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Financial sabotage
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 2
EXHIBIT_START
Exhibit Map - Recusal Supplement.pdf
EXHIBIT INDEX AND CLICKABLE REFERENCE MAP 0 https://tinyurl.com/POExhibitIndex Index of Exhibit's with clickable links to supporting documentation. Document includes descriptions of referencd materials for context. DANE PATCHING DECLARATION https://tinyurl.com/DestructionDeclaration A Independent witness evidence regarding April 16 aftermath, destructive handling, electronics and valuables near trash, camera/security damage, and Applicant not being the dangerous actor. APRIL 16 WRIT AFTERMATH / TIMELINE / PHOTOS / VIDEOS https://tinyurl.com/WritAftermath...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 6
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
...to watch. Jason has not been allowed to stabilize. He has struggled to maintain access to medical care and prescriptions, he appears exhausted and has been under immense financial strain, and he’s endured repeated hospitalizations. We have also discussed the psychological strain of the constant police reports in both Dallas and San Antonio; and specifically him being mirandized for something when he wasn’t even in the same city when the alledged event occurred. 23. At the same time, Gwendolyn appears to have retained the benefits of the sacrifices they m...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 47
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
...osecution or Diltz, Peter Sentence Supervising Time Notes Agency In the event Defendant satisfies these conditions, State will, at the end District 18 of 18 months, move to amend the criminal charge to forfeiture violation. Attorney Months Upon such amendment, amount deposited with Clerk of Court shall be taken as a total payment for this offense. Conditions Condition Time Notes Community 75 Defendant shall perform 75 hours of uncompensated service Hours community service for a not-for-profit agency or organization unrelated to the defendant or any famil...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 48
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
the defendant to the District Attorney's office at least thirty (30) days before the expiration of this agreement. Defendant shall provide a copy of this agreement, along with the Criminal Complaint, to any counselor and sign any and all releases necessary to allow the counselor (or agency) to report compliance or lack thereof to the District Attorney's Office. Any assessments done without this agreement and the Criminal Complaint(s) being supplied to the counselor will be considered violations of this agreement and not be accepted. This agreement may be...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 54
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
SAN ANTONIO POLICE SanSan AntonioAntonio PolicePolice DepartmentDepartment ReportReport ## SAPD25041335SAPD25041335- -Offense/IncidentOffense/Incident ReportReport CoverCover SheetSheet REPORTREPORT DATEDATE // TIMETIME DISTRICTDISTRICT // SECTIONSECTION // SUBSTATIONSUBSTATION // COUNCILCOUNCIL DISTRICTDISTRICT // SCHOOLSCHOOL EVENTEVENT STARTSTART DATEDATE // TIMETIME -- EVENTEVENT ENDEND DATEDATE // TIMETIME DISTRICTDISTRICT MarMar 1,1, 20252025 19:4619:46 MarMar 1,1, 20252025 19:4719:47 -- 19:4719:47 72207220 // 7272 // PRUEPRUE OFFENSE-1OFFENSE-1 OF...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 56
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
sANfifiNsANflflNlnIn PIIIIISEPIIIIISE SanSan AntonioAntonio PolicePolice DepartmentDepartment — ReportReport ## SAPD25002158SAPD25002158 - -Offense/IncidentOffense/Incident ReportReport CoverCover SheetSheet REPORTREPORT DATEDATEI I TIMETIME DISTRICT/DISTRICT/ SECTIONSECTIONII SUBSTATIONSUBSTATION / / COUNCILCOUNCILDISTRICTDISTRICT/ / SCHOOLSCHOOL EVENTEVENTSTARTSTARTDATEDATE/ /TIMETIME ,, EVENTEVENT ENDEND DATEDATE ITIMEITIME JanJan 4,4, 20252025 09:2409:24 D'STR'CTD'STR'CT __ DecDec22,22, 2024202408:4108:41-- JanJan 4,4, 20252025 09:2509:25 72207220 // 727...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 57
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
VIV1 statedstated today,today, sheshe locatedlocated anotheranother trackingtracking devicedevice onon herher vehicle.vehicle. OnOn scene,scene,aa whitewhite airair tagtag waswas locatedlocated inin aablackblackweatherproofweatherproof casecase locatedlocated behindbehind thethe rearrear bumperbumper passengerpassengerside.side. V1VI advisedadvised videovideo footagefootageavailableavailableforfor thethe exactexactlocationlocationofof airair tag.tag. WhileWhile atat location,location, II observedobserved V1'sVI's techniciantechnician removeremove thethet...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 64
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
TORN HE KEN PAXTON ATTORNEY GENERAL OF TEXAS MarchMarch 25,25, 20252025 Mr.Mr. JamesJames KoppKopp AssistantAssistant CityCity AttorneyAttorney CityCity ofof SanSan AntonioAntonio P.O.P.O. BoxBox 839966839966 SanSan Antonio,Antonio, TexasTexas 78283-396678283-3966 OR2025-010505OR2025-010505 Re:Re: RequestRequest forfor W671378-013025.W671378-013025. DearDear Mr.Mr. Kopp:Kopp: TheThe OfficeOffice ofof thethe AttorneyAttorney GeneralGeneral hashas receivedreceived youryour requestrequest forfor aa rulingruling andand assignedassigned youryour requestreques...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 65
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
...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 withholdwithhold publicpublic recordsrecords relatedrelated to...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 66
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
...rneyattorney inin earlyearly DecemberDecember 2024.2024. SinceSince then,then, sheshe has:has: •• UsedUseda powera powerof ofattorneyattorneyto tocutcutoffoffmymyfinancialfinancialaccessaccessandandfalselyfalselyreportedreported mymy legallegal retainerretainer paymentpayment asas fraud,fraud, retractingretracting itit andand cancelingcanceling mymy creditcredit card.card. • Made• Madeatatleastleasteighteight(8)(8)falsefalse policepolice reportsreports inin andand aroundaround Dallas.Dallas. •• ContinuedContinuedfilingfilingnewnewfalsefalsereportsreportsin...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 67
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
1.1. ManufactureManufacture aa criminalcriminal chargecharge toto useuse inin familyfamily courtcourt proceedings.proceedings. 2.2. DestroyDestroy mymy careercareer andand reputationreputation byby associatingassociating mymy namename withwith falsefalse allegations.allegations. 3.3. PerpetuatePerpetuate legallegal abuseabuse andand harassmentharassment throughthrough continuedcontinued fraudulentfraudulent filings.filings. ByBy withholdingwithholding thesethese records,records, thethe CityCity ofof SanSan AntonioAntonio isis notnot onlyonly violatingviol...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 137
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
...RESPONDENT’S REQUESTS FOR RELIEF & NOTICE OF EXPONENTIALLY COMPOUNDING HARM 1. AFFIDAVITS / DECLARATIONS / CHARACTER REFERENCES 2025 • 07/10/2025 (Entry 81) — 43 pages — FINANCIAL RELIEF, ENFORCEMENT OF STANDING ORDERS, PROTECTION AGAINST PROCEDURAL ABUSE, AND HEARING ON SPOUSAL SUPPORT, LEGAL FEES, MARITAL DEBT AND EARLY LOAN REPAYMENT DUE TO MEDICAL HARDSHIP – DECLARATION OF CHRISTINA SEGURA IN SUPPORT OF JASON MCKEMIE RESPONDENT’S WARNINGS TO THE COURT, AND REQUESTS FOR RELIEF/STABILIZATION 1 of 14DF-24-18010
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 139
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
...EQUAL ACCESS PROPOSED ORDER ON MOTION TO DESIGNATE PRO SE REPRESENTATION AND REQUEST FOR EQUAL ACCESS • 06/24/2025 (Entry 66) — 8 pages — EMERGENCY MOTION FOR TEMPORARY FINANCIAL RELIEF DUE TO IMMINENT HOUSING LOSS, MEDICAL HARDSHIP EMERGENCY M/FINANCIL • 06/27/2025 (Entry 67) — 4 pages — MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPEL DISCOVERY RESPONSES MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPELL DISCOVERY RESPONSES • 06/27/2025 (Entry 69) — 5 pages — OBJECT IN MATERIAL DISCOVERY NOTICE OF MATERIAL DISCOVERY NOTICE OF MATERIAL DISCOVERY • 07/10/202...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 140
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
• 07/16/2025 (Entry 86) — 75 pages — EMERGENCY M/PRESERVE EVIDENCE AND CONTINUE TRIAL DUE TO PROCEDURAL SABOTAGE AND BREAKDOWN IN JUDICIAL OVERSIGHT • 07/16/2025 (Entry 87) — 4 pages — TO SEEK DISPROPORTIONATE DIVISION OF MARITAL ESTATE NOTICE OF INTENT SEEK DISPROPORTIONATE DIVISION OF • 07/17/2025 (Entry 85) — 5 pages — ORDER GRANTING M/SANCTIONS AND REFERRAL PROPOSED MOTION SANCTION FOR AGGRAVATED PERJURY AND FRAUD UPON THE OCURT AGAINST • 07/17/2025 (Entry 88) — 2 pages — EMERGENCY NOTICE OF COUNSEL MISCONDUCT, PRIOR COMMUNICATIONS, AND DEMAND FOR IM...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 142
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
...3 pages — REQUEST FOR TEMPORARY ORDERS NOTICE OF COURT PROCEEDING - REQUEST FOR TEMPORARY ORDERS 2025 • 06/24/2025 (Entry 66) — 8 pages — EMERGENCY MOTION FOR TEMPORARY FINANCIAL RELIEF DUE TO IMMINENT HOUSING LOSS, MEDICAL HARDSHIP EMERGENCY M/FINANCIL • 07/10/2025 (Entry 70) — 1 page — FINANCIAL RELIEF, ENFORCEMENT OF STANDING ORDERS, PROTECTION AGAINST PROCEDURAL ABUSE, AND HEARING ON SPOUSAL SUPPORT, LEGAL FEES, MARITAL DEBT AND EARLY LOAN REPAYMENT DUE TO MEDICAL HARDSHIP – ESERVED COPY OF ORDER DENYING JASON MCKEMIE'S RELIEF • 07/10/2025 (Entry 71...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 143
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
...T • 07/10/2025 (Entry 77) — 1 page — ORDER GRANTING EMERGENCY MOTION TO STAY EXECUTION OF WRIT OF POSSESSION PROPOSED ORDER/JUDGMENT • 07/10/2025 (Entry 79) — 26 pages — FINANCIAL RELIEF, ENFORCEMENT OF STANDING ORDERS, PROTECTION AGAINST PROCEDURAL ABUSE, AND HEARING ON SPOUSAL SUPPORT, LEGAL FEES, MARITAL DEBT AND EARLY LOAN REPAYMENT DUE TO MEDICAL HARDSHIP – FINANCIAL RELIEF, CONTINUANCE, ENFORCEMENT OF STANDING ORDERS • 07/10/2025 (Entry 80) — 149 pages — FINANCIAL RELIEF, ENFORCEMENT OF STANDING ORDERS, PROTECTION AGAINST PROCEDURAL ABUSE, AND HEAR...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 145
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
...CARE COMPLIANCE, REQUEST FOR REMOTE APPEARANCE, REQUEST FOR ACCESS TO PERSONAL PROPERTY, REQUEST FOR CONSOLIDATION & HEARING LIMITS, AND CASE MANAGEMENT CLARIFICATION 5. FINANCIAL RELIEF / REIMBURSEMENTS / FRAUD / RENT & STABILIZATION / STANDING OR TEMPORARY ORDERS 2025 • 06/24/2025 (Entry 66) — 8 pages — EMERGENCY MOTION FOR TEMPORARY FINANCIAL RELIEF DUE TO IMMINENT HOUSING LOSS, MEDICAL HARDSHIP EMERGENCY M/FINANCIL • 07/10/2025 (Entry 70) — 1 page — FINANCIAL RELIEF, ENFORCEMENT OF STANDING ORDERS, PROTECTION AGAINST PROCEDURAL ABUSE, AND HEARING ON...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 146
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
...M/SANCTIONS AND REFERRAL PROPOSED MOTION SANCTION FOR AGGRAVATED PERJURY AND FRAUD UPON THE OCURT AGAINST • 08/07/2025 (Entry 113) — 10 pages — EMERGENCY EX PARTE MOTION TO AUTHORIZE WITHDRAWAL FROM IRA • 10/02/2025 (Entry 115) — 1 page — LETTER • 10/02/2025 (Entry 119) — 6 pages — MOTION FOR REINSTATEMENT OF WRONGFULLY REPORTED AND WITHHELD MARITAL FUNDS • 10/02/2025 (Entry 120) — 6 pages — WAITING FOR $80.00- REQUEST • 10/02/2025 (Entry 118) — 6 pages — WAITING FOR $80.00- REQUEST • 10/19/2025 (Entry 121) — 6 pages — MOTION TO OBTAIN CERTIFIED TRANSCRI...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 147
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
• 06/27/2025 (Entry 67) — 4 pages — MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPEL DISCOVERY RESPONSES MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPELL DISCOVERY RESPONSES • 06/27/2025 (Entry 69) — 5 pages — OBJECT IN MATERIAL DISCOVERY NOTICE OF MATERIAL DISCOVERY NOTICE OF MATERIAL DISCOVERY • 07/10/2025 (Entry 72) — 1 page — ORDER ON MOTION TO COMPELL DISCOVERY AND REQUEST FOR SANCTIONS PROPOSED ORDER/JUDGMENT • 07/10/2025 (Entry 73) — 1 page — ORDER TO REOPEN A LIMITED DISCOVERY DUE TO PROCEDURAL MISCONDUCT AND OBSTRUCTION PROPOSED ORDER/JUDGMENT • 07...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 148
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
...R EQUAL ACCESS • 06/27/2025 (Entry 68) — 4 pages — NOTICE OF OBJECTION TO PROCEDURAL REENTRY AND MOTION FILING BY RESPONDENT'S COUNSEL • 07/10/2025 (Entry 70) — 1 page — FINANCIAL RELIEF, ENFORCEMENT OF STANDING ORDERS, PROTECTION AGAINST PROCEDURAL ABUSE, AND HEARING ON SPOUSAL SUPPORT, LEGAL FEES, MARITAL DEBT AND EARLY LOAN REPAYMENT DUE TO MEDICAL HARDSHIP – ESERVED COPY OF ORDER DENYING JASON MCKEMIE'S RELIEF • 07/10/2025 (Entry 71) — 2 pages — FINANCIAL RELIEF, ENFORCEMENT OF STANDING ORDERS, PROTECTION AGAINST PROCEDURAL ABUSE, AND HEARING ON SPOU...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 149
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
• 08/06/2025 (Entry 104) — 7 pages — EMERGENCY MOTION TO ABATE TRIAL SETTING AND WITHHOLD FINAL ORDERS PENDING RESOLUTION OF OUTSTANDING MOTIONS, PROCEDURAL VIOLATIONS, AND DISCOVERY COLLAPSE • 08/07/2025 (Entry 105) — 11 pages — JUDICIAL NOTICE OF UNRULED MOTIONS REQUIRING DETERMINATION PRIOR TO ANY PRETRIAL HEARING, TRIAL, OR FINAL JUDICIAL NOTICE OF UNRULED MOTIONS • 08/08/2025 (Entry 106) — 4 pages — NOTICE OF PROCEDURAL BAR TO PRETRIAL OR TRIAL SETTING AND PRESERVATION OF OBJECTION • 10/29/2025 (Entry 123) — 3 pages — STANDING REQUEST FOR COURT REPO...
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2026-06-16
Respondent / Jason
Motion - Miscellaneous
Page 4
EXHIBIT_START
DF-24-18010 - Recusal Notice_Written Ruling_Objection to Decree Action.pdf
This notice is made to preserve the record, prevent waiver, and avoid any false record that Jason acquiesced in decree action while the pending verified recusal remained unresolved or unclear. VII. REQUESTED RELIEF Jason respectfully requests that the Court: denied, granted, or referred; 2. direct the Clerk to deliver the pending verified recusal, this notice, the emergency supplement, and the supplemental exhibit map to the respondent judge and regional presiding judge; 3. withhold rendition, signature, entry, transmission, enforcement, or approval of a...
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2026-06-16
Petitioner / Gwendolyn
Order
Page 7
PROPOSED_ORDER_OR_ORDER
2026-06-16 OUR Motion to Enter Final Decree Final.pdf
...or beneficiary interest in any retirement account, IRA, brokerage account, HSA, employee-benefit plan, life-insurance policy, stock plan, deferred-compensation plan, or financial account awarded or confirmed to the other party. A. Community Property Awarded to Wife IT IS ORDERED AND DECREED that Wife, GWENDOLYN ULIJASZ-McKEMIE, is awarded the following as her sole and separate property, and Husband is divested of all right, title, interest, and claim in and to that property: W-1. The UBS Accenture VEIP/ESPP brokerage account ending in x5313, with an app...
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2026-06-16
Petitioner / Gwendolyn
Order
Page 9
PROPOSED_ORDER_OR_ORDER
2026-06-16 OUR Motion to Enter Final Decree Final.pdf
W-9. Any and all other community assets in Wife's name, possession, or control not otherwise awarded herein. B. Community Property Awarded to Husband IT IS ORDERED AND DECREED that Husband, JASON EMORY McKEMIE, is awarded the following as his sole and separate property, and Wife is divested of all right, title, interest, and claim in and to that property: H-1. Any and all bank, retirement, or investment accounts in his own name. H-2. The 2018 Jaguar F-Pace automobile, together with all keys, title documents, and equipment, subject to any indebtedness the...
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 2
PLEADING_BODY
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
...nds asserted in the prior recusals. Each recusal arose from a distinct escalation point in an increasingly severe pattern of procedural breakdown, discovery obstruction, financial concealment, healthcare interference, and trial-preparation sabotage: e Recusal No. 1 addressed the 254th District Court's failure to hear emergency relief, discovery obstruction, medical collapse, and the procedural trap created when counsel withdrew during discovery and reappeared at the discovery deadline to file blanket objections; ¢ Recusal No. 2 addressed the subsequent s...
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 5
PLEADING_BODY
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
Domestic Partnership, 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 I...
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 6
EXHIBIT_START
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
...ontrol the narrative, invade Jason's privacy, monitor his property, attack his credibility, and then ask the Court to shift fees or wipe out Jason's estate interest. The financial productions remain structurally unusable. Prior filings document missing months, missing pages, mixed-year page inserts, one-day snapshots masquerading as statements, reissued card numbers, missing account continuity, missing source records, and discovery responses that recited Bates ranges without curing the defects. No decree can be safely signed on this financial record. Vil...
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 10
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
...c vice admission and additional out-of-state counsel because the estate was already funding extraordinary litigation expenditures while Petitioner represented herself as financially distressed or destitute. Jason's request was simple: Petitioner may hire whomever she wants, but if she brings in additional out- of-state counsel and extraordinary resources, those costs must not be shifted to Jason or the estate, and local counsel sponsoring out-of-state counsel should share responsibility for misconduct, sanctions, improper service, witness suppression, or...
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2026-06-12
Respondent / Jason
Objections - Misc
Page 1
PLEADING_START
RESPONDENT'S EMERGENCY OBJECTION TO PROPOSED FINAL DECREE, NOTICE OF RECUSAL & MANDAMUS_55158B69.pdf
6/12/2026 8:31 AM CLERKTEXAS NOTICE: THIS DOCUMENT CONTAIASBISLAS THE MARRIAGE OF § § & § RESPONDENT'S EMERGENCY OBJECTION TO PROPOSED FINAL DECREE, NOTICE OF PENDING RECUSAL MATTERS, REQUEST TO WITHHOLD SIGNATURE AND ENTRY, AND NOTICE OF MANDAMUS TO THE HONORABLE COURT: Respondent Jason McKemie files this Emergency Notice of Under-Review Filings, Objection to Petitioner's Proposed Final Decree, Request for Recusal Delivery and Referral, Request to Withhold Signature and Entry, Request to Stay Enforcement, and Notice of Mandamus. This filing is made on a...
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2026-06-12
Respondent / Jason
Objections - Misc
Page 5
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY OBJECTION TO PROPOSED FINAL DECREE, NOTICE OF RECUSAL & MANDAMUS_55158B69.pdf
9. Respondent's source-record issues; 10.Respondent's Rule 204 issues; 11.Respondent'sfinancial-stabilizationandaccess-to-counselissues; 12.Respondent'ssanctions,contempt,civil-claim,attorney-misconduct,criminal-referral, and non-waiver issues. Respondent objects to any decree that uses a global catchall denial to dispose of Respondent's recusal objection, medical-incapacity objection, no-bridge objection, de novo request, healthcare/OLE/HSA/FSA issues, source-record issues, stolen-evidence issues, Rule 204 request, financial-relief requests, sanctions r...
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2026-06-12
Respondent / Jason
Objections - Misc
Page 8
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY OBJECTION TO PROPOSED FINAL DECREE, NOTICE OF RECUSAL & MANDAMUS_55158B69.pdf
Respondent further objects because he is in total financial collapse. There is no gas, no food money, no medication money, no working phone service, no available credit, no loans, no stable housing, no litigation funding, no printer, no trial materials, no access to stolen evidence repositories, and no ability to meaningfully participate unless emergency financial and litigation-access relief is entered. Respondent's financial collapse is not waiver. It is the result of Petitioner's financial strangulation, healthcare obstruction, source-record concealme...
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2026-06-12
Respondent / Jason
Objections - Misc
Page 11
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY OBJECTION TO PROPOSED FINAL DECREE, NOTICE OF RECUSAL & MANDAMUS_55158B69.pdf
...ndamus 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-relief issue, reimbursement claim, parent-loan claim, forensic-accounting request, or request for emergency survival-level financial relief, interim attorney's fees, litigation expenses, access-to-counsel relief, fee shifting, sanctions, estate reconstitution, or written findings. No decr...
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2026-06-12
Respondent / Jason
Objections - Misc
Page 15
FILING_STAMP_OR_ESERVICE
RESPONDENT'S EMERGENCY OBJECTION TO PROPOSED FINAL DECREE, NOTICE OF RECUSAL & MANDAMUS_55158B69.pdf
on the date and to the persons listed below. The rules governing Envelope ID: 116062972 Filing Code Description: Objections - Misc Filing Description: RESPONDENT'S EMERGENCY OBJECTION TO PROPOSED FINAL DECREE, NOTICE OF PENDING RECUSAL MATTERS, REQUEST TO WITHHOLD SIGNATURE AND ENTRY, AND NOTICE OF MANDAMUS Status as of 6/12/2026 12:01 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Rebecca LArmstrong rebecca@armstronglawtexas.com 6/12/2026 8:31:59AM SENT Terra Aguirre terra@armstronglawtexas.com 6/12/2026 8:31:59AM SENT Lauren N.Shaw...
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2026-06-11
Respondent / Jason
Notice Of Filing
Page 1
PLEADING_START_FILE_MARKED
NOTICE OF NON-WAIVER OF SANCTIONS, CIVIL CLAIMS, ATTORNEY MISCONDUCT CLAIMS, AND OBJECTION_2BE3851C.pdf
...ondent caused delay is false. The delay was caused by Petitioner's fraud, perjury, concealment, discovery obstruction, source-record concealment, healthcare obstruction, financial sabotage, evidence theft, trial-material theft, hard-drive theft, legal-work-product theft, false reporting, manufactured eviction, and abuse of process. Respondent expressly preserves and does not waive any claim, defense, objection, sanctions request, contempt request, enforcement request, fee objection, disciplinary complaint, criminal referral, mandamus issue, appellate iss...
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2026-06-11
Respondent / Jason
Notice Of Filing
Page 2
PLEADING_BODY
NOTICE OF NON-WAIVER OF SANCTIONS, CIVIL CLAIMS, ATTORNEY MISCONDUCT CLAIMS, AND OBJECTION_2BE3851C.pdf
...se of process, and malicious continuation of proceedings, where legally available; 6. Abuse of process, itigation abuse, procedural sabotage, and use of court process to financially, medically, reputationally, and evidentially disable Respondent; 7. Insurance fraud, false QLE conduct, healthcare obstruction, benefit interference, HSA/FSA obstruction, life insurance/AD&D obstruction, critical-illness benefit obstruction, and ERISA/EBSA-related claims or referrals; 8. Theft, civil theft, Texas Theft Liability Act claims, conversion, and return/recovery of...
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2026-06-11
Respondent / Jason
Notice Of Filing
Page 3
PLEADING_BODY
NOTICE OF NON-WAIVER OF SANCTIONS, CIVIL CLAIMS, ATTORNEY MISCONDUCT CLAIMS, AND OBJECTION_2BE3851C.pdf
15. Financial sabotage, financial strangulation, concealment or dissipation of marital assets, source-record concealment, account wipeouts, disguised transfers, false characterization of equity/investment compensation, and obstruction of estate reconstruction; 16. Manufactured eviction, concealed lease buyout, landlord/lease-buyout concealment, county court, bankruptcy, or civil remedies; 17.Attorneymisconduct,counselparticipation,former-counselparticipation,current-counsel participation, pro hac vice counsel conduct, law-firm conduct, discovery obstruct...
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2026-06-11
Respondent / Jason
Motion - Miscellaneous
Page 2
PLEADING_BODY
EMERGENCY MOTION TO ABATE, STAY OR CONTINUE TRIAL_F9183942.pdf
...or consent to final orders. 5. Order that all proceedings occur on the record with a court reporter and that no off-record trial-readiness, de novo, recusal, healthcare, financial, or evidence-theft matters be resolved without a verbatim record. 6. Preserve healthcare and prevent any final order, trial event, or decree from terminating, impairing, waiving, or rewarding obstruction of Respondent's medical coverage, HSA, FSA, critical illness coverage, life insurance, AD&D, spouse AD&D, medication access, surgery access, or plan-administrator records. 7. O...
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2026-06-11
Respondent / Jason
Motion - Miscellaneous
Page 5
PLEADING_BODY
EMERGENCY MOTION TO ABATE, STAY OR CONTINUE TRIAL_F9183942.pdf
...their separate claims may belong in separate civil litigation, but the collapse of two generations is relevant to the severity, foreseeability, and scope of Petitioner's financial sabotage and to the Court's assessment of temporary relief, fee denial, sanctions, trial readiness, and due process. HEALTHCARE OBSTRUCTION, FALSE QLE, SOURCE RECORDS, AND INABILITY TO STABLIZE IF TRIAL CONTINUES Healthcare is not a collateral issue. It is a life-safety issue. Petitioner has obstructed Respondent's access to healthcare since at least December 18, 2024. Responde...
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2026-06-11
Respondent / Jason
Motion - Miscellaneous
Page 2
PLEADING_BODY
005 - DF-24-18010_FINAL_Emergency_Motion_Manufactured_Collapse_2026-06-11.pdf
...or consent to final orders. 5. Order that all proceedings occur on the record with a court reporter and that no off-record trial-readiness, de novo, recusal, healthcare, financial, or evidence-theft matters be resolved without a verbatim record. 6. Preserve healthcare and prevent any final order, trial event, or decree from terminating, impairing, waiving, or rewarding obstruction of Respondent’s medical coverage, HSA, FSA, critical illness coverage, life insurance, AD&D, spouse AD&D, medication access, surgery access, or plan-administrator records. 7. O...
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2026-06-11
Respondent / Jason
Motion - Miscellaneous
Page 5
PLEADING_BODY
005 - DF-24-18010_FINAL_Emergency_Motion_Manufactured_Collapse_2026-06-11.pdf
...their separate claims may belong in separate civil litigation, but the collapse of two generations is relevant to the severity, foreseeability, and scope of Petitioner’s financial sabotage and to the Court’s assessment of temporary relief, fee denial, sanctions, trial readiness, and due process. HEALTHCARE OBSTRUCTION, FALSE QLE, SOURCE RECORDS, AND INABILITY TO STABLIZE IF TRIAL CONTINUES Healthcare is not a collateral issue. It is a life-safety issue. Petitioner has obstructed Respondent’s access to healthcare since at least December 18, 2024. Responde...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 2
PLEADING_BODY
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...setting and the unresolved source-record, discovery, healthcare, stolen-evidence, and trial-readiness defects. 3. The denial of leave to issue third-party subpoenas for financial source records, including but not limited to bank records, credit-card records, payment-source records, overpayment/refund records, replacement-card/account-lineage records, payroll records, Accenture records, VEIP/equity records, myHoldings records, RSU records, bonus worksheets, tax transcripts, loan-funding records, GLU Distribution LLC records, San Antonio lease/reimburseme...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 15
EXHIBIT_START
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...res. Notice to Petitioner and counsel regarding discovery deficiencies, Exhibit B Discovery Email missing records, and requests for compliance. Demonstrates Respondent's financial condition, expenses, inability to Exhibit C Sworn Budget absorb continued delay, and need for relief. High Liquidity While Declaring Contradicts claims of financial hardship by showing significant Exhibit D Destitution available funds or liquidity. Exhibit E AMEX Annual Summaries Credit card spending analysis and reconstruction of financial activity, Petitioner statements minim...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 16
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...no final trial. Movant requests that the Court: 1. Continue the June 11, 2026 trial setting; 2. Grant leave to issue third-party subpoenas for source records concerning 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 the limited purpose third-party source-reco...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 20
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...simple and painless process. The source records will confirm her position quickly. If she has not, the source records are the only way to prevent a final trial based on financial fiction. VI. VEIP / EQUITY INVESTMENT MISLABELED AS "EXTRA TAX WITHHOLDING" One of the clearest examples is Petitioner's VEIP/equity investment activity. Petitioner labeled or allowed a $130,000 equity investment to be characterized as "extra tax withholding." No one can mislabel a $130,000 equity investment yielding approximately a 50% return in less - than twelve months and h...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 25
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...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 printouts are not enough. e The Court should authorize subpoenas for IRS transcripts, tax preparer records, employer payroll/tax records, bank-origin tax payments, and records sufficient to determine whether tax claims were legitimate or used to obscure equ...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 44
EXHIBIT_START
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...edit-card overpayments and alleged missing funds, such as $67,000 and $650,000 figures. Those figures appear only in Respondent's PHV-objection briefing and are not tied to any produced source document in the May 26 Motion. To the extent Respondent attempts to introduce those characterizations at this hearing, Petitioner objects on grounds including foundation, authentication, hearsay, relevance, Rule 403, and lack of competent source proof. E. The Rule 1006 chart reference is not proof. The Motion states that Respondent "intends" to attach a visual summ...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 58
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...Steele, Rebecca L. Armstrong, Sullivan & Cook, and any attorney who certified, sponsored, presented, defended, relied upon, or attempted to shield materially incomplete financial production from verification. V. PETITIONER'S PROTECTIVE ORDER IS BAD-FAITH DISCOVERY OBSTRUCTION. in n full. Petitioner's protective order should be denied Petitioner is not asking the Court to protect privileged communications. She is asking the Court to protect missing source records from being tested. She wants protection from banks, payroll custodians, Accenture, equity ad...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 59
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...is not a burden objection. It is fraud protection. VII. PETITIONER'S LOAN CLAIMS ARE NOT LOANS WITHOUT TRACEABLE FUNDS TRANSFERS. Petitioner cannot simultaneously claim financial hardship, claim the need for undocumented family loans, funnel five-figure sums into VEIP equity investments, accumulate employer-matched stock compensation, and schedule elective cosmetic procedures at a uxury aesthetic clinic. Those positions are mutually incompatible. If sufficient funds existed for equity accumulation and elective cosmetic 8 of 110 DF-24-18010 Reply in Supp...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 66
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
14. ENFORCE healthcare/HSA/FSA functionality and stabilization relief necessary to prevent further medical and financial harm; 15. REQUIRE written rulings on every item granted, denied, or reserved; 16. GRANT all other relief to which Jason McKemie is entitled. XVI. SUPPLEMENTAL UNSWORN DECLARATION OF JASON MCKEMIE is 539 W. Commerce My name is Jason McKemie. My date of birth is April 8, 1976. My address St., Suite 2010, Dallas, Texas 75208. | declare under penalty of perjury that the following is true in this filing. and correct based on my personal kno...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 68
EXHIBIT_START
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...res. Notice to Petitioner and counsel regarding discovery deficiencies, Exhibit 8 Discovery Email missing records, and requests for compliance. Demonstrates Respondent's financial condition, expenses, inability to Exhibit C Sworn Budget absorb continued delay, and need for relief. High Liquidity While Declaring Contradicts claims of financial hardship by showing significant Exhibit D Destitution available funds of liquidity. Exhibit E AMEX Annual Summaries Credit card spending analysis and reconstruction of financial activity. Petitioner statements minim...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 71
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
e Heserved discovery in good faith; e Petitioner's counsel moved to withdraw citing financial hardship; e Petitioner did not formally proceed pro se, creating service ambiguity; e With less than one hour remaining in the discovery period, counsel reappeared at 11:08 every discovery request; e Approximately one hour later, discovery was declared closed; e Trial proceeded despite unresolved discovery disputes and without complete financial disclosure. Respondent further advised Judge Jackson that there could be no fair trial absent: 1. Third-party subpoena...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 76
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...e statements 7 135 2. Motions (all) 61 807 3. Motions seeking to "compel" 7 50 4. Healthcare / Medical / HSA / Abatement or Stay / Standing or 41 507 Temporary Orders 5. Financial relief I/ reimbursements / fraud / rent / stabilization / 39 354 Standing or Temporary Orders 6. Discovery obstruction / compel / subpoenas / enforcement 24 199 7. Due process / record / ex parte / court reporter / verbatim 43 516 record / procedural fairness 8. Eviction / housing stability 10 108 1. AFFIDAVITS / DECLARATIONS / CHARACTER REFERENCES 2025 ® 07/10/2025 (Entry 81)...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 78
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
© 06/24/2025 (Entry 66) 8pages EMERGENCY MOTION FOR TEMPORARY FINANCIAL RELIEF DUE TO IMMINENT HOUSING LOSS, MEDICAL HARDSHIP EMERGENCY M/FINANCIL e 06/27/2025 (Entry 67) 4pages MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPEL DISCOVERY RESPONSES MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPELL DISCOVERY RESPONSES e 06/27/2025 (Entry 69) 5pages OBJECTIN MATERIAL DISCOVERY NOTICE OF MATERIAL DISCOVERY NOTICE OF MATERIAL DISCOVERY e 07/10/2025 (Entry 70) 1page FINANCIAL RELIEF, ENFORCEMENT OF STANDING ORDERS, PROTECTION AGAINST PROCEDURAL ABUSE, AND HEARING O...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 79
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...POSED MOTION SANCTION FOR AGGRAVATED PERJURY AND FRAUD UPON THE COURT e 07/16/2025 (Entry 86) 75 pages EMERGENCY M/PRESERVE EVIDENCE AND CONTINUE TRIAL DUE TO PROCEDURAL SABOTAGE AND BREAKDOWN IN JUDICIAL OVERSIGHT e 07/16/2025 (Entry 87) 4pages TO SEEK DISPROPORTIONATE DIVISION OF MARITAL ESTATE NOTICE OF INTENT SEEK DISPROPORTIONATE DIVISION OF e 07/17/2025 (Entry 85) 5pages ORDER GRANTING M/SANCTIONS AND REFERRAL PROPOSED MOTION SANCTION FOR AGGRAVATED PERJURY AND FRAUD UPON THE OCURT AGAINST e 07/17/2025 (Entry 88) 2pages EMERGENCY NOTICE OF COUNSEL...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 82
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...Entry 24) 3pages REQUEST FOR TEMPORARY ORDERS NOTICE OF COURT - PROCEEDING REQUEST FOR TEMPORARY ORDERS 2025 06/24/2025 (Entry 66) 8 pages EMERGENCY MOTION FOR TEMPORARY FINANCIAL RELIEF DUE TO IMMINENT HOUSING LOSS, MEDICAL HARDSHIP EMERGENCY M/FINANCIL 07/10/2025 (Entry 70) 1 page FINANCIAL RELIEF, ENFORCEMENT OF STANDING ORDERS, PROTECTION AGAINST PROCEDURAL ABUSE, AND HEARING ON SPOUSAL SUPPORT, LEGAL FEES, - MARITAL DEBT AND EARLY LOAN REPAYMENT DUE TO MEDICAL HARDSHIP ESERVED COPY OF ORDER DENYING JASON MCKEMIE'S RELIEF 07/10/2025 (Entry 71) 2 page...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 83
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
e 08/06/2025 (Entry104) 7pages EMERGENCY MOTION TO ABATE TRIAL SETTING AND WITHHOLD FINAL ORDERS PENDING RESOLUTION OF OUTSTANDING MOTIONS, PROCEDURAL VIOLATIONS, AND DISCOVERY COLLAPSE e 11/21/2025 (Entry 132) gy2 pages ORDER FOR DE NOVO REVIEW AND TRO PROPOSED ORDER/JUDGMENT e 11/21/2025 (Entry 133) 6 pages MOTION FOR DE NOVO DISTRICT JUDGE REVIEW OF PRIOR - RULINGS AND EMERGENCY APPLICATION FOR TEMPORARY RESTRAINING ORDER MOTION MISCELLANEOUS - CORRECTING FALSE e 11/25/2025 (Entry 134) 6pages NOTICE OF FILING OF SWORN AFFIDAVIT RECORDING ALLEGATIONS A...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 85
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...CARE COMPLIANCE, REQUEST FOR REMOTE APPEARANCE, REQUEST FOR ACCESS TO PERSONAL PROPERTY, REQUEST FOR CONSOLIDATION & HEARING LIMITS, AND CASE MANAGEMENT CLARIFICATION 5. Financial relief / reimbursements / fraud / rent & stabilization / standing or temporary orders 2025 06/24/2025 (Entry 66) 8 pages EMERGENCY MOTION FOR TEMPORARY FINANCIAL RELIEF DUE TO IMMINENT HOUSING LOSS, MEDICAL HARDSHIP EMERGENCY M/FINANCIL 07/10/2025 (Entry 70) 1 page FINANCIAL RELIEF, ENFORCEMENT OF STANDING ORDERS, PROTECTION AGAINST PROCEDURAL ABUSE, AND HEARING ON SPOUSAL SUPP...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 87
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
© 06/27/2025 (Entry 69) 5pages OBJECT IN MATERIAL DISCOVERY NOTICE OF MATERIAL DISCOVERY NOTICE OF MATERIAL DISCOVERY e 07/10/2025 (Entry 72) 1page ORDER ON MOTION TO COMPELL DISCOVERY AND REQUEST FOR SANCTIONS PROPOSED ORDER/JUDGMENT e 07/10/2025 (Entry 73) 1page ORDER TO REOPEN A LIMITED DISCOVERY DUE TO PROCEDURAL MISCONDUCT AND OBSTRUCTION PROPOSED ORDER/JUDGMENT e 07/10/2025 (Entry 72) 1page ORDER ON MOTION TO COMPELL DISCOVERY AND REQUEST FOR SANCTIONS PROPOSED ORDER/JUDGMENT e 07/10/2025 (Entry 73) 1page ORDER ON MOTION TO COMPEL DISCOVERY AND REQ...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 88
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...D REQUEST FOR EQUAL ACCESS 06/27/2025 (Entry 68) 4 pages NOTICE OF OBJECTION TO PROCEDURAL REENTRY AND MOTION FILING BY RESPONDENT'S COUNSEL 07/10/2025 (Entry 70) 1 page FINANCIAL RELIEF, ENFORCEMENT OF STANDING ORDERS, PROTECTION AGAINST PROCEDURAL ABUSE, AND HEARING ON SPOUSAL SUPPORT, LEGAL FEES, - MARITAL DEBT AND EARLY LOAN REPAYMENT DUE TO MEDICAL HARDSHIP ESERVED COPY OF ORDER DENYING JASON MCKEMIE'S RELIEF 07/10/2025 (Entry 71) 2 pages FINANCIAL RELIEF, ENFORCEMENT OF STANDING ORDERS, PROTECTION AGAINST PROCEDURAL ABUSE, AND HEARING ON SPOUSAL SU...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 89
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
e 07/10/2025 (Entry 80) 149pages FINANCIAL RELIEF, ENFORCEMENT OF STANDING ORDERS, PROTECTION AGAINST PROCEDURAL ABUSE, AND HEARING ON SPOUSAL SUPPORT, LEGAL FEES, - MARITAL DEBT AND EARLY LOAN REPAYMENT DUE TO MEDICAL HARDSHIP EVIDENCE AND EXHIBITS e 07/24/2025 (Entry 91) 8pages RESPONDENT VERIFIED M/RECUSE e 07/24/2025 (Entry100) 11pages EMERGENCY MOTION FOR IMMEDIATE RELIEF, OBJECTION TO TRIAL, AND REQUEST FOR ACKNOWLEDGEMENT e 08/06/2025 (Entry 104) 7pages EMERGENCY MOTION TO ABATE TRIAL SETTING AND WITHHOLD FINAL ORDERS PENDING RESOLUTION OF OUTSTAN...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 95
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...in records will allow accurate evaluation of the marital estate. IV. REQUEST FOR RELIEF | respectfully request that the Court: 1 Grant this Motion and recognize that the financial disclosures produced to date are materially incomplete and unusable; 2. Acknowledge that further supplementation cannot cure the structural defects documented in this Motion; 3. Preserve my right to immediately seek thirdparty subpoenas for native, institution- issued financial statements and transaction histories; 4. Set a short deadline for any remaining documents Petitioner...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 98
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...xx5000 (~6008, ~7006) AMEX PLATINUM xx6008 (5000, ~7006) AMEX PLATINUM xx7006 (~5000, ~6008) CIT] Advantage xx22905 INVESTMENT AND RETIREMENT ACCOUNTS AIG 401k E*TRADE STOCK / Morgan Stanley at Work / Grant number: 444637 / AUG 16TH, 2024 Empower Cognizant Technology Solutions 401k Savings Plan Vanbquard Value Index Fund / Vanguard Growth Index Accenture 401k Voya - Cognizant 401(k) Retirement Savings Plan E-Trade x8274 E-Trade x5029 E-Trade x6977 £-Trade x6587 E-Trade x201 Cognizant Tecnology 401(k) Savings Plan E-Trade Roth IRA Traditional IRA Account...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 113
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...ly statements (all pages) plus check images, wires/ACH/Zelle, and a CSV/Excel ledger. C. Retirement/equity deferrals (VEIP/ESPP) & employer match (Oct 2024-present) - 4. Payroll elections/changes Produce VEIP/ESPP election/change confirmations (Nov/Dec 2024) and any HR/benefits emails memorializing effective dates/amounts - Produce the per-pay registers showing VEIP line 5. Payroll registers/pay stubs items and tax withholdings to reconcile any entries labeled "extra tax withholding." Plan/provider postings - Provide plan statements reflecting each payro...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 134
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...under the Texas Rules of Evidence and Texas Rules of Civil Procedure. VI. BANKRUPTCY / PRETRIAL SEQUENCING Because the bankruptcy trustee's review overlaps with disputed financial issues, and because third-party institutional verification is required, the Court orders the following sequencing: A VERIFIED-RECORD FIRST The Court will prioritize receipt of third-party records authorized by this Order so that pretrial hearings and/or trial are conducted on an accurate, neutral factual record. B. CASE MANAGEMENT CONFERENCE / HEARING STRUCTURE Upon receipt of...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 142
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...counts, w; account #'s, names GLU DISTRIBUTION X8627 Statements | have recived no statements. Chase Sapphire x3444 - Aug 2025 $13,210, Chase Tracing for All Overpayments towards Credit Cards Sapphire x2372 Feb 2024 $5,796, Etc. (Lots). Need full tracing FULL Statements Released for VENMO 0UNE 2023 - PRESENT) need all Tracing for Dally Account Balances all accounts Create Contiguous Summary forall Checking Accounts contiguous with legend showing mapping to credit card swapping Tort Claim was False. Community Asset. $ requires fu" COGNIZANT SETTLEMENT trac...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 149
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...ly statements (all pages) plus check images, wires/ACH/Zelle, and a CSV/Excel ledger. C. Retirement/equity deferrals (VEIP/ESPP) & employer match (Oct 2024-present) - 4. Payroll elections/changes Produce VEIP/ESPP election/change confirmations (Nov/Dec 2024) and any HR/benefits emails memorializing effective dates/amounts - Produce the per-pay registers showing VEIP line 5. Payroll registers/pay stubs items and tax withholdings to reconcile any entries labeled "extra tax withholding." - 6. Plan/provider postings Provide plan statements reflecting each pa...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 152
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
Category Amount (S$) Frequency TV & Streaming S 250 Monthly The financial Verizon Phone S 120 Monthly disclosures T-Mobile Phone S 160 Monthly systematically Toiletries & Makeup S 80 Monthly transform assets into Dry Cleaning S 70 Monthly Charitable Contributions S 120 Monthly liabilities and wealth Hair (Quarterly) S 200 Monthly accumulation into Car Wash S 40 Monthly apparent financial Nails $ 150 Monthly Prescriptions S 30 Monthly Apple Subscriptions S 100 Monthly House Cleaning S 260 Monthly Gas S 90 Monthly Car Insurance (Semi-Annual) 267 Monthly Ca...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 158
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...x7396 (~7496) AMEX PLATINUM xx5000 (6008, ~7006) AMEX PLATINUM xx6008 (~5000, ~7006) AMEX PLATINUM xx7006 (~5000, ~6008) CITI Advantage xx2295 ZNTLS : : AIG Wik E*TRADE STOCK / Morgan Stanley at Work / Grant number: A44637 / AUG 16TH, 2024 Empower Cognizant Technology Solutions 401k Savings Plan Vanbquard Value Index Fund / Vanguard Growth Index Accenture 401k Voya - Cognizant 401(k) Retirement Savings Plan E-Trade «8274 E-Trade x5029 E-Trade x6977 E-Trade x6587 E-Trade x201 Cognizant Tecnology 401(k) Savings Plan E-Trade Roth IRA Traditional IRA Account...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 2
PLEADING_BODY
DF-24-18010 - Respondent's De Novo Hearing Request (CMP) (3).pdf
...setting and the unresolved source-record, discovery, healthcare, stolen-evidence, and trial-readiness defects. 3. The denial of leave to issue third-party subpoenas for financial source records, including but not limited to bank records, credit-card records, payment-source records, overpayment/refund records, replacement-card/account-lineage records, payroll records, Accenture records, VEIP/equity records, myHoldings records, RSU records, bonus worksheets, tax transcripts, loan-funding records, GLU Distribution LLC records, San Antonio lease/reimburseme...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 16
EXHIBIT_CONTINUATION
DF-24-18010 - Respondent's De Novo Hearing Request (CMP) (3).pdf
...no final trial. Movant requests that the Court: 1. Continue the June 11, 2026 trial setting; 2. Grant leave to issue third-party subpoenas for source records concerning 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 the limited purpose of third-party source-r...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 20
EXHIBIT_CONTINUATION
DF-24-18010 - Respondent's De Novo Hearing Request (CMP) (3).pdf
...simple and painless process. The source records will confirm her position quickly. If she has not, the source records are the only way to prevent a final trial based on financial fiction. VI. VEIP / EQUITY INVESTMENT MISLABELED AS “EXTRA TAX WITHHOLDING” One of the clearest examples is Petitioner’s VEIP/equity investment activity. Petitioner labeled or allowed a $130,000 equity investment to be characterized as “extra tax withholding.” No one can mislabel a $130,000 equity investment yielding approximately a 50% return in less than twelve months — appro...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 25
EXHIBIT_CONTINUATION
DF-24-18010 - Respondent's De Novo Hearing Request (CMP) (3).pdf
...been received. Later claims conflict with that testimony. Source records are required. E. Tax Records • 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. • Emails and printouts are not enough. • The Court should authorize subpoenas for IRS transcripts, tax preparer records, employer payroll/tax records, bank-origin tax payments, and records sufficient to determine whether tax claims were legitimate or used to obscure equ...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 44
EXHIBIT_START
DF-24-18010 - Respondent's De Novo Hearing Request (CMP) (3).pdf
...edit-card overpayments and alleged missing funds, such as $67,000 and $650,000 figures. Those figures appear only in Respondent's PHV-objection briefing and are not tied to any produced source document in the May 26 Motion. To the extent Respondent attempts to introduce those characterizations at this hearing, Petitioner objects on grounds including foundation, authentication, hearsay, relevance, Rule 403, and lack of competent source proof. E. The Rule 1006 chart reference is not proof. The Motion states that Respondent "intends" to attach a visual summ...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 58
EXHIBIT_CONTINUATION
DF-24-18010 - Respondent's De Novo Hearing Request (CMP) (3).pdf
...Steele, Rebecca L. Armstrong, Sullivan & Cook, and any attorney who certified, sponsored, presented, defended, relied upon, or attempted to shield materially incomplete financial production from verification. V. PETITIONER’S PROTECTIVE ORDER IS BAD-FAITH DISCOVERY OBSTRUCTION. Petitioner’s protective order should be denied in full. Petitioner is not asking the Court to protect privileged communications. She is asking the Court to protect missing source records from being tested. She wants protection from banks, payroll custodians, Accenture, equity admi...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 59
EXHIBIT_CONTINUATION
DF-24-18010 - Respondent's De Novo Hearing Request (CMP) (3).pdf
...is not a burden objection. It is fraud protection. VII. PETITIONER’S LOAN CLAIMS ARE NOT LOANS WITHOUT TRACEABLE FUNDS TRANSFERS. Petitioner cannot simultaneously claim financial hardship, claim the need for undocumented family loans, funnel five-figure sums into VEIP equity investments, accumulate employer-matched stock compensation, and schedule elective cosmetic procedures at a luxury aesthetic clinic. Those positions are mutually incompatible. If sufficient funds existed for equity accumulation and elective cosmetic 8 of 110DF-24-18010 Reply in Supp...
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