DF-24-18010 Litigation Record Search

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

JasonJason EE McKemieMcKemie WednesdayWednesday 539539 WW CommerceCommerce St,St, #2010#2010 FebruaryFebruary19,19,20252025 Dallas,Dallas, TXTX 75208,75208, USAUSA (214)(214) 868-4901868-4901 OfficeOffice ofof thethe AttorneyAttorney GeneralGeneral OpenOpen GovernmentGovernment SectionSection P.O.P.O. BoxBox 1254812548 Austin,Austin, TexasTexas 78711-254878711-2548 ToTo WhomWhom ItIt MayMay Concern,Concern, II amam submittingsubmitting thisthis formalformal rebuttalrebuttal totothetheCityCityofofSanSan Antonio'sAntonio’s attemptattempt toto withholdwithho...

...E-TRIAL HEARING MOTION FOR CONTINUANCE-NOTICE OF FAILED MEDIATION AND OF APRIL 7th, 2025, PRE-TRIAL HEARING • 04/14/2025 (Entry 55) — 5 pages — MOTION TO STRIKE IMPROPER EXPERT DESIGNATIONS AND TO LIMIT TESTIMONY OF OPPOSING COUNSEL • 04/24/2025 (Entry 56) — 1 page — MOTION FOR NOTICE PRIOR TO ANY DISMISSAL PROPOSED ORDER ON MOTION FOR NOTICE PRIOR TO ANY DISMISSAL • 04/24/2025 (Entry 60) — 3 pages — MOTION TO DESIGNATE PRO SE REPRESENTATION AND REQUEST FOR EQUAL ACCESS • 04/24/2025 (Entry 57) — 4 pages — MOTION FOR NOTICE PRIOR TO ANY DISMISSAL NOTICE P...

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

THE MARRIAGE OF GWENDOLYN ULIJASZ-MCKEMIE AND JASON MCKEMIE FINAL DECREE OF DIVORCE On June 11, 2026, the Court heard this cause. 1. Appearances Petitioner, GWENDOLYN ULIJASZ-McKEMIE ("Wife"), appeared in person and through her attorneys of record, Jonathan D. Steele and Rebecca Lee Armstrong, announced ready for trial, and proved up her case on Petitioner's pleading and supersedes all prior petitions, including the December 2024 original pleading. Respondent, JASON EMORY McKEMIE (“Husband”), previously appeared and answered pro se. The Court finds this...

...rified Emergency Supplement to the Motion to Recuse supplement to the pending recusal, due-process, healthcare, discovery, stolen-evidence, protective- order, financial, witness-suppression, and trial-integrity issues already before the Court. Respondent is filing this Supplement before any ruling on the proposed decree because once a decree is signed, the practical ability to prevent further medical, financial, evidentiary, and procedural harm is materially reduced. Because the Court is expected to determine whether to sign Petitioner's proposed decree...

...THE RECORD IS AN INVERSION OF REALITY The proposed decree is not merely unfavorable. It is the inverse of reality. Petitioner's marital timeline is false. Her financial disclosures are false or structurally unusable. Her destitution narrative is false. Her healthcare compliance is false. Her property narrative is false. Her police-report narrative is false. Her proposed decree would reward the very misconduct that manufactured Jason's collapse. This was not a situation of someone with a history of not paying bills. Respondent had a 790 credit score, mac...

...artnership, joint accounts, joint financial conduct, reciprocal powers of attorney, Ameriprise beneficiary documentation identifying the parties as spouses, and multiple witnesses, including the wedding officiant, confirming the relationship timeline. This evidence destroys the "short marriage" fiction. The decree should not be signed on a Marital timeline contradicted by signed declarations, domestic-partnership documents, powers of attorney, joint investment activity, joint accounts, beneficiary records, and witness testimony. VI. FINANCIAL ISOLATION W...

XVII. FORMER-HUSBAND WITNESS AND ACTIVE WITNESS SUPPRESSION Recent filings from Christopher McNally, Petitioner's former husband and a material witness in this case, show protective-order-extension and fee/body-attachment challenges in Cook County, Illinois. Those filings identify overlapping counsel involvement and the use of protective-order restrictions and coercive relief in a manner that impaired or chilled McNally's ability to communicate or testify. Additional filings state that fees and body-attachment pressure risked impairing his ability to tes...

...sealed in-camera exhibits, joint accounts, joint investments, domestic-partnership documents, reciprocal powers of attorney, beneficiary records, character/relationship witnesses, and a signed Declaration and Registration of Informal Marriage dated September 22, 2023. 9. The Court has been notified that healthcare/HSA/FSA/QLE/COBRA compliance remains disputed and requires third-party source verification before any decree affecting healthcare access is signed or enforced. 10.The Court has been notified that SAPD records bear on false reporting, device/tr...

...le devices, stolen computers, stolen trial binders, and stolen property; 20. deny in full Petitioner's request for fees, expenses, sanctions, costs, protective expenses, expert/vendor expenses, or fee shifting against Jason; 21.allowJasontosubmitMcNally'ssworntestimonyorunsworndeclarationandsupplemental exhibit pinpoints before decree signature; 22. order release or advancement of sufficient estate funds for Jason to obtain bodycam/dashcam footage, transcripts, medical continuity, COBRA, storage preservation, transportation preservation, and emergency pr...

...y person contact her, or an attempt to harass, intimidate, embarrass, or communicate with her. I provide this statement only because I have been identified as a material witness with firsthand knowledge relevant to litigation-pattern evidence, protective-order use, witness restrictions, credibility, and potential witness suppression. 1 I was previously in a long-term relationship with Gwendolyn Laura Ulijasz. Our relationship ended in or around December 2022. 2. I am aware that JJason McKemie is currently involved in divorce litigation with 3. I was subp...

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

...trial, and the recent June requests for body- attachment relief, appear calculated to disrupt my ability to comply with the subpoena and provide testimony as a material witness. 16. I have documents, records, messages, court papers, police reports, or other materials that may corroborate my testimony. 17. I Iam willing to appear for testimony, provide documents, and answer questions under oath, subject to appropriate court process and protection from any allegation that my participation is prohibited contact. I declare under penalty of perjury under the...

...ST FOR RECUSAL DELIVERY, REFERRAL, AND RULE 18a COMPLIANCE Respondent's Verified Motion to Recuse was submitted before any evidence was offered by Respondent, before any witness was called by Respondent, before any exhibit was offered by Respondent, before any testimony was taken from Respondent, and before Respondent consented to any trial evidence, prove-up, rendition, decree, or final order in his absence. Respondent requests immediate compliance with Texas Rule of Civil Procedure 18a, including delivery, referral, written ruling, and written or on-th...

Respondent does not agree to the proposed decree in form or substance. Respondent objects to all recitals, findings, property awards, debt allocations, account awards, healthcare/HSA/benefits provisions, injunctions, domain-name provisions, social-media provisions, separate-property findings, community-estate findings, default findings, enforcement provisions, divestiture provisions, and global denial provisions contained in Petitioner's proposed decree. Respondent specifically objects that Petitioner's proposed decree recites that Respondent "failed to...

without stolen evidence repositories, and without meaningful litigation infrastructure because of the manufactured collapse described in Respondent's filings. IX. NON-WAIVER Respondent does not waive any objection, claim, defense, request, relief, sanctions request, contempt request, mandamus issue, appellate issue, civil claim, criminal-referral issue, attorney-misconduct issue, healthcare-obstruction issue, source-record issue, stolen-evidence issue, financial-sabotage issue, false-reporting issue, digital-intrusion issue, Rule 204 issue, protective-re...

...THE HONORABLE COURT: Respondent, Jason McKemie, files this Verified Motion to Recuse before any evidence has been offered at the June 11,2026, trial setting, before any witness has been called, before any exhibit has been offered, before any testimony has been taken, and before any trial evidence has been received. This filing is made to invoke the recusal procedure before trial evidence begins and to prevent any false record that Respondent waited until trial was underway. Respondent has repeatedly tried to give the Court the opportunity to cure struct...

...discovery, source-record, financial-relief, trial-readiness, and appellate complaints. 5. Interim ancillary protection prohibiting Gwendolyn Laura Ulijasz, her counsel, experts, vendors, investigators, agents, contractors, and anyone acting with or for her from having any access to, contact with, use of, control over, disclosure of, alteration of, deletion of, reliance upon, or benefit from Respondent's stolen hard drives, evidence repositories, legal work product, binders, paper files, financial records, medical records, trial materials, printer, print...

...rmation be sent by email to jmckemie@mckemie.net. IV. TRIAL SHOULD NOT PROCEED IN RESPONDENT'S ABSENCE Respondent objects to any trial proceeding, evidence presentation, witness testimony, exhibit admission, default-type action, prove-up, final order, decree, rendition, or adverse ruling in Respondent's absence. Respondent's absence from the courtroom is caused by medical incapacity, congestive-heart- failure symptoms, repeated hospitalization, homelessness, disconnected phone service, lack of gas resources, unsafe transportation after a recent wreck, br...

2. Fraudulent protective-order applications, false protective-order evidence, and abuse of protective-order process; 3. Fraudulent evidence submissions, fabricated evidence, altered evidence, false exhibits, and use or attempted use of stolen evidence; 4. Perjury, aggravated perjury, coordinated aggravated perjury, false sworn testimony, false declarations, and false representations to the Court; 5. Malicious prosecution, malicious use of process, and malicious continuation of proceedings, where legally available; 6. Abuse of process, itigation abuse, pr...

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

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

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

evidence-theft, protective-order, and sanctions issues. Il. SPECIFIC ISSUES PRESENTED FOR DE NOVO REVIEW Under Texas Family Code § 201.015(b), Jason specifically requests de novo review of the following issues: 1. The denial of Respondent, Jason McKemie's, Motion for Enforcement, Sanctions, Continuance, and Leave to Issue Third-Party Subpoenas. 2. The refusal or failure to consider Jason's continuance / abatement request despite the June 11, 2026, trial setting and the unresolved source-record, discovery, healthcare, stolen-evidence, and trial-readiness...

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

Petitioner be denied in full, with no later prove-up, no reserved entitlement, and no cost shifting against Jason. 18.The denial or failure to address witness-protection issues involving Christopher McNally and Jonathan Drake Steele. 19.The denial or failure to address trial-readiness defects created by incomplete financial production, blocked source-record subpoenas, missing/stolen evidence repositories, unresolved healthcare access, lack of functional litigation infrastructure, and unresolved witness-protection issues. 20.Any finding, conclusion, recom...

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

IV. THE DISTRICT JUDGE MUST HEAR EVIDENCE, NOT MERELY REVIEW THE REPORT Jason requests a full evidentiary de novo hearing. At the de novo hearing, Jason requests permission to present: 1. Jason McKemie's sworn testimony; 3. Petitioner's sworn financial materials; 4. Jonathan Drake Steele's affidavit and fee/protective-expense request; 5. production indexes and Bates logs; 6. Rule 1006 source-record summary charts; 7. missing-statement and account-continuity charts; 8. VEIP/equity/payroll/Accenture compensation records; 9. HSA/FSA/healthcare/OLE/benefits...

...o a trial-readiness finding; 4. grants or preserves Petitioner's protective order; 5. grants or preserves Petitioner's fees, costs, protective expenses, vendor expenses, expert expenses, or cost-shifting requests; 6. blocks third-party source-record verification; 7. restricts Jason's ability to obtain financial source records; 8. restricts Jason's ability to obtain QLE/benefits/HSA/FSA/healthcare source records; 9. restricts Jason's ability to obtain April 16 chain-of-custody records; 10. allows Petitioner, counsel, experts, vendors, contractors, agents,...

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

...t blocks, restricts, burdens, delays, chills, or prevents source-record verification; 8. DENY Petitioner's request for attorney's fees, court costs, protective expenses, expert/vendor expenses, discovery expenses, or any cost shifting against Jason McKemie in full, with no later prove-up, no reserved entitlement, and no cost shifting; 9. ORDER Petitioner, Jonathan Drake Steele, Rebecca L. Armstrong, Sullivan & Cook, and any attorney who certified, sponsored, presented, defended, relied upon, or attempted to shield Petitioner's financial production to app...

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

...re already raised by the filings and hearing record before or at the June 1, 2026, hearing. To the extent the Court determines that any sanctions, counsel-certification, witness-protection, healthcare- enforcement, source-record verification, or trial-readiness issue was not reached by the Associate Judge's Report, Jason requests that the Court set those issues for a separate emergency evidentiary hearing before the June 11,2026 trial setting. Jason does not waive those issues by requesting de novo review. Vill. UNSWORN DECLARATION OF JASON MCKEMIE is 53...

...though and present opposing counsel's own written communications and prior representations. | did not understand in real time that needed to immediately call myself as a witness to lay the foundation for those materials, and that issue consumed approximately fifteen minutes of the limited time available. | attempted to read, 8. Petitioner's counsel repeatedly objected "hearsay" when pleadings, records, email communications, and prior representations relevant to the issues noticed for hearing. 9. Because of the compressed time, the damaged laptop screen,...

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

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

...and lack Fzhihit G $0 HSA of available medical funds. IRS-source tax records used to verify income, tax liability, Exhibit G-1 Tax Transcripts withholding, and financial disclosures. Demonstrates repeated account/card number changes, continuity issues, Exhibit K Card Flipping and tracing obstacles. Annual Snapshots Without Inflows or Illustrates production of summary balances without underlying Exhibit L Outflows transactional support. Court findings, procedural histery, and prior discovery-related Exhibit M Associate Judge's Report determinations. Gwen...

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

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...

...letion, not compliance. That matters because the defect is not a missing page. The defect is the destruction of traceability. Petitioner has repeatedly treated financial disclosure as a tactical narrative exercise rather than a source-record obligation. The result is an estate that cannot be reconstructed from Petitioner- controlled production. Third-party source records are now the only available cure. IV. THIS IS NOT MISSING STATEMENTS; IT IS ARCHITECTED OBSTRUCTION This is not merely "missing statements." It is obstruction by an architect of the finan...

3. Credit-card balances paid off multiple times per month; 4. Significant overpayments to cards; 5. At least one card with approximately $67,000 in overpayments; 6. No reliable way to determine payment source from party-produced statements; 7. No reliable way to determine whether overpayments generated refunds, credits, transfers, or concealed liquidity; 8. No reliable account-lineage records connecting old card numbers, new card numbers, reissued cards, replacement cards, or linked accounts; 9. No single account with contiguous statements from August 20...

6.. Payroll deductions; 7.. Employer reimbursements; 8. VEIP/equity investment activity; 9. Tax withholding versus equity contribution classification; 10. IRS/tax payments; 11. Loan origination and funding; 12. San Antonio housing reimbursement; 13. Lease payoff/buyout records; 14. Legal retainer payment sources; 15.Third-partycontractorpaymentsources; or 16.April 16 theft chain of custody. Only third-party source records can do that. If Petitioner has been fully forthcoming and compliant with discovery, then this will be a simple and painless process. T...

Item Amount Total liquid asset value $195,000 Liability Effect of Mislabeling of Asset -$325,000 Total Variance in Estate Value $520,000 The net effect was the conversion of approximately $195,000 in liquid asset value into an apparent negative $325,000 liability, creating a more than half-million-dollar estate distortion. This cannot be tried on party summaries, tax emails, or screenshots. It requires employer-origin, payroll-origin, equity-plan-origin, tax-origin, and bank-origin source records. VII. VISUAL GAP CHART / RULE 1 006 SUMMARY Movant intends...

1. The accounts cannot be mapped; 2. Account numbers cannot be tied to replacement cards; 3. Payments cannot be sourced; 4. Overpayments cannot be traced; 5. Credits/refunds cannot be located: 6. Loans cannot be authenticated; 7. Tax claims cannot be verified; 8. Employer reimbursements cannot be traced; 9. Legal and contractor spending cannot be allocated; and 10.The estate cannot be reconstructed. No source records, no estate reconstruction. No estate reconstruction, no final trial. IX. SAN ANTONIO HOUSING / RENT / EXPENSE REPORTS Petitioner's San Anto...

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

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

8. Proof that any alleged loan was community debt; and 9. Proof that any loan was not used for elective cosmetic surgery, legal warfare, or litigation- adjacent spending. e Petitioner's January 7 testimony represented that certain loans had already been received. Later claims conflict with that testimony. Source records are required. E. Tax Records e Petitioner has not produced legitimate tax transcripts sufficient to verify tax claims, tax liabilities, tax payments, withholding, refunds, or the alleged tax treatment of VEIP/equity. e Emails and printout...

Category Calculation Amount Salary 1/2 of $390,000 $195,000 Annual bonus 1/2 of $49,893 $24,946.50 Rent reimbursement / lease guarantor issue reimbursement claimed $30,000 Additional dissipation / add-backs to be traced TBD Movant also asserts that approximately $650,000 went missing before the divorce proceedings and requires source-record reconstruction. These figures are not the full estate calculation. They are minimum categories proving why the estate cannot be tried without third-party records. Xil. APRIL 16 THEFT IS PART OF THE SAME PATTERN The Ap...

7. Technical work; 8. Network designs; 9. Presentations; 10.Talking points; 11.Research: 12. Music/studio materials; 13. Professional records; and 14. Data necessary to rebut Petitioner's false non-contributor narrative. Before April 16, party production was already impossible as 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 rec...

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

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...

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

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

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

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

5/29/2026 3:42 PM DALLAS CO., TEXAS NO. DF-24-18010 THE MARRIAGE OF GWENDOLYN ULIJASZ-MCKEMIE JASON MCKEMIE PETITIONER'S RESPONSE TO RESPONDENT'S MOTION FOR ENFORCEMENT, SANCTIONS, CONTINUANCE, AND LEAVE TO ISSUE THIRD-PARTY SUBPOENAS, AND COUNTER-MOTION FOR PROTECTIVE ORDER AND FOR OTHER APPROPRIATE RELIEF TO THE HONORABLE JUDGE OF SAID COURT: Petitioner Gwendolyn Ulijasz-McKemie ("Petitioner" or "Gwen") files this Response to Respondent Jason McKemie's May 26, 2026 Motion for Enforcement, Sanctions, Continuance, and Leave to Issue Third-Party Subpoenas...

subpoenas because he says the records he wants are not in his hands today. He asks to reserve sanctions, adverse inferences, estate reconstitution, property-return remedies, and April 16 remedies because he says those issues should be revisited after subpoena returns that do not yet a continuance exist. A party who sat on the discovery tools available to him cannot manufacture by pointing to the discovery he chose not to pursue. Granting the Motion would transform a final-trial setting into a new third-party investigation, without proposed subpoenas, wit...

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

...spondent's request / Record problem Requested ruling allegation Continuance ofJune 11 trial No Rule 252-compliant showing identifying (Deny continuance; specific missing witnesses, residences, preserve trial setting. expected testimony, materiality, diligence, or inability to obtain the evidence earlier. Discovery period has closed. Blanket subpoena leave No proposed subpoenas attached; no custodian, Deny leave; no new account, date-range, or category specificity; Inonparty discovery on the broad categories include "all related eve of trial. custodians,"...

...osing counsel, law firms, Protect privilege and legal retainers, consultants, investigators, and work product; deny. security, reputation, cyber, and OSINT vendors, plus witness-preparation materials and work product. Sanctions / adverse inference / Respondent expressly seeks reservation Deny present relief reconstitution pending subpoena returns and further hearing; without prejudice. predicate evidence is not before the Court. Bankruptcy / April 16/ Chapter 7 is pending; trustee is Areya Holder; No family-court findings property-return the bankruptcy o...

it, the cause of failure, that the testimony cannot be obtained from any other source, the witness's name and residence if the continuance is based on an absent witness, 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 i...

...atives. Requests for counsel's files, law-firm billing records, litigation consultants, investigators, security vendors, cyber and OSINT vendors, reputation vendors, and witness-preparation materials are presumptively privilege- sensitive and require heightened protection. See National Union Fire Ins. Co. v. Valdez, 863 S.W.2d 458 (Tex. 1993); In re National Lloyds Ins. Co., 532 S.W.3d 794 (Tex. 2017). D. Sanctions and adverse findings. Sanctions must be just, directly related to the proven misconduct, and no more severe than necessary. TransAmerican Nat...

examiner familiarity, and a reasonable likelihood that the proposed methodology will yield relevant information. In re Weekley Homes, L.P., 295 S.W.3d 309, 317-22 (Tex. 2009). E. Bankruptcy overlay. 7 trustee is Areya Holder. True and correct copies of the relevant bankruptcy orders are attached to the Affidavit of Jonathan D. Steele, and Petitioner describes them functionally here rather than by docket number alone. Those orders include an order terminating the automatic stay to permit the landlord to pursue eviction remedies; an order entered the after...

...e movant could have pursued earlier, through available procedure, is not supported by the diligence Rule 252 requires. Respondent does not identify a single missing bank witness by name, residence, or expected testimony. He does not identify an Accenture witness by name, residence, or expected testimony. He does not attach a subpoena return showing any missing witness failed to appear. He does not attach a forensic-accounting affidavit, a digital-forensic affidavit, an Accenture custodian declaration, a bank custodian declaration, IRS transcripts, or a t...

Respondent did not attach the proposed subpoenas or Rule 205.3 notices. The Court therefore cannot evaluate actual text, burden, privilege, proportionality, timing, return date, date range, account identifiers, or document categories. Instead, Respondent asks for category-level permission first and actual subpoenas later. Texas law does not require the Court to authorize an undefined investigation. More fundamentally, authorizing new nonparty discovery now would furnish the very ground for the continuance the Motion seeks. If the Court authorizes subpoen...

...$130,000 VEIP/equity investment was mislabeled as extra tax withholding, a $65,000 gain, and a $520,000 estate distortion. The Motion attaches no custodian declaration, expert report, CPA letter, tax-origin document, bank-origin tracing, or equity-plan-origin record proving that theory. Respondent's own Motion states that source records would be required to test his theory. That is a trial merits dispute, not a basis to continue trial, and certainly not a basis to reopen discovery the movant declined to pursue when it was available. G. The April 16 and...

The bankruptcy orders attached to the Steele Affidavit speak for themselves. One order terminated the automatic stay to permit the landlord to pursue forcible-detainer remedies. A second order, entered the afternoon of April 16, 2026, reinstated the automatic stay and directed that writ enforcement cease. A third order extended Respondent's move-out deadline and expressly reserved claims for rent, expenses, damages, and automatic-stay violations for separate motion or adversary proceeding. No bankruptcy order adjudicated theft, spoliation, stay violation...

...burden, unnecessary expense, harassment, annoyance, invasion of privacy and property rights, and invasion of attorney-client privilege, attorney work product, consulting-expert protections, and litigation strategy. Petitioner requests that the protective order issue regardless of the Court's disposition of Respondent's Motion, including in the event the Court grants any portion of Respondent's requested relief. A. Protection against renewed or expanded subpoena practice. Because discovery has closed and trial is imminent, Respondent should not be permitt...

...odian, litigation consultant, investigator, security vendor, communications vendor, reputation vendor, OSINT or cyber vendor, witness-preparation participant, consulting expert, or litigation-support vendor absent prior leave of Court, a specific nonprivileged relevance showing, and an express privilege and work-product protocol. C. Mutual preservation. Petitioner does not oppose mutual preservation with no findings of wrongdoing. Petitioner does oppose a continuance, blanket subpoena leave, any new nonparty discovery on the eve of trial, privilege-invas...

segregation. Petitioner requests that entitlement to fees and expenses be granted or reserved and that the amount be determined by further submission or hearing. VIII. Prayer Petitioner respectfully requests that the Court: 1. deny Respondent's request to continue the June 11, 2026 trial setting; 2. deny Respondent's request for leave to issue third-party subpoenas; 3. deny Respondent's request to modify discovery deadlines; 4. deny Respondent's request to enforce alleged prior discovery rulings absent signed orders, exact obligations, service, deadlines...

8A.in the alternative, if the Court determines that the property division portion of the June 11, 2026 trial requires coordination with the Chapter 7 trustee or further bankruptcy-court action, sever and reserve the property division portion only, with the dissolution of marriage and any matters expressly excepted from the automatic stay under 11 U.S.C. § 362(b)(2) proceeding on June 11, 2026 as scheduled; 9. award Petitioner reasonable attorney's fees, court costs, expenses, and protective expenses incurred in responding to the Motion and obtaining prot...

By: /s/ Jonathan D. Steele JONATHAN D. STEELE Page 17 of 17 Copy from re:SearchTX

on the date and to the persons listed below. The rules governing Terra Aguirre on behalf of Rebecca Armstrong Bar No. 24062589 terra@armstronglawtexas.com Envelope ID: 115516576 Filing Code Description: Response Filing Description: TO MOTION FOR ENFORCEMENT AND COUNTER MOTION FOR PROTECTIVE ORDER Status as of 6/1/2026 10:16 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Kim Jones kjones@sullivancook.com 5/29/2026 3:42:21 PM SENT Jeffrey ECook jcook@sullivancook.com 5/29/2026 3:42:21 PM SENT Tiffany Castenada tcastenada@sullivancook.c...

...ction cannot reconstruct the marital estate. Petitioner responded by asking the Court to protect her from the exact source records required to test 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, mis...