DF-24-18010 Litigation Record Search

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EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL

#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
ConfirmedHealthcareEmergencyDiscovery ViolationsFinancial ReliefParity / Status QuoMedical Risk
2/20/2026 4:59 PM DALLAS CO., TEXAS THE MARRIAGE OF § § nd & § EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL TO THE HONORABLE COURT: Movant Jason McKemie, appearing pro se, files this Emergency Verified Motion to Continue or Abate the February 24, 2026 bench trial setting and to enter trial-readiness orders required for any final adjudication on property division, reimbursement claims, and credibility-dependent issues. This Motion is a procedural stop-button. It asks the Court to prevent trial on a record that remains legally stayed (bankrup...
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EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL

#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
ConfirmedHealthcareEmergencyDiscovery ViolationsFinancial ReliefParity / Status QuoMedical Risk
Relief requested: The Court must continue/abate the February 24 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. Febr...
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EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL

#199 2026-02-20 Respondent / Jason Notice Of Filing Page 3 PLEADING_BODY
EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL_109EBB73.pdf
ConfirmedHealthcareEmergencyDiscovery ViolationsFinancial ReliefParity / Status QuoMedical Risk
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...
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EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL

#199 2026-02-20 Respondent / Jason Notice Of Filing Page 4 PLEADING_BODY
EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL_109EBB73.pdf
ConfirmedHealthcareEmergencyDiscovery ViolationsFinancial ReliefParity / Status QuoMedical Risk
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...
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EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL

#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
ConfirmedHealthcareEmergencyDiscovery ViolationsFinancial ReliefParity / Status QuoMedical Risk
e Spouse/Domestic 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 FO...
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EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL

#199 2026-02-20 Respondent / Jason Notice Of Filing Page 6 DECLARATION
EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL_109EBB73.pdf
ConfirmedHealthcareEmergencyDiscovery ViolationsFinancial ReliefParity / Status QuoMedical Risk
...l granted; Jan 9 deadline; HSA card note). e Exhibit E: District docket sheet entry noting "no written orders re: 1/6/26 hearing or compel orders." e Exhibit F: Order on Emergency Reinstatement of Healthcare signed December 17, 2025. e Exhibit G: Benefits Summary generated February 2, 2026 reflecting multiple coverages waived. e Exhibit H: Motion to Obtain Certified Transcript of January 7, 2025 Hearing (with proposed order). e Exhibit I: Motion to Establish Conditions for Re-Entry of Counsel and Preserve Fair Trial. e Exhibit J: Notice of Repeated Notic...
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EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL

#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
ConfirmedHealthcareEmergencyDiscovery ViolationsFinancial ReliefParity / Status QuoMedical Risk
record and/or parties entitled to notice in accordance with the Texas Rules of Civil Procedure and : Jas6o-McKemie Copy from re:SearchTX
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EMERGENCY VERIFIED MOTION TO CONTINUE OR ABATE BENCH TRIAL

#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
ConfirmedHealthcareEmergencyDiscovery ViolationsFinancial ReliefParity / Status QuoMedical Risk
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
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 1 PLEADING_START_FILE_MARKED
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
1/20/2026 12:00 AM DALLAS CO., TEXAS IN THE MATTER OF THE MARRIAGE OF GWENDOLYN ULIJIASZ-MCKEMIE AND JASON MCKEMIE RESPONDENT'S NOTICE OF DISCOVERY COMPLIANCE, NOTICE OF HEALTHCARE COMPLIANCE, REQUEST FOR REMOTE APPEARANCE, REQUEST FOR ACCESS TO PERSONAL PROPERTY, REQUEST FOR CONSOLIDATION AND HEARING LIMITS, AND CASE MANAGEMENT CLARIFICATION Petitioner files this Notice to clarify the status of discovery and healthcare compliance, to request permission to appear remotely for upcoming hearings, to request written authority to retrieve personal property,...
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 2 PLEADING_BODY
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
...retrieving her personal property. Ill. REQUEST FOR REMOTE APPEARANCE BY ZOOM Petitioner resides over five hours from Dallas, Texas. Petitioner was required to attend an emergency hearing on January 6, 2026, and is now required to attend additional procedural hearings set for January 20, 2026 and January 22, 2026, all within the final pretrial preparation period. These hearings require multiple days away from work with little notice to her employer and cancellations on her client meetings, as well as travel, lodging, and dog boarding. Petitioner respectf...
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 3 CERTIFICATE_OF_SERVICE
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
By way of context only, Petitioner notes that in the past twelve months, Respondent has in writing July 22, 2025. Respondent additionally submitted another 25 motions in the second half of 2025, most of which have involved overlapping and duplicative issues. In the past three weeks alone leading up to final pretrial deadlines, four hearings have been set. Petitioner is not requesting abatement or delay of trial and is prepared to proceed as scheduled. Petitioner respectfully requests a brief extension of pretrial discovery and exhibit deadlines of 5 cale...
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 4 EXHIBIT_START
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
Exhibit A: 2™confirmation from Petitioners attorney confirming discovery completion and Production Inventory produced Copy from re:SearchTX
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 5 EXHIBIT_CONTINUATION
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
1/17/26, 1:40 PM Gmail - Fwd: Discovery Gwen Ulijasz <gulijasz@gmail.com> Gmail Fwd: Discovery message Gwen Ulijasz <guliiasz@gmail.com> Sat, Jan 10, 2026 at 2:30 PM To: gulijasz@gmail.com Jason Below is a complete , organized excel inventory of all discovery materials previously produced in this matter. This was last provided on Oct 10 and many times prior. Two pages were missing from two different months on my Chase account. They are again attached. | confirmed that you had access to the drop box Cooke Law where copies of 101+ documents I've provided t...
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 6 EXHIBIT_START
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
1/17/26, 1:40 PM Gmail - Fwd: Discovery (214) 520-7494 escroaains@sullivancock.com Thank you, Gwen Ulijasz Thank you, Gwen Ulijasz 3 attachments 2025-10-09 Exhibit A - Discovery Log.xIsx Dec 2024 Page 3.pdf 1139K Page 3.pdf = Nov1139K2024 https://mail.google.com/mail/u/0/7ik=546a93Ocb5&view=pt&search=all&permthid=thread-f: 8538906906 | 8699987%7Cmsp-f: 1853963 133834107797&simpl=msg-... 2/2 Copy from re:SearchTX
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 7 EXHIBIT_START
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
EXHIBIT A GWEN'S PRODUCTION Description Start End Date Produced Responsive To RFP 2022-06-22 AdvantiGen Subscription Agreement.pdf GU600001 'GU000002 2/24/25 1A 2023-03-19 AdvantiGen Subscription Ag:reement pdf GU000003 GU000004 22425 TA 2024 AIG 401(k).pdf GU00000S Gu000010 2/24/25 IA 2024 AMEX Platinum x6008 Statements pdf Guoo00t GU000031 2/24/25 IA 2024 Chase Acct x3898 SStalernents pdf GU000032 GU000075 2/24/25 IA 2024 Chase Acct x6893 Statements pdf GU000076 GU000105 22425 IA 2024-07 throuyh 2025-01 Chase Saphire x2372.pdf GU000106 GU000126 2/24/25...
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 8 EXHIBIT_CONTINUATION
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
My Holdings All RSUs and Stock w. vesting she s Final.pdf GU001338 GU001352 6/23/25 1,312 New CC Account PaidOffFinal.pdf GUG01353 GU001356 6/23/25 12 Payment to IRS for 2024 Taxes.pdf GU001357 GU001357 6/23/25 12 Pictures of Software and Jason.pdf GU001358 GU001595 6/23/25 12,13 Promisorry Note.pdf GU001596 GU001597 6/23/25 4,12 Statements pdf GU001598 GU001650 6/23/25 1, 10, 12, 15 Texts with Sisterpdf GU00I651 GU001656 6/23/25 5, 11, 12 Tracking Devices Final.pdf GU001657 GU001662 6/23/25 12 ULIJASZ LETTER - Procedure.pdf. GU001663 GU001663 62325 7,12...
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 9 EXHIBIT_CONTINUATION
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
ACCOUNT ACTIVITY (CONTINUED) Date of Transaction Merchant Name or Transaction Description $ Amount 10/25 WWW.WAGGINWATER.COM WWW.WAGGINWAT IL 69.00 « 10/25 EATZI'S - OAK LAWN DALLAS TX 166.19 10/26 NOHEMY TEAROOM DALLAS TX 16.78 10/25 TM "LANE 800-653-8000 CA 105.70 10/26 7-ELEVEN 32924 DALLAS TX 41.78 10/26 7-ELEVEN 32924 DALLAS TX 39.95 10/25 & SLING.COM 888-363-1777 CO 79.01 10/26 FORESTWOOD ANTIQUE MALL DALLAS TX 150.47 10/27 & KASA YOGA DALLAS 972-7465991 TX 280.00 10/28 VZWRLSS*APOCG VISN 800-922-0204 FL 321.60 10/28 7-ELEVEN 50711 HTTPSWWW.7ELE TX...
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 10 EXHIBIT_CONTINUATION
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
ACCOUNT ACTIVITY (CONTINUED) Date of Transaction Merchant Name or Transaction Description Amount 10/25 WWW.WAGGINWATER.COM WWW.WAGGINWAT IL 69.00 10/25 EATZI'S - OAK LAWN DALLAS TX 166.19 10/26 NOHEMY TEAROOM DALLAS TX 16.78 10/25 TM "LANE 800-653-8000 CA 105.70 10/26 7-ELEVEN 32924 DALLAS TX 11.78 10/26 7-ELEVEN 32924 DALLAS TX 39.95 10/25 & SLING.COM 888-363-1777 CO 79.01 10/26 FORESTWOOD ANTIQUE MALL DALLAS TX 150.47 40/27 & KASA YOGA DALLAS 972-7465991 TX 280.00 40/28 VZWRLSS*APOCC VISN 800-922-0204 FL 321.60 10/28 7-ELEVEN 50711 HTTPSWWW.7ELE TX 40....
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 11 EXHIBIT_CONTINUATION
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
ACCOUNT ACTIVITY (CONTINUED) Dale of Transaction Merchant Name or Transaction Description Amount 1125 & SLING.COM 888-363-1777 CO 79.01 41/25 & TST*HARVEY HOUSE Madison WI 162.61 1127 & AO ROSEMONT Rosemont IL 785.25 11126 & IONOS inc. 877-4612631 PA 12.00 11/25 & FIVE CBD 855-6760226 CA 59.49 41/26 & KROGER #0528 DALLAS TX 10.98 41/27 & Burberry Ltd Rosemont IL 820.26 41/26 & 7-ELEVEN 32924 DALLAS TX 40.00 W127 & Zadig0467 Chicago Out Rosemont IL 242.14 11/26 & ARMED SERVICES YMCA ASYMCA.ORG VA 90.00 11/26 & KROGER #0528 DALLAS TX 29.30 14/26 & 7-ELEVEN...
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 12 EXHIBIT_START
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
Exhibit B: Sept 23, 2025: First confirmation from Petitioner's attorney regarding Discovery Completion Copy from re:SearchTX
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 13 EXHIBIT_START
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
0442) A ail | 1417126, 944 AM Exhibit B: First Confirmation from Petitioner's Attorney Regarding Discovery Completion - [3] FW: Subject: Court-Ordered Financials Immediate Production Required... From @ Ethan Scroggins <esciogyins@sullivancock.com> vw ©3 Sep 23, 2025 To will Cook v a & Oo FYI ETHAN SCROGGINS Sullivan & Cook LLC Altforney 600 East Las Colinas Blvd, Suite 1300 Irving, TX 75039 (214) 520-7494 escroggins@sullivancook.com Mr. McKemie, The Court directed and made sure that production would be made in response to legitimate and reasonable reques...
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 14 EXHIBIT_CONTINUATION
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
(1442) All mail 1/17/26, 9:44 AM if you have identified specific instances of missing pages in statements, provide those specific instances. You cannot just state that the entire production is incomplete while ignoring what we have produced. | will not address the arguments you are making about community property and separate property in this ergail. That is a matter for the Court and an issue for final trial. Sincerely, ETHAN SCROGGINS Sullivan & Cook LLC Attorney 600 East Las Colinas Blvd, Suite 1300 Irving, TX 75039 (214) 520-7494 escroggins@sullivanc...
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 15 EXHIBIT_START
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
Exhibit C: HSA compliance Copy from re:SearchTX
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 16 EXHIBIT_CONTINUATION
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
Petitioners Notice of Compliance with Court Order (Health Insurance & Health Savings Account access) CASE DF-24-18010 IN THE MATTER OF THE MARRIAGE OF GWENDOLYN ULIJASZ, Petitioner AND JASON McKEMIE, Respondent PETITIONER'S NOTICE OF COMPLIANCE WITH COURT ORDER Petitioner files this Notice to confirm compliance with the Court's order regarding reinstatement of health insurance coverage and delivery of the Health Savings Account (HSA) card. Petitioner confirms that health insurance coverage has been reinstated as directed by the Court. Petitioner was aler...
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 17 EXHIBIT_CONTINUATION
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
No separate HSA portal is available for dependents to the best of Petitioner's knowledge. A portal and a password is not required to utilize the physical HSA card for qualified expenses, whether in person or online. To ensure proper documentation and avoid tax and penalties, Respondent may submit receipts for qualified medical expenses by email to Petitioner, consistent with the process previously used by the parties but in a timely manner. Petitioner requests the Court's awareness that this has been an issue in the past resulting in tax and penalities....
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 18 EXHIBIT_START
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
Exhibit A1: and clarification from Accountability Petitioner's HR Re: (employer) Respondent's Insurance issue Copy from re:SearchTX
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 19 EXHIBIT_CONTINUATION
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
Ulijasz, Gwen From: Pott, Wynn E. Sent: Friday, December 19, 2025 1:35 PM To: Ulijasz, Gwen Subject: Benefits Coverage Hi Gwen. As we discussed, your husband (Jason McKemie) was mistakenly dropped from coverage due to a misunderstanding at our Benefits Center. It appears they thought your husband was no longer eligible for coverage, so contrary to your wishes, they terminated coverage. | have directed them to reinstate coverage, with no gap in care, and asked them to send urgent eligibility updates to our medical and pharmacy vendors. It may still take a...
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 20 EXHIBIT_START
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
Exhibit A: Proof Jason is on the HSA account Copy from re:SearchTX
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 21 EXHIBIT_CONTINUATION
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
H story Bookmarks W ndow He p; n a an10 2:46PM TESS N mybenefits.inspirafinancial.com @ Oe A A w+© Apple Q Bing G Google Yahoo Login for Individuals | Inspira Financial Dependents Inspira Financial |s| Account Settings 03 Aetna Member Website [2 Logout @ Howe © insplraCud @ Help&Support & inspira Your Atcvms wv Alerts Aralth|Pisn Chaim 5, Forms + Health Account Saving (HSA) Dependents Account notifications This is the list of eligible dependents you think may use your Health Savings Account (HSA) funds. Health plan claims You can add, edit or remove your...
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 22 EXHIBIT_START
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
Exhibit B: New cards were needed and ordered for both parties (12/18/25) Copy from re:SearchTX
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 23 EXHIBIT_CONTINUATION
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
Ulijasz, Gwen From: Inspira <eNotify@inspirafinancial.com> Sent: Thursday, December 18, 2025 10:20 PM To: Ulijasz, Gwen Subject: [External] Inspira Financial Confirmation: Your debit card External email. Inspect before opening any links or attachments. Dear GWENDOLYN, This notice confirms we received your request for an Inspira debit card. e if you made this request, you don't need to do anything else. e If you didn't make this request, email us immediately at accountsecuritv@inspirafinancial.com. Sincerely, Inspira Financial Inspira Financial Health, In...
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 24 EXHIBIT_START
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
Exhibit C: Proof no or password anything further needed from Petitioner to use the account funds Copy from re:SearchTX
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 25 EXHIBIT_CONTINUATION
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
Safari File Edit View History Bookmarks Window Help ) ® Q & Jan 11 11:38AM $4 € > A A + mybenefits.inspirafinancial.com eC,Jr @ @ Apple Q Bing G Google Yahoo Login for Individuals Inspira Financial Frequently Asked Questions (FAQs) Inspira Financial A Member Website Account Settings B Aetna B Logout @ Home © InspiraCard @ Help&Support © FINANCIAL inspira Yoru Avert 7 your Card will De activated. After I activate my card, when can I start using it to pay for eligible expenses? You can use your card as soon as you activate it. But you'll need to have funds...
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 26 EXHIBIT_START
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
Exhibit D: Proof Jason has card use authorization Copy from re:SearchTX
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 27 EXHIBIT_CONTINUATION
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization requiredOCR warning
Copy from re:SearchTX
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 28 EXHIBIT_CONTINUATION
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
B® Jan10 2:51PM 8 © @ & Q View History Bookmarks Window Help ww t r Q mybenefits.inspirafinancial.com x @ Om A A & + < > Uy eeo M- é Apple Q Bing G Google Yahoo Login for Individuals Inspira Financial | | InspiraCard | Inspira Financial Account Settings Aetna Member Website CB Logout tf Home © InspiraCard @ Help&Support © -- inspira Alerts ve Account settings My Inspira Card™ My profile You can view the status of your Inspira Card. And you can order a card for your spouse or Bank accounts dependent. n O Account notifications Q Accentu re LLP ACN FSA Heal...
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 29 EXHIBIT_START
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
Exhibit E: Insurance Card and Jason has copies proof insurance (date stamp/name appears) Copy from re:SearchTX
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 30 EXHIBIT_CONTINUATION
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
...a nc. - Texas(DEN) Submit Claims To: PO BOX 981106 EL PASO TX 79998 1106 W.aetna.com See your plan documents for all plan requirements, including precertification. In an emergency, seek care immediately or call 911. This card does not guarantee coverage. Feedback https://healthaetna.com/id-cards 1/5 Copy from re:SearchTX
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 31 EXHIBIT_CONTINUATION
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
- Aetna 1/10/26, 10:00 PM ID Cards Effective date: eaetna 01/01/2026 Member ID#: W2903 70360 Member: Gwendolyn L Ulijasz Group #: 0657455-055-00004 Member Services: 1-800-525-4207 http://www.aetna.cony Note: This card does not guarantee coverage AETNA P.O. BOX 14094 LEXINGTON, KY 40512-4094 Payer ID# 60054 148 https://healthaetna.com/id-cards 2/5 Copy from re:SearchTX
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 32 EXHIBIT_CONTINUATION
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
...) Dental Aetna Inc. - Texas(DEN Submit Claims To:PO BOX 98 106 EL PASO TX 79998 1106 See your plan documents for all plan requirements, including precertification. in an emergency, seek care immediately or call 911. This card does not guarantee coverage. https://healthaetna.com/id-cards 3/5 Copy from re:SearchTX
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 33 EXHIBIT_CONTINUATION
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
- Aetna 1/10/26, 10:00 PM ID Cards Effective date: eaetna 01/01/2026 Member ID#: W2903 70360 Member: Jason E Mckemie Group #: 0657455-055-00004 Member Services: 1-800-525-4207 http://www.aetna.cony Note: This card does not guarantee coverage AETNA P.O. BOX 14094 LEXINGTON, KY 40512-4094 Payer ID# 60054 148 https://healthaetna.com/id-cards AIS Copy from re:SearchTX
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RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR AC

#184 2026-01-20 Respondent / Jason Miscellaneous Event Page 34 FILING_STAMP_OR_ESERVICE
NOTICE OF DISCOVERY COMPLIANCE_53B2EECC.pdf
ConfirmedHealthcareEmergencyFinancial ReliefDue Process FailuresParity / Status QuoFalse NarrativesAttorney Gamesmanship
StatusEmergency motion / stabilization required
on the date and to the persons listed below. The rules governing Envelope ID: 110194281 Filing Code Description: Miscellaneous Event Filing Description: RESPODENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, EQUEST FOR REMOTE APPEARANCE, REQUEST FOR ACESS TO PERSONAL PROPERTY, REQUEST FOR CONSOLIDATION & HEARING LIMITS AND CASE MANAGEMENT CLARIFICATION Status as of 1/22/2026 10:36 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 1/19/2026 9:02:38 AM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.co...
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EMERGENCY MOTION TO TEMORARY STAY OR IN THE ALTERNATIVE , IMPOSE PROTECTIVE CONDITIONS ON COURT-AUTHORIZ

#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
ConfirmedHealthcareEmergencyDiscovery ViolationsFinancial ReliefDue Process Failures
StatusEmergency motion / stabilization required
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...
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EMERGENCY MOTION TO TEMORARY STAY OR IN THE ALTERNATIVE , IMPOSE PROTECTIVE CONDITIONS ON COURT-AUTHORIZ

#173 2026-01-12 Respondent / Jason Motion - Miscellaneous IN Page 2 PLEADING_BODY
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
ConfirmedHealthcareEmergencyDiscovery ViolationsFinancial ReliefDue Process Failures
StatusEmergency motion / stabilization required
...list identifying 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
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EMERGENCY MOTION TO TEMORARY STAY OR IN THE ALTERNATIVE , IMPOSE PROTECTIVE CONDITIONS ON COURT-AUTHORIZ

#173 2026-01-12 Respondent / Jason Motion - Miscellaneous IN Page 3 PLEADING_BODY
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
ConfirmedHealthcareEmergencyDiscovery ViolationsFinancial ReliefDue Process Failures
StatusEmergency motion / stabilization required
...possession, Respondent requests an order expressly prohibiting Petitioner from entering the premises or removing any personal or marital property, and directing that any EMERGENCY MOTION TO TEMPORARILY STAY 3of5 DF-24-18010 Copy from re:SearchTX
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EMERGENCY MOTION TO TEMORARY STAY OR IN THE ALTERNATIVE , IMPOSE PROTECTIVE CONDITIONS ON COURT-AUTHORIZ

#173 2026-01-12 Respondent / Jason Motion - Miscellaneous IN Page 4 PLEADING_BODY
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
ConfirmedHealthcareEmergencyDiscovery ViolationsFinancial ReliefDue Process Failures
StatusEmergency motion / stabilization required
...hese recurring allegations have placed Respondent at repeated risk of law-enforcement involvement and false accusation. 16. FIREARM NOW PRESENT IN THE FACTUAL LANDSCAPE. EMERGENCY MOTION TO TEMPORARILY STAY 4of5 DF-24-18010 Copy from re:SearchTX
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EMERGENCY MOTION TO TEMORARY STAY OR IN THE ALTERNATIVE , IMPOSE PROTECTIVE CONDITIONS ON COURT-AUTHORIZ

#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
ConfirmedHealthcareEmergencyDiscovery ViolationsFinancial ReliefDue Process Failures
StatusEmergency motion / stabilization required
...5208 (214) 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
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EMERGENCY MOTION TO TEMORARY STAY OR IN THE ALTERNATIVE , IMPOSE PROTECTIVE CONDITIONS ON COURT-AUTHORIZ

#173 2026-01-12 Respondent / Jason Motion - Miscellaneous IN Page 6 PLEADING_BODY
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
ConfirmedHealthcareEmergencyDiscovery ViolationsFinancial ReliefDue Process Failures
StatusEmergency motion / stabilization required
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...
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EMERGENCY MOTION TO TEMORARY STAY OR IN THE ALTERNATIVE , IMPOSE PROTECTIVE CONDITIONS ON COURT-AUTHORIZ

#173 2026-01-12 Respondent / Jason Motion - Miscellaneous IN Page 7 PLEADING_BODY
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
ConfirmedHealthcareEmergencyDiscovery ViolationsFinancial ReliefDue Process Failures
StatusEmergency motion / stabilization required
...11. Preservation 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
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EMERGENCY MOTION TO TEMORARY STAY OR IN THE ALTERNATIVE , IMPOSE PROTECTIVE CONDITIONS ON COURT-AUTHORIZ

#173 2026-01-12 Respondent / Jason Motion - Miscellaneous IN Page 8 PLEADING_BODY
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
ConfirmedHealthcareEmergencyDiscovery ViolationsFinancial ReliefDue Process Failures
StatusEmergency motion / stabilization required
...s previously been permitted multiple opportunities to retrieve personal property, which did not resolve the issue and increased disputes. Under the present circumstances EMERGENCY MOTION TO TEMPORARILY STAY 3 0f 4 DF-24-18010 Copy from re:SearchTX
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EMERGENCY MOTION TO TEMORARY STAY OR IN THE ALTERNATIVE , IMPOSE PROTECTIVE CONDITIONS ON COURT-AUTHORIZ

#173 2026-01-12 Respondent / Jason Motion - Miscellaneous IN Page 9 PLEADING_BODY
MOTION STAY PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY_52A3AB61.pdf
ConfirmedHealthcareEmergencyDiscovery ViolationsFinancial ReliefDue Process Failures
StatusEmergency motion / stabilization required
.... G. CONTINUING 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
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EMERGENCY MOTION TO TEMORARY STAY OR IN THE ALTERNATIVE , IMPOSE PROTECTIVE CONDITIONS ON COURT-AUTHORIZ

#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
ConfirmedHealthcareEmergencyDiscovery ViolationsFinancial ReliefDue Process Failures
StatusEmergency motion / stabilization required
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...
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EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS

#175 2026-01-12 Respondent / Jason Motion - Stay Page 1 PLEADING_START_FILE_MARKED
EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS_BEE80C57.pdf
ConfirmedHealthcareEmergencyDiscovery ViolationsFinancial ReliefDue Process Failures
StatusEmergency motion / stabilization required
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...
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EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS

#175 2026-01-12 Respondent / Jason Motion - Stay Page 2 PLEADING_BODY
EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS_BEE80C57.pdf
ConfirmedHealthcareEmergencyDiscovery ViolationsFinancial ReliefDue Process Failures
StatusEmergency motion / stabilization required
...rt. 4. Unresolved Accounting Issues Are Not Before This Court. There are unresolved payment and accounting issues related to the tenancy that cannot be adjudicated on an emergency basis. Respondent does not ask this Court to resolve those disputes here. 5. Conditional Impossibility and Tolling. Until court-ordered funds are received, compliance with rent registry requirements is impossible through no fault of Respondent. Equity requires tolling rather than forfeiture. Ill. IRREPARABLE HARM IF EVICTION PROCEEDS 6. Irreversible Harm. Eviction during medica...
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EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS

#175 2026-01-12 Respondent / Jason Motion - Stay Page 3 PLEADING_BODY
EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS_BEE80C57.pdf
ConfirmedHealthcareEmergencyDiscovery ViolationsFinancial ReliefDue Process Failures
StatusEmergency motion / stabilization required
Respondent respectfully requests that the Court grant one or more of the following temporary, non- merits forms of relief: 10. Temporary stay of eviction proceedings, including issuance or execution of any writ of possession, during Respondent's medical incapacitation and for a short, defined period thereafter; 11. Extension of the rent registry deadline for a reasonable period to allow medical stabilization and receipt of court-ordered funds; OR, IN THE ALTERNATIVE 12. Stay of execution as to possession and personal property only, prohibiting removal du...
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EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS

#175 2026-01-12 Respondent / Jason Motion - Stay Page 4 PLEADING_BODY
EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS_BEE80C57.pdf
ConfirmedHealthcareEmergencyDiscovery ViolationsFinancial ReliefDue Process Failures
StatusEmergency motion / stabilization required
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
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EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS

#175 2026-01-12 Respondent / Jason Motion - Stay Page 5 PROPOSED_ORDER_OR_ORDER
EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS_BEE80C57.pdf
ConfirmedHealthcareEmergencyDiscovery ViolationsFinancial ReliefDue Process Failures
StatusEmergency motion / stabilization required
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...
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EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS

#175 2026-01-12 Respondent / Jason Motion - Stay Page 6 PLEADING_BODY
EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS_BEE80C57.pdf
ConfirmedHealthcareEmergencyDiscovery ViolationsFinancial ReliefDue Process Failures
StatusEmergency motion / stabilization required
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...
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EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS

#175 2026-01-12 Respondent / Jason Motion - Stay Page 7 FILING_STAMP_OR_ESERVICE
EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS_BEE80C57.pdf
ConfirmedHealthcareEmergencyDiscovery ViolationsFinancial ReliefDue Process Failures
StatusEmergency motion / stabilization required
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
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EMERGENCY MOTION ON MEDICAL HARM

#164 2026-01-12 Respondent / Jason Motion - Miscellaneous Page 1 PLEADING_START_FILE_MARKED
EMERGENCY MOTION ON MEDICAL HARM_8BE697F0.pdf
ConfirmedHealthcareEmergencyDue Process Failures
StatusEmergency motion / stabilization required
1/12/2026 5:26 AM DALLAS CO., TEXAS NOTICE: DOCUMENT CONTAINS DF-24-18010 NO. SENSITIVE INFORMATION. MARRIAGE OF & EMERGENCY MOTION FOR MEDICAL PRESERVATION, INTERIM MAKE-WHOLE RELIEF, JUDICIAL FINDINGS OF MISREPRESENTATION/IMPOSSIBILITY, CONDITIONAL SANCTIONS, AND THIRD-PARTY SUBPOENA AUTHORITY (QLE RECORDS) Respondent, Jason McKemie, files this Emergency Motion because he has suffered actual, ongoing medical harm due to abrupt loss of healthcare and prescription access, and because Petitioner's asserted "compliance" is materially inconsistent with obje...
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EMERGENCY MOTION ON MEDICAL HARM

#164 2026-01-12 Respondent / Jason Motion - Miscellaneous Page 2 PLEADING_BODY
EMERGENCY MOTION ON MEDICAL HARM_8BE697F0.pdf
ConfirmedHealthcareEmergencyDue Process Failures
StatusEmergency motion / stabilization required
Il. THE COURT ORDERED HEALTHCARE/HSA ACCESS; PETITIONER CLAIMS COMPLIANCE; FUNCTIONAL ACCESS REMAINS BLOCKED HSA access has been restored, and that Respondent can comply by uploading receipts to a portal without needing credentials. Respondent disputes those compliance claims because they conflict with objective administrator confirmations and the system's own behavior. Il]. OBJECTIVE DISCREPANCIES: PETITIONER'S "COMPLIANCE" CANNOT BE RELIED UPON A. Coverage Termination Processed as a QLE (COBRA / Decree-Upload Logic) 7. Respondent was informed by plan/e...
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EMERGENCY MOTION ON MEDICAL HARM

#164 2026-01-12 Respondent / Jason Motion - Miscellaneous Page 3 PLEADING_BODY
EMERGENCY MOTION ON MEDICAL HARM_8BE697F0.pdf
ConfirmedHealthcareEmergencyDue Process Failures
StatusEmergency motion / stabilization required
.../receipt process because it is technically impossible without access controlled and withheld by Petitioner; and 15. Respondent has suffered actual medical harm requiring emergency preservation relief. These findings are necessary to prevent future prejudice, prevent reliance on inaccurate narratives, and support interim relief pending third-party production. V. EMERGENCY MAKE-WHOLE PRESERVATION AND SUBSTITUTE PERFORMANCE (INTERIM MONEY) 16. Respondent has already suffered substantial medical harm due to loss of coverage and prescription access, including...
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EMERGENCY MOTION ON MEDICAL HARM

#164 2026-01-12 Respondent / Jason Motion - Miscellaneous Page 4 PLEADING_BODY
EMERGENCY MOTION ON MEDICAL HARM_8BE697F0.pdf
ConfirmedHealthcareEmergencyDue Process Failures
StatusEmergency motion / stabilization required
Vill. EXPRESS PRESERVATION OF LIABILITY AND CIVIL/ERISA CLAIMS 24. Respondent expressly preserves all claims and remedies against any responsible party, including Petitioner, the employer, the ERISA plan administrator, benefits vendors, and any third-party service providers. 25. Nothing in this Motion constitutes a waiver, election of remedies, admission of fault, or release of claims. IX. RELIEF REQUESTED Respondent requests the Court: A. Medical Preservation / Functional Access 1. Order immediate restoration of functional healthcare and prescription ac...
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EMERGENCY MOTION ON MEDICAL HARM

#164 2026-01-12 Respondent / Jason Motion - Miscellaneous Page 5 FILING_STAMP_OR_ESERVICE
EMERGENCY MOTION ON MEDICAL HARM_8BE697F0.pdf
ConfirmedHealthcareEmergencyDue Process Failures
StatusEmergency motion / stabilization required
5. Reserve sanctions pending third-party production and set a compliance review date. F. Grant all other relief the Court deems just. PRAYER e WHEREFORE, PREMISES CONSIDERED, Respondent prays the Court grant the requested relief. Respectfully submitted, Son [KL Jason McKemie 539 W Commerce St., Ste. 2010, Dallas, TX 75208 (214) 868-4901 | jmckemie@mckemie.net 2026. Jason McKemie EMERGECY MOTION: MEDICAL HARMS & RESERVATION OF RIGHTS 5of5 DF-24-18010 Copy from re:SearchTX
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EMERGENCY MOTION ON MEDICAL HARM

#164 2026-01-12 Respondent / Jason Motion - Miscellaneous Page 6 FILING_STAMP_OR_ESERVICE
EMERGENCY MOTION ON MEDICAL HARM_8BE697F0.pdf
ConfirmedHealthcareEmergencyDue Process Failures
StatusEmergency motion / stabilization required
on the date and to the persons listed below. The rules governing Envelope ID: 109911090 Filing Code Description: Motion - Miscellaneous Filing Description: EMERGENCY MOTION ON MEDICAL HARM Status as of 1/15/2026 12:00 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 1/12/2026 5:26:49 AM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 1/12/2026 5:26:49 AM SENT Copy from re:SearchTX
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EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER

#165 2026-01-12 Respondent / Jason Application - Temporary Restraining Order Page 1 PLEADING_START_FILE_MARKED
EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
ConfirmedHealthcareEmergencyDanger / High Risk
StatusEmergency motion / stabilization required
...DALLAS CO., TEXAS NO. DF-24-18010 NOTICE: THIS 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 & E...
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EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER

#165 2026-01-12 Respondent / Jason Application - Temporary Restraining Order Page 2 CERTIFICATE_OF_COMPLIANCE
EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
ConfirmedHealthcareEmergencyDanger / High Risk
StatusEmergency motion / stabilization required
...ng surgery) with limited functional use of one arm and unstable, nonfunctional access to prescribed medications, rendering Respondent physically unable to relocate on an emergency timeline. 4. IRREVERSIBILITY Once eviction occurs, possession is lost and property is exposed to removal or damage; later relief cannot undo that harm. 6. PETITIONER HAS NOT COMPLIED. Petitioner was required to order an HSA card in Respondent's name and provide proof (screenshot, administrator email, or sworn affidavit). Petitioner later represented that such a card was ordered...
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EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER

#165 2026-01-12 Respondent / Jason Application - Temporary Restraining Order Page 3 PLEADING_BODY
EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
ConfirmedHealthcareEmergencyDanger / High Risk
StatusEmergency motion / stabilization required
IV. IRREPARABLE HARM & WHY DELAY DEFEATS RELIEF Immediate eviction before judicial review would cause irreparable harm. Respondent's medical instability amplifies the danger of displacement and inability to move safely. Relief that is not immediately accessible will not prevent eviction because statutory deadlines expire before further review is available. A narrow TRO is necessary to preserve the status quo now. V. RELIEF REQUESTED Respondent respectfully requests that the Court: A. Compel immediate direct payment of $21,497 by 2:00pm on the Date of Sig...
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EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER

#165 2026-01-12 Respondent / Jason Application - Temporary Restraining Order Page 4 CERTIFICATE_OF_COMPLIANCE
EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
ConfirmedHealthcareEmergencyDanger / High Risk
StatusEmergency motion / stabilization required
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...
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EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER

#165 2026-01-12 Respondent / Jason Application - Temporary Restraining Order Page 5 PLEADING_BODY
EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
ConfirmedHealthcareEmergencyDanger / High Risk
StatusEmergency motion / stabilization required
CONDITIONAL FINDING OF BAD FAITH AND OBSTRUCTION The Court finds that Respondent's sworn affidavit establishes that Respondent is medically incapacitated, unable to relocate, and at risk of homelessness absent timely receipt of funds acknowledged or conceded as belonging to Respondent. In the event the opposing party fails to timely comply with a court-ordered payment obligation without good cause, and such failure foreseeably places Respondent at risk of homelessness or irreparable harm, the Court may deem such noncompliance evidence of bad faith, obstr...
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EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER

#165 2026-01-12 Respondent / Jason Application - Temporary Restraining Order Page 6 DECLARATION
EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
ConfirmedHealthcareEmergencyDanger / High Risk
StatusEmergency motion / stabilization required
VIII. NON-OFFSET Any coercive payment, accrual, or security imposed under this Order is an enforcement remedy, not a division of property, advance against community assets, or offset against Respondent's share of the marital estate. IX. 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...
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EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER

#165 2026-01-12 Respondent / Jason Application - Temporary Restraining Order Page 7 PLEADING_BODY
EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
ConfirmedHealthcareEmergencyDanger / High Risk
StatusEmergency motion / stabilization required
DF-24-18010 THE MARRIAGE OF § § & ON EMERGENCY REINSTATEMENT OF HEALTHCARE On this day, the Court considered Jason McKemie's (Respondent's) Emergency Motion regarding reinstatement of healthcare coverage. The Court finds immediate relief is necessary to prevent medical har : IT1S RDERED: |. COMPLIANCE PATH (PETITIONER MUST CHOSE AND COMPLETE ONE PATH) 1. Within twenty-four (24) hours of the signing of this Order, Petitioner shall complete one of the following two compliance paths and provide Respondent written proof of completion (email is sufficient). O...
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EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER

#165 2026-01-12 Respondent / Jason Application - Temporary Restraining Order Page 8 PLEADING_BODY
EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
ConfirmedHealthcareEmergencyDanger / High Risk
StatusEmergency motion / stabilization required
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...
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EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER

#165 2026-01-12 Respondent / Jason Application - Temporary Restraining Order Page 9 PLEADING_BODY
EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
ConfirmedHealthcareEmergencyDanger / High Risk
StatusEmergency motion / stabilization required
favor of Respondent in an amount equivalent to two (2) weeks of Petitioner's total grass compensation, including base'salary, bonuses, cashincentives, 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 acc...
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EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER

#165 2026-01-12 Respondent / Jason Application - Temporary Restraining Order Page 10 EXHIBIT_START
EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER_7476D473.pdf
ConfirmedHealthcareEmergencyDanger / High Risk
StatusEmergency motion / stabilization required
Exhibit B NO. DF-24-18010 NOTICE: THIS DOCUMENT CONTAINS SENSITIVE MATERIALS THE MARRIAGE OF 8 § § UNSWORN DECLARATION OF JASON MCKEMIE (Tex. Civ. Prac. & Rem. Code § 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 serio...
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