 180) — 11 pages — MOTION TO ABATE TRIAL, ENFORCE DISCOVERY ORDERS AND HEALTHCARE REINSTATEMENT • 01/15/2026 (Entry 182) — 4 pages — RESPONDENT'S MOTION TO ESTABLISH CONDITIONS FOR RE-ENTRY OF COUNSEL AND TO PRESERVE FAIR TRIAL • 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 3. MOTIONS SEEK...

• 06/27/2025 (Entry 67) — 4 pages — MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPEL DISCOVERY RESPONSES MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPELL DISCOVERY RESPONSES • 07/10/2025 (Entry 75) — 2 pages — ORDER TO PREVENT ANY FURTHER OBSTRUCTION AND TO COMPEL ACCESS TO HSA CARD/ FUNDS PROPOSED ORDER/JUDGMENT • 07/10/2025 (Entry 72) — 1 page — ORDER ON MOTION TO COMPELL DISCOVERY AND REQUEST FOR SANCTIONS PROPOSED ORDER/JUDGMENT • 07/10/2025 (Entry 73) — 1 page — ORDER ON MOTION TO COMPEL DISCOVERY AND REQUEST FOR SANCTIONS PROPOSED ORDER/JUDGMENT • 12/...

...TO SERVE SUBPOENAS PROPOSED ORDER GRANTING LEAVE TO SERVE SUBPOENAS • 12/23/2025 (Entry 150) — 3 pages — TO ISSUE SUBPOENA REGARDING LEASE BUYOUT AND ASSOCIATED PAYMENTS MOTION - LEAVE • 12/23/2025 (Entry 151) — 181 pages — MOTION - SEALED SUBMISSION FOR IN CAMERA REVIEW ONLY (CONFIDENTIAL) MOTION SEAL SUBMISSION FOR CAMERA REVIEW • 12/29/2025 (Entry 152) — 13 pages — SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL (REQUEST FOR CUSTODIAN CONTINUITY RECORDS / SUBPOENA LEAVE) SUPPLEMENTAL SUBMISSION IN SUPPORT OF MOTION TO COMPEL 2026 • 01/02/2026 (...

...MPOSSIBILITY, CONDITIONAL SANCTIONS, AND THIRD-PARTY SUBPOENA AUTHORITY (QLE RECORDS) PROPOSED ORDER • 01/14/2026 (Entry 180) — 11 pages — 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

• 06/27/2025 (Entry 67) — 4 pages — MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPEL DISCOVERY RESPONSES MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPELL DISCOVERY RESPONSES • 06/27/2025 (Entry 69) — 5 pages — OBJECT IN MATERIAL DISCOVERY NOTICE OF MATERIAL DISCOVERY NOTICE OF MATERIAL DISCOVERY • 07/10/2025 (Entry 72) — 1 page — ORDER ON MOTION TO COMPELL DISCOVERY AND REQUEST FOR SANCTIONS PROPOSED ORDER/JUDGMENT • 07/10/2025 (Entry 73) — 1 page — ORDER TO REOPEN A LIMITED DISCOVERY DUE TO PROCEDURAL MISCONDUCT AND OBSTRUCTION PROPOSED ORDER/JUDGMENT • 07...

• 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...

...ot reurge the same grounds asserted in the prior recusals. Each recusal arose from a distinct escalation point in an increasingly severe pattern of procedural breakdown, discovery obstruction, financial concealment, healthcare interference, and trial-preparation sabotage: e Recusal No. 1 addressed the 254th District Court's failure to hear emergency relief, discovery obstruction, medical collapse, and the procedural trap created when counsel withdrew during discovery and reappeared at the discovery deadline to file blanket objections; ¢ Recusal No. 2 add...

...ths, missing pages, mixed-year page inserts, one-day snapshots masquerading as statements, reissued card numbers, missing account continuity, missing source records, and discovery responses that recited Bates ranges without curing the defects. No decree can be safely signed on this financial record. Vill. NEW BMW / INVENTORY CONTRADICTION REQUIRES SOURCE VERIFICATION roa BMW X3 on May 29, 2026. Petitioner's New SAPD dashcam evidence appears to show Petitioner with February 7, 2026 inventory identifies only a 2023 BMW M340xi with a claimed $55,902 loan ba...

...AIVER OF SANCTIONS, CONTEMPT, ENFORCEMENT, OR FEE OBJECTIONS Respondent does not waive any request for sanctions, contempt, enforcement, fee shifting against Petitioner, discovery sanctions, evidentiary sanctions, attorney-fee recovery, referral, disqualification, disgorgement, or other relief against Petitioner, current counsel, former counsel, pro hac vice counsel, law firms, investigators, vendors, OSINT/cyber actors, reputation-management actors, landlord-side actors, movers, security personnel, U-Haul/payment proxies, benefit/HR/plan-administrator a...

...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, evidentiary remedies, fee denial, fee shifting against Petitioner/counsel, discovery sanctions, Rule 13 sanctions, Chapter 10 sanctions, Rule 215 s...

...spondent 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 reporter protection, source-record verification, subpoena authority, trial abatement, continuance, housing stabilit...

...spondent 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 reporter protection, source-record verification, subpoena authority, trial abatement, continuance, housing stabilit...

...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 records, RS...

...tions. 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 trial- readiness defects. 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

...cation occurred on the sanctions/counsel-certification issues. 13.No merits adjudication occurred on whether Petitioner's protective order seeks protection from improper discovery or protection from verification. The Associate Judge's denial therefore rests on a procedurally incomplete presentation, not on a full evidentiary determination of the merits. Texas Family Code § 201.015 exists for this exact reason: the District Judge must conduct a fresh hearing on the specified issues and permit the parties to present witnesses and evidence. DF-24-18010 Requ...

...ing/stolenharddrives,devices,litigationrecords,trial materials, financial records, and evidence repositories; 12. prior notices and motions showing repeated requests for discovery enforcement, subpoena authority, source-record verification, healthcare enforcement, trial abatement, 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...

...dens, 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 Petitioner's financial production to appear and show cause why s...

...ens, 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 shield materially incomplete financial production to appear and show cause...

...it -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 financial...

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...

...dline 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 Page 4 of 17 Copy from re:SearchTX

...ccount has contiguous statements from August 2023 through present. That alone prevents final trial. The Court cannot conduct a final property division where: DF-24-18010 Motion for Enforcement, Sanctions, Continuance, & Leave Page 6 of 17 Copy from re:SearchTX

...ives were Movant's separate property owned before the marriage. Those stolen hard drives contained: 1. Seventeen months of exhibits; 2. Financial reconstruction work; 3. Discovery materials; 4. Records prepared for production; 5. Trial preparation; 6. Accenture-related contribution evidence: DF-24-18010 Motion for Enforcement, Sanctions, Continuance, & Leave Page 11 of 17 Copy from re:SearchTX

...a cure. But Movant at least had his own records. Now he has nothing. Petitioner stole the records Movant built to reconstruct the estate, prove contribution, respond to discovery, and prepare for trial. She should not be permitted to 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 boo...

XV. THIS 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 instabil...

...ent'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, payroll-origin not continuance predicate record, equity-plan-origin record, or tax-origin record attached supporting the alleged gain or lestate-variance claim. April 16 / alleged device theft No...

...ness, the expected testimony, and that the continuance is not sought for delay. Tex. R. Civ. P. 252. Diligence is the heart of the inquiry. A party who failed to use the discovery tools available during the discovery period has not shown the diligence Rule 252 requires, and a continuance motion that does not set forth the evidence sought, its materiality, and the due diligence used to obtain it is properly denied. Wal-Mart Stores Tex., L.P. v. Crosby, 295 S.W.3d 346, 356 (Tex. App.-Dallas 2009, pet. denied); Garner v. Fidelity Bank, N.A., 244 S.W.3d 855,...

...st whether her financial disclosures are truthful. e That is not compliance. e That is obstruction. Petitioner's protective-order request is not protection from improper discovery. It is protection from verification. It asks this Court to bless 17 months of missing statements, missing months, missing pages, missing account continuity, missing payroll records, missing VEIP/equity records, missing tax records, missing loan funding records, missing GLU Distribution LLC records, missing source documents, and missing third-party records - then force Jason to...

...elied upon, or failed to correct this production belongs in the sanctions inquiry. Petitioner's protective order is the tell. She is not seeking protection from improper discovery. She is seeking protection from the records that will determine whether her disclosures are true. The books either reconcile or they do not. The loans either have funded transfers or they do not. The VEIP records either exist or they do not. The tax transcripts either support her position or they do not. The April 16 records either explain what happened or they do not. That is...

Petitioner's "he waited until trial" argument is false by omission. Jason did not wait. Jason repeatedly raised these defects. Jason repeatedly sought financial discovery, subpoena authority, source-record verification, written rulings, and enforcement. The record includes, among other filings and hearing entries: - June 27, 2025 Motion to Preserve Discovery Rights and Compel Discovery Responses; July 16, 2025 - Motion for Sanctions / fraud-upon-the-court track; July 17, 2025 - Notice of Material Discovery Concealment and reservation of rights; July 17,...

...e voluntarily placed counsel review and certification directly at issue. His affidavit states that he was actively involved in the preparation and review of Petitioner's discovery production. He identifies a production index and Bates range. He does not identify a single complete continuous institution-origin account. He does not identify a single account/month/source-record chart proving continuity. He does not identify the missing replacement-card lineage. He does not identify payroll registers. He does not identify VEIP election records. He does not i...

...red, presented, defended, relied upon, or attempted to shield materially incomplete financial production from verification. V. PETITIONER'S PROTECTIVE ORDER IS BAD-FAITH DISCOVERY OBSTRUCTION. in n full. Petitioner's protective order should be denied Petitioner is not asking the Court to protect privileged communications. She is asking the Court to protect missing source records from being tested. She wants protection from banks, payroll custodians, Accenture, equity administrators, VEIP records, tax records, loan records, lease records, landlord records...

..., protective expenses, and litigation expenses against Jason. That request is offensive. Petitioner has stretched this divorce across 17 months of financial concealment, discovery obstruction, healthcare obstruction, false narratives, protective-order gamesmanship, late production, source- record concealment, housing destabilization, forced bankruptcy pressure, and April 16 theft. e Jason is homeless. e Jason has been denied functional healthcare access. e Jason has been blocked from heart medication and surgical care. e Jason has been forced into bankru...

...nsel's production index as compliance. XI. RECONSTITUTION, DISPROPORTIONATE DIVISION, FORENSIC ACCOUNTING, AND STABILIZATION ARE NOW REQUIRED. This is no longer ordinary discovery enforcement. Petitioner's conduct directly affects the Court's ability to determine the true composition and value of the marital estate. The Court cannot make a just and right division of an estate that cannot be identified. The Court cannot reject reconstitution while source records are blocked. The Court cannot decide disproportionate division while Petitioner's financial pr...

...ts, or anyone acting for her to access, inspect, image, copy, use, or benefit from Jason's stolen hard drives or evidence repositories. XII. THE COURT SHOULD NOT CONVERT OBSTRUCTION INTO FINAL JUDGMENT. Petitioner wants the Court to proceed to trial while the estate cannot be reconstructed. That would reward obstruction. A final trial without source records would force Jason to defend against a financial narrative built from missing statements, rotated accounts, unexplained overpayments, unsupported loans, mislabeled equity, missing tax transcripts, miss...

...ity, bodyguards, All My Sons, Merritt McClayton, Decisive Resources, Jetty Partners, landlord records, constable records, and related source-record custodians; 5. MODIFY discovery deadlines for the limited purpose of third-party source-record verification and related follow-up; 6. CONTINUE or ABATE the June 11,2026trial setting until the marital estate can be reconstructed from complete, continuous, source-verifiable records; 7. ORDER Petitioner, Jonathan Drake Steele, Rebecca L. Armstrong, Sullivan & Cook, and any counsel who certified, sponsored, prese...

...ry that the following is true in this filing. and correct based on my personal knowledge and review the records referenced 1. | have repeatedly sought complete financial discovery, source-record verification, subpoena authority, and enforceable compliance throughout this case. 2. | served deficiency notices and identified missing pages, missing months, missing accounts, missing VEIP records, missing GLU Distribution LLC records, missing Chase continuity records, missing overpayment tracing, missing payroll records, missing equity records, and missing sou...

...ontinuance and subpoenas are not sought for delay. They are necessary because trial without source records would convert Petitioner's noncompliance, false certification, discovery obstruction, and evidence theft into litigation advantage. 10. | request denial of Petitioner's protective order, denial all fees/costs/protective expenses against me, authorization of third-party subpoenas, sworn counsel certification, trial continuance, and a sanctions/show-cause hearing. Jason McKemie 539 W. Commerce St., Suite 2010 Dallas, Texas 75208 214-868-4901 jmckemie@...

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 8 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 financial hardship by showi...

e Heserved discovery in good faith; e Petitioner's counsel moved to withdraw citing financial hardship; e Petitioner did not formally proceed pro se, creating service ambiguity; e With less than one hour remaining in the discovery period, counsel reappeared at 11:08 every discovery request; e Approximately one hour later, discovery was declared closed; e Trial proceeded despite unresolved discovery disputes and without complete financial disclosure. Respondent further advised Judge Jackson that there could be no fair trial absent: 1. Third-party subpoena...

...Promised "substantive responses" followed by recycled Bates productions; Production delivered in inaccessible format; Counsel withdrawal immediately after filing of the Motion to Compel; No uninterrupted sequence of institution-origin monthly statements sufficient for tracing These deficiencies are not isolated clerical errors. They are structural defects that prevent meaningful estate reconstruction. IV. PRESENT STRUCTURAL IMPOSSIBILITY The estate cannot be evaluated because: e There is no uninterrupted monthly sequence for any account; e Institution-o...

...plete; e Anactive bankruptcy stay exists under Trustee oversight. These facts are extensively documented and; Proceeding to trial under these conditions would: e Convert discovery collapse into adjudication; e Freeze dissipation into final division; e Render third-party verification impossible; e Permanently impair Respondent's ability to challenge false or incomplete production. V. CONDITIONAL NATURE OF THIS MOTION Respondent does not seek recusal if: 1 The Court grants limited third-party subpoena rights; 2. The Court enforces its December 17 healthcar...

EXHIBIT LIST (TO BE ATTACHED) Exhibit A: Respondent/Movant Pleadings Index by Category (100 filings / 1,110 pages). Exhibit B: Motion to Compel with Color Production Grid Exhibit D: Credit Card Over Payment Exhibit E: Signed Order to Reinstate Healthcare Exhibit F: Motion to Compel Docket Sheet Exhibit G: Benefits Summary generated February 2, 2026, reflecting multiple coverages waived Exhibit H: Motion to Obtain Certified Transcript of January 7, 2025 Hearing (with proposed order). Exhibit I: Motion to Establish Conditions for Re-Entry of Counsel and Pr...

...A / Abatement or Stay / Standing or 41 507 Temporary Orders 5. Financial relief I/ reimbursements / fraud / rent / stabilization / 39 354 Standing or Temporary Orders 6. Discovery obstruction / compel / subpoenas / enforcement 24 199 7. Due process / record / ex parte / court reporter / verbatim 43 516 record / procedural fairness 8. Eviction / housing stability 10 108 1. AFFIDAVITS / DECLARATIONS / CHARACTER REFERENCES 2025 ® 07/10/2025 (Entry 81) 43 pages FINANCIAL RELIEF, ENFORCEMENT OF STANDING ORDERS, PROTECTION AGAINST PROCEDURAL ABUSE, AND HEARING...

...ges EMERGENCY MOTION FOR TEMPORARY FINANCIAL RELIEF DUE TO IMMINENT HOUSING LOSS, MEDICAL HARDSHIP EMERGENCY M/FINANCIL e 06/27/2025 (Entry 67) 4pages MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPEL DISCOVERY RESPONSES MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPELL DISCOVERY RESPONSES e 06/27/2025 (Entry 69) 5pages OBJECTIN MATERIAL DISCOVERY NOTICE OF MATERIAL DISCOVERY NOTICE OF MATERIAL DISCOVERY e 07/10/2025 (Entry 70) 1page FINANCIAL RELIEF, ENFORCEMENT OF STANDING ORDERS, PROTECTION AGAINST PROCEDURAL ABUSE, AND HEARING ON SPOUSAL SUPPORT, LEGAL FE...

...ALTERNATIVE, IMPOSE PROTECTIVE CONDITIONS ON COURT-AUTHORIZED PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY 01/12/2026 (Entry 180) 11 pages MOTION TO ABATE TRIAL, ENFORCE DISCOVERY ORDERS AND HEALTHCARE REINSTATEMENT VERIFIED MOTION TO RECUSE DF-24-18010 12 Ob69¢ 110 Copy from re:SearchTX

...SPONDENT'S MOTION TO ESTABLISH CONDITIONS FOR RE- ENTRY OF COUNSEL AND TO PRESERVE FAIR TRIAL e 01/26/2026 (Entry185) 5pages NOTICE OF PRESERVATION OF WITNESSES, & LARGE DISCOVERY PRODUCTION IN FINAL HOUR NOTICE OF PRESERVATION OF WITNESSES, & LARGE DISCOVERY PRODUCTION IN FINAL HOUR 3. Motions seeking to "compel" something 2025 06/27/2025 (Entry 67) 4 pages MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPEL DISCOVERY RESPONSES MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPELL DISCOVERY RESPONSES 07/10/2025 (Entry 75) 2 pages ORDER TO PREVENT ANY FURTHER OBSTR...

e 08/06/2025 (Entry104) 7pages EMERGENCY MOTION TO ABATE TRIAL SETTING AND WITHHOLD FINAL ORDERS PENDING RESOLUTION OF OUTSTANDING MOTIONS, PROCEDURAL VIOLATIONS, AND DISCOVERY COLLAPSE e 11/21/2025 (Entry 132) gy2 pages ORDER FOR DE NOVO REVIEW AND TRO PROPOSED ORDER/JUDGMENT e 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 - CORRECTING FALSE e 11/25/2025 (Entry 134) 6pages NOTICE OF FILING OF SWORN AFFIDAVIT RECORDING ALLEGATIONS A...

...GENCY MOTION ON MEDICAL HARM 01/12/2026 (Entry 162) 4 pages ORDER ON EMERGENCY TRO PROPOSED ORDER/JUDGMENT 01/12/2026 (Entry 180) 11 pages MOTION TO ABATE TRIAL, ENFORCE DISCOVERY ORDERS AND HEALTHCARE REINSTATEMENT VERIFIED MOTION TO RECUSE DF-24-18010 16 Of69¢ 110 Copy from re:SearchTX

...TION/IMPOSSIBILITY, CONDITIONAL SANCTIONS, AND THIRD-PARTY SUBPOENA AUTHORITY (QLE RECORDS) PROPOSED ORDER 01/14/2026 (Entry 180) 11 pages MOTION TO ABATE TRIAL, ENFORCE DISCOVERY ORDERS AND HEALTHCARE REINSTATEMENT 6. Discovery obstruction / compel / subpoena requests 2025 e 06/27/2025 (Entry 67) 4 pages MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPEL DISCOVERY RESPONSES MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPELL DISCOVERY RESPONSES VERIFIED MOTION TO RECUSE DF-24-18010 18 110 Copy from re:SearchTX

© 06/27/2025 (Entry 69) 5pages OBJECT IN MATERIAL DISCOVERY NOTICE OF MATERIAL DISCOVERY NOTICE OF MATERIAL DISCOVERY e 07/10/2025 (Entry 72) 1page ORDER ON MOTION TO COMPELL DISCOVERY AND REQUEST FOR SANCTIONS PROPOSED ORDER/JUDGMENT e 07/10/2025 (Entry 73) 1page ORDER TO REOPEN A LIMITED DISCOVERY DUE TO PROCEDURAL MISCONDUCT AND OBSTRUCTION PROPOSED ORDER/JUDGMENT e 07/10/2025 (Entry 72) 1page ORDER ON MOTION TO COMPELL DISCOVERY AND REQUEST FOR SANCTIONS PROPOSED ORDER/JUDGMENT e 07/10/2025 (Entry 73) 1page ORDER ON MOTION TO COMPEL DISCOVERY AND REQ...

CONDITIONAL SANCTIONS, AND THIRD-PARTY SUBPOENA AUTHORITY (QLE RECORDS) PROPOSED ORDER e 01/14/2026 (Entry180) 11pages MOTION TO ABATE TRIAL, ENFORCE DISCOVERY ORDERS AND HEALTHCARE REINSTATEMENT e 01/26/2026 (Entry185) 5pages 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 e 04/24/2025 (Entry 56) 1 page MOTION FOR NOTICE PRIOR TO ANY DISMISSAL PROP...

NOTICE: THIS DOCUMENT CONTAINS NO. DF-24-18010 SENSITIVE DATA THE MARRIAGE OF 5 EMERGENCY MOTION TO COMPEL FINANCIAL DISCOVERY TO THE HONORABLE JUDGE OF THE 302" DISTRICT COURT: Respondent Jason McKemie respectfully files this Emergency Motion to Compel, and shows: |. BACKGROUND Full financial discovery has never occurred in this case. In the prior court (254th District), opposing counsel withdrew on the eve of their discovery deadline while still drafting and filing objections behind the scenes, and Petitioner did not declare herself pro se during that...

...ce pages. Less than 20% of required financial statements exist, and even those are structurally unusable. Petitioner remains responsible for providing complete financial discovery for all accounts, not just those listed here. MOTION TO COMPEL FINANCIAL DISCOVERY 3of5 DF-24-18010 26 Q669¢ 110 Copy from re:SearchTX

...or forensic accountant without native institution-issued statements. * These disclosures were built to prevent tracing and cannot be repaired. MOTION TO COMPEL FINANCIAL DISCOVERY 4o0f5 DF-24-18010 27 O69 110 Copy from re:SearchTX

...ction cannot replace institution-origin records; and 5. Reserve the Court's authority to impose sanctions or other appropriate relief if Petitioner continues to obstruct discovery or withhold required financial information. | request any additional relief the Court deems appropriate. Respectfully submitted, Jason McKemie 539 W. Commerce St., Suite 2010 Dallas, TX 75208 jmckemie@mckemie.net 214-868-4901 MOTION TO COMPEL FINANCIAL DISCOVERY Sof§ DF-24-18010 28 110 Copy from re:SearchTX

Jason McKemie Wednesday, December 3, 2025 at 1:51:20AM Central Standard Time Subject: Discovery Date: Friday, October 10, 2025 at 1:33:20PM Central Daylight Time From: Ethan Scroggins <escroggins@sullivancook.com> To: Jason McKemie <jmckemie@mckemie.net>, Jason McKemie <mckemie76@gmail.com> cc: Will Cook <weook@sullivancook.com>, Chandler Alt <calt@sullivancook.com> Attachments: 2025-10-09 Exhibit A - Discovery Log.xlsx, Dec 2024 Page 3.pdf, Nov 2024 Page 3.pdf Mr. McKemie, Your "exhibits" to your requests for information appear to be based only on the 2...

...10, 12 Jet Invoice Final, GUOO1LI19 GU001319 DNAS iz Lease Final.pdt GUNO1320 GU001337 823/25 6,12 | spent 24 hours detailing all the They emailed this list of defective discovery docs deficiencies 110 Copy from re:SearchTX

...ourt-Ordered Financials - Immediate Production Required Date: Thursday, September 25, 2025 at 2:20:51 PM Central Daylight Time From: Jason McKemie <jmckemie@mckemie.net> To: Ethan Scroggins <escroggins@sullivancook.com> c: Will Cook <weook@sullivancook.com>, Chandler Alt <calt@sullivancook.com>, Kim Jones <kjones@sullivancook.com>, Jason McKemie <mckemie76@gmail.com> Priority: High Attachments: Disc DemandGwen - Disc List (Master).pdf Ethan, know there' a lot to pull together but can you prioritize these for quick turn around? Would be much appreciated....

...full and complete documentation by Tuesday, Sept 30, 2025. Jason McKemie From: Ethan Scroggins <escroggins@sullivancook.com> Date: Tuesday, September 23, 2025 at 3:12 PM To: Jason McKemie <imckemie@mckemie.net> Cc: "wcook@sullivancook.com" <wcook@sullivancook.com>, Chandler Alt <calt@sullivancook.com>, Kim Jones <kjones@sullivancook.com>, Jason Mckemie <mckemie76@gmail.com> Subject: RE: Subject: Court-Ordered Financials - Immediate Production Required Mr. McKemie, The Court directed and made sure that production would be made in response to legitimate an...

...dered Financials - Immediate Production Required Date: Tuesday, September 30, 2025 at 5:47:54 PM Central DaylightTime From: Ethan Scroggins <escroggins@sullivancook.com> To: Jason McKemie <jmckemie@mckemie.net> cc: Will Cook <wcook@sullivancook.com>, Chandler Alt <calt@sullivancook.com>, Kim Jones <kjones@sullivancook.com>, Jason McKemie <mckemie76@gmail.com> Mr. McKemie, I had an emergency TRO come up today that took up most of my day and an all day mediation yesterday. Six days is too short a turnaround for the amount of items you identified. We will h...

...m> Subject: RE: Subject: Court-Ordered Financials - Immediate Production Required Mr. McKemie, The Court directed and made sure that production would be made in response to legitimate and reasonable requests for production made under proper procedure. You already asked for these - GU001668 in documents, and we have already produced documents bates labeled GU000001 rasponse. The manner at which we have produced documents follows the rules. If you have identified specific instances of missing pages in statements, provide those specific instances. You canno...

accounts, No account may be excluded on the ground it is "separate property." If an account is asserted to be separate, your client bears the burden to establish separate character through complete statements and tracing. 2. Monthly statements only. Produce official, institution-issued monthly statements. No quarterlies, annual summaries, or daily "snapshots" (e.g., AIG one-day reports). These do not satisfy the Court's directive. 3. Sequential, gap-free coverage. Statements must be consecutive and cover every day in the period. The closing balance of on...

$10,000/month, ~$130,000/year) to equity funds initiated after entry of the orders are inconsistent with any asserted loan-based "need" and must be fully disclosed in the statements and accountings. 3. Elective cosmetic procedures. Elective cosmetic surgery is not a community obligation and must be excluded from community expense accounting. 4, GLU Distribution (...8627). Produce monthly statements in the same consolidated, sequential, complete manner as all other accounts. 5. Reimbursements and allowances. Provide a full accounting of all reimbursements...

cannot reasonably prepare exhibits or submit materials to a forensic accountant. Any attempt to delay production until exhibits are due will require me to seek a continuance of the trial date. | will file Non-compliance: If production is not made in this format and by these deadlines, notice with the Court and seek appropriate relief, including an order compelling proper production or authorizing subpoenas to custodians of records at your client's expense, as well as any other relief the Court deems just. Please confirm receipt, provide the complete Dece...

..."ignoring" what was produced; I'm identifying the specific defects that prevent the Court-ordered "full and complete" financials. Please cure the items below or point me to the exact Bates range that already satisfies each request. Attached are Demonstrative Exs. A-1 and A-2 marking missing months/pages; they are illustrative only and not a substitute for production. | find any additional documentation missing. This should get you started. will advise if A. Global completeness (all accounts). Based on my review of GU000001-GU001668, no account includes a...

...tization schedule; and Each loan payment posted Sept 2023-present (principal/interest). If available, provide the administrator's "balance as of Sept 1, 2023" letter. E. Production map (to avoid more back-and-forth) 46 110 Copy from re:SearchTX

...nthlies + CSV, and (iii) fees. To keep lanes clean: HSA access will be addressed by separate emergency motion and proposed order (same-day digital provisioning). | am F. Discovery. As a courtesy for the time required to compile the deficiency inventory, extending the response deadline by one business day. Please provide a full and complete response-either producing the missing materials or citing exact Bates ranges-no later than close of business (5:00 p.m. CT) on Tuesday, September 30, 2025. Best, Jason McKemie 214)868-4901 jmckemie@mckemie.net 47 110 C...

EXHIBIT LIST (TO BE ATTACHED) Exhibit A: Respondent/Movant Pleadings Index by Category (100 filings / 1,110 pages). Exhibit B: Motion to Compel with Color Production Grid Exhibit D: Credit Card Over Payment Exhibit E: Signed Order to Reinstate Healthcare Exhibit F: Motion to Compel Docket Sheet Exhibit G: Benefits Summary generated February 2, 2026, reflecting multiple coverages waived Exhibit H: Motion to Obtain Certified Transcript of January 7, 2025 Hearing (with proposed order). Exhibit I: Motion to Establish Conditions for Re-Entry of Counsel and Pr...

...ity records as applicable). C. ORDER GRANTING LEAVE FOR TARGETED THIRD-PARTY SUBPOENAS This authorization constitutes leave of court under Rule 205.3 notwithstanding any discovery control plan, scheduling order, or discovery cutoff, and is entered as a targeted exception necessary to ensure record integrity and due process. D. LANDLORD, PROPERTY MANAGER, AND ASSOCIATED FINANCIAL INSTITUTIONS Lease files, modifications, buyouts, rent ledgers, payment history, notices, eviction filings/records, and complete banking and payment records sufficient to verify...

compensatory damages, exemplary damages, sanctions, statutory remedies, or other civil relief, nor does it waive any right to pursue such claims in a court of competent jurisdiction, including any right to a jury trial where applicable. E. THIRD-PARTY PRODUCTION DEADLINE Unless otherwise agreed in writing or ordered by the Court, any third-party custodian served pursuant to this Order shall produce responsive documents and electronically stored information within fourteen (14) days of service. Production may be made electronically via secure link or othe...

Jason McKemie Wednesday, December 3, 2025 at 1:51:20AM Central Standard Time Subject: Discovery Date: Friday, October 10, 2025 at 1:33:20PM Central Daylight Time From: Ethan Scroggins <escroggins@sullivancook.com> To: Jason McKemie <jmckemie@mckemie.net>, Jason McKemie <mckemie76@gmail.com> cc: Will Cook <wcook@sullivancook.com>, Chandler Alt <calt@sullivancook.com> Attachments: 2025-10-09 Exhibit A - Discovery Log.xlsx, Dec 2024 Page 3.pdf, Nov 2024 Page 3. pdf Mr. McKemie, Your "exhibits" to your requests for information appear to be based only on the...

...Required Subject: Re: Subject: Court-Ordered Financials Date: Thursday, September 25, 2025 at 2:20:51 PM Central Daylight Time From: Jason McKemie <jmckemie@mckemie.net> To: Ethan Scroggins <escroggins@sullivancook.com> cc: Will Cook <wcook@sullivancook.com>, Chandler Alt <calt@sullivancook.com>, Kim Jones <kjones@sullivancook.com>, Jason McKemie <mckemie76@gmail.com> Priority: High - Attachments: Disc Demand_Gwen Disc List (Master).pdf Ethan, | know there' a lot to pull together but can you prioritize these for quick turn around? Would be much appreciat...