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Mandamus
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2026-06-16
Respondent / Jason
Motion - Miscellaneous
Page 1
PLEADING_START_FILE_MARKED
DF-24-18010 - Recusal Notice_Written Ruling_Objection to Decree Action.pdf
...ble to him. Because decree signature would materially affect property division, debt allocation, healthcare access, benefits, enforcement, sanctions, fees, and appellate/mandamus rights, Jason requests that the Court clarify the Rule 18a status before any decree action. Texas Rule of Civil Procedure 18a. 1 of 5
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2026-06-16
Respondent / Jason
Motion - Miscellaneous
Page 2
EXHIBIT_START
DF-24-18010 - Recusal Notice_Written Ruling_Objection to Decree Action.pdf
...Jason is asking the Court to confirm whether the pending verified recusal has been ruled on, referred, denied, or otherwise addressed in a manner sufficient to preserve mandamus and appellate review before any decree is signed. IV. OBJECTION TO DECREE ACTION BEFORE RULE 18a STATUS IS CLARIFIED 2 of 5
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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
...ds it may proceed under tertiary-recusal law or any other authority, state the legal basis in writing or on the record before decree action; 5. preserve Jason’s recusal, mandamus, due-process, medical-incapacity, no-bridge, healthcare, stolen-evidence, source-record, trial-readiness, sanctions, fee/cost, and appellate objections; and 6. grant all further relief necessary to preserve the record and prevent decree action before Rule 18a status is clarified. Respectfully Submitted, Jason McKemie 539 W. Commerce St., Ste. 2010 Dallas, Texas 75208 214-868-490...
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2026-06-16
Petitioner / Gwendolyn
Order
Page 1
PLEADING_START
2026-06-16 OUR Motion to Enter Final Decree Final.pdf
...ractice and Remedies Code § 30.016, which expressly authorizes the Court to continue to preside and move the case to final disposition. Respondent’s petition for writ of mandamus has not resulted in any stay. Entry of the decree is proper. II. BACKGROUND 3. This matter has been pending since December 16, 2024. 5. The Court set this case for final trial on June 11, 2026, at 1:30 p.m. 6. Petitioner and her counsel appeared and announced ready for trial. Respondent did not appear. Instead, between 1:17 p.m. and 1:46 p.m. on the day of trial, Respondent moti...
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2026-06-16
Petitioner / Gwendolyn
Order
Page 2
PLEADING_BODY
2026-06-16 OUR Motion to Enter Final Decree Final.pdf
8. At 4:28 p.m. on June 11, 2026, Petitioner sent a proposed Final Decree of Divorce to Respondent and the Court for the Court’s signature. the proposed decree (June 12, 2026) and recusal “supplements” (June 15 and June 16, (No. 05-26-00854-CV) on June 12, 2026. On June 15, 2026, the Court of Appeals returned and rejected five of the ten documents Respondent submitted in connection with that filing. No court has stayed these proceedings. III. ARGUMENT AND AUTHORITIES A. Respondent’s pending motion to recuse is a tertiary recusal motion, and Texas Civil P...
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2026-06-16
Petitioner / Gwendolyn
Order
Page 3
PLEADING_BODY
2026-06-16 OUR Motion to Enter Final Decree Final.pdf
...X. R. CIV. P. 18a(b)(1). Nothing indicates Respondent neither knew nor reasonably should have known of any asserted ground before that date. C. No stay is in effect; the mandamus filing does not divest this Court of authority. 15. The filing of a petition for writ of mandamus does not stay trial-court proceedings absent an order granting temporary relief. See TEX. R. APP. P. 52.10. No such order has issued. Undersigned counsel has confirmed the absence of any temporary-relief or stay order on the docket of the Fifth Court of Appeals in No. 05-26-00854-CV...
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 14
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
...medical continuity, COBRA, storage preservation, transportation preservation, and emergency property protection before decree action; 23. preserve Jason's objections for mandamus, appeal, due process, recusal, stolen-evidence, healthcare, discovery, source-record, sanctions, contempt, financial-relief, false-reporting, witness-suppression, and trial-readiness review. XXIII. SOURCE MAP / EXHIBITS FOR IMMEDIATE REVIEW Issue Primary source/exhibit Why it matters before decree Recusal No. 3 Verified Motion to Recuse Procedural bar/mandatory written ruling Ja...
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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
...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 an emergency basis because Petitioner's counsel transmitted a proposed...
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2026-06-12
Respondent / Jason
Objections - Misc
Page 2
PROPOSED_ORDER_OR_ORDER
RESPONDENT'S EMERGENCY OBJECTION TO PROPOSED FINAL DECREE, NOTICE OF RECUSAL & MANDAMUS_55158B69.pdf
...lief not be denied or delayed solely because exhibits are being supplemented on an emergency rolling basis due to Respondent's medical collapse, financial collapse, lack of phone service, lack of funds, stolen trial materials, stolen hard drives, stolen evidence repositories, and lack of meaningful access to litigation infrastructure. I. UNDER-REVIEW AND SUBMITTED FILINGS on June11, 2026: 1. Verified Emergency Motion to Abate, Stay, or Continue Trial, submitted June 11,2026 at 1:17:47 p.m., Envelope No. 116028476, reflected as Under Review. 2. Verified M...
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2026-06-12
Respondent / Jason
Objections - Misc
Page 3
EXHIBIT_START
RESPONDENT'S EMERGENCY OBJECTION TO PROPOSED FINAL DECREE, NOTICE OF RECUSAL & MANDAMUS_55158B69.pdf
...rove-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-the-record good-cause findings to the extent the Court contends it may proceed notwithstanding the pending verified recusal motion. Respondent specifically requests that the Clerk immediately deliver Respondent's Verified Motion to Recuse to the respondent judge and to the regional presiding judge or assigned judge as required by Rule 18a procedure. Resp...
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2026-06-12
Respondent / Jason
Objections - Misc
Page 4
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY OBJECTION TO PROPOSED FINAL DECREE, NOTICE OF RECUSAL & MANDAMUS_55158B69.pdf
...visions contained in Petitioner's proposed decree. Respondent specifically objects that Petitioner's proposed decree recites that Respondent "failed to appear," that the Court proceeded by "post-answer default," that testimony was received, and that exhibits were admitted. Respondent's physical absence was medical incapacity, not waiver, abandonment, failure to prosecute, delay, consent to trial, consent to evidence, consent to prove-up, consent to rendition, consent to decree, or consent to final orders. Respondent requested remote bridge information be...
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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
...ests, civil-claim preservation, attorney- misconduct issues, criminal-referral issues, or any other pending threshold matter without identifying those matters and making written rulings. Respondent requests that the Court decline to sign Petitioner's proposed decree, withhold entry, set aside any oral rendition made in Respondent's absence, reopen evidence, stay enforcement, and make written rulings on Respondent's pending recusal, emergency medical, no-bridge, healthcare, stolen-evidence, source-record, de novo, Rule 204, sanctions, financial-relief, an...
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2026-06-12
Respondent / Jason
Objections - Misc
Page 6
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY OBJECTION TO PROPOSED FINAL DECREE, NOTICE OF RECUSAL & MANDAMUS_55158B69.pdf
...records show that Petitioner is not merely making false reports. Petitioner is manufacturing the source material for false reports. Petitioner manufactured the eviction/writ aftermath, unlawfully entered the residence, stole property and device evidence, controlled or relocated that property, then used stolen or controlled items to manufacture new police narratives involving alleged mailed property, alleged abandoned property, tracker devices, alleged medical letters, alleged narcotics, HSA-call fraud, and other false criminal narratives. Respondent den...
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2026-06-12
Respondent / Jason
Objections - Misc
Page 7
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY OBJECTION TO PROPOSED FINAL DECREE, NOTICE OF RECUSAL & MANDAMUS_55158B69.pdf
...remain unresolved. functional benefit denial, refusal to produce the administrative record, HSA/FSA obstruction, and medical harm. Respondent has repeatedly advised this Court that healthcare is not collateral. It is life-safety. A signed healthcare order exists. Petitioner has represented compliance while functional access remained obstructed. Respondent has evidence that Petitioner produced false or nonfunctional HSA compliance, retained control over functional access, and then weaponized Respondent's attempt to obtain court-ordered healthcare access b...
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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
...ft, manufactured eviction, false reporting, and procedural abuse. Vil. REQUEST TO WITHHOLD SIGNATURE, ENTRY, ENFORCEMENT, AND DECREE EFFECTS Respondent requests that the Court immediately: 1. withhold signature and entry of Petitioner's proposed Final Decree of Divorce; 2. decline to sign Petitioner's proposed decree; 3. set aside any oral rendition made in Respondent's medical absence; 4. reopen evidence; 5. stay enforcement; 6. stay implementation, turnover, property transfer, debt allocation, healthcare/benefits effects, injunctions, domain-name trans...
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2026-06-12
Respondent / Jason
Objections - Misc
Page 9
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY OBJECTION TO PROPOSED FINAL DECREE, NOTICE OF RECUSAL & MANDAMUS_55158B69.pdf
...rotective expenses, discovery expenses, or cost shifting against Respondent based on the collapse Petitioner manufactured; 20.enterwritten rulings sufficient to preserve mandamus and appellate review. Vill. NOTICE OF MANDAMUS AND REQUEST TO SUPPLEMENT EXHIBITS Respondent is filing emergency mandamus relief in the Fifth Court of Appeals seeking immediate temporary relief staying signing, entry, enforcement, implementation, property transfer, debt allocation, healthcare/benefits effects, injunctions, fees, costs, sanctions, and all effects of Petitioner's...
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2026-06-12
Respondent / Jason
Objections - Misc
Page 10
EXHIBIT_START
RESPONDENT'S EMERGENCY OBJECTION TO PROPOSED FINAL DECREE, NOTICE OF RECUSAL & MANDAMUS_55158B69.pdf
...olice/constable records; 1 healthcare/HSA/FSA records; 12.EBSA/DOL records; 13.sourcefinancial records; 1 Accenture/Businessolver/Aetna/HSA/FSA records; 15.lease-buyout, writ, eviction, mover, U-Haul, payment, vendor, and chain-of-custody records; 16.declarations, exhibits, screenshots, location records, and related proof as available. Respondent requests that emergency protection not be denied merely because exhibits are being supplemented on a rolling basis. Respondent is medically collapsed, financially collapsed, without working phone service, withou...
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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
...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-relief issue, reimbursement claim, parent-loan claim, forensic-accounting request, or request for emergency survival-...
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2026-06-12
Respondent / Jason
Objections - Misc
Page 12
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY OBJECTION TO PROPOSED FINAL DECREE, NOTICE OF RECUSAL & MANDAMUS_55158B69.pdf
...idence, and derivative materials; 11 .allow Respondent to supplement exhibits and supporting records as soon as available; 12.enterwritten rulings sufficient to preserve mandamus and appellate review; and 13.grantallfurtherrelieftowhichRespondentisentitled. Respectfully Submitted, Jon. Jason McKemie 539 W. Commerce St., Suite 2010 Dallas, Texas 75208 214-868-4901 jmckemie@mckemie.net Respondent, Pro Se 12 of 14 Copy from re:SearchTX
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2026-06-12
Respondent / Jason
Objections - Misc
Page 13
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY OBJECTION TO PROPOSED FINAL DECREE, NOTICE OF RECUSAL & MANDAMUS_55158B69.pdf
...ion because my phone service was disconnected and | could not place outbound calls. did not receive usable bridge information sufficient to appear. | am filing emergency mandamus relief and will supplement supporting exhibits and records as soon as available. Executed in Texas on June 12, 2026. Jason McKemie 13 of 14 Copy from re:SearchTX
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2026-06-12
Respondent / Jason
Objections - Misc
Page 14
FILING_STAMP_OR_ESERVICE
RESPONDENT'S EMERGENCY OBJECTION TO PROPOSED FINAL DECREE, NOTICE OF RECUSAL & MANDAMUS_55158B69.pdf
44 Jason McKemie 14 of 14 Copy from re:SearchTX
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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
...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 lauren@armstronglawtexas.com 6/12/2026 8:31:59AM SENT Jason McKemie jmckemie@mckemie.net 6/12/2026 8:31:59AM SENT Gwendolyn Ulija...
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2026-06-11
Respondent / Jason
Motion - Recuse
Page 2
PLEADING_BODY
VERIFIED MOTION TO RECUSE AND REQUEST FOR REFERRAL_8A0E2F01.pdf
...Motion, a clear statement of the legal basis and good cause on the record before any evidence is offered. 4. Preservation of Respondent's objections, including recusal, mandamus, de novo, due process, stolen-evidence, healthcare, 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, disclosur...
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2026-06-11
Respondent / Jason
Motion - Recuse
Page 5
EXHIBIT_START
VERIFIED MOTION TO RECUSE AND REQUEST FOR REFERRAL_8A0E2F01.pdf
...Court proceeds despite this Motion, Respondent requests a clear ruling on the record and states that he appears, if at all, under objection and without waiving recusal, mandamus, de novo, due- process, healthcare, discovery, stolen-evidence, trial-readiness, financial-relief, court-reporter, or appellate complaints. Respectfully submitted, Jason McKemie 539 W. Commerce St., Ste. 2010 Dallas, TX 75208 214-868-4901 jmckemie@mckemie.net Page 5 of 6 Copy from re:SearchTX
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2026-06-11
Respondent / Jason
Miscellaneous Event
Page 2
PLEADING_BODY
SUPPLEMENTAL EMERGENCY FILING_07490B53.pdf
...onsenting to trial. Respondent is not consenting to evidence being taken in his absence. Respondent is not consenting to final orders. Respondent is not waiving recusal, mandamus, appellate rights, due process, de novo/trial- readiness issues, healthcare objections, stolen-evidence objections, discovery objections, source- record objections, court-reporter objections, or financial-relief objections. Page 2 of 7 Copy from re:SearchTX
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2026-06-11
Respondent / Jason
Miscellaneous Event
Page 5
EXHIBIT_CONTINUATION
SUPPLEMENTAL EMERGENCY FILING_07490B53.pdf
...email; 9. Rule on Respondent's recusal motion before evidence is received; 10. Rule on Respondent's emergency motion to abate, stay, or continue trial; 11. Preserve all mandamus, appellate, recusal, due-process, healthcare, stolen-evidence, discovery, source-record, court-reporter, de novo, financial-relief, and trial-readiness objections. Respondent further requests any other relief to which Respondent is entitled. Respectfully submitted, [Son fram Jason McKemie 539 W. Commerce St., Ste. 2010 Dallas, TX 75208 214-868-4901 jmckemie@mckemie.net Page 5 of...
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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
.... Respondent does not waive sanctions, contempt, enforcement, fee objections, civil claims, attorney- misconduct complaints, disciplinary complaints, criminal referrals, mandamus, appellate complaints, or independent tort claims arising from the manufactured collapse created by Gwendolyn Laura Ulijasz, her counsel, former counsel, agents, vendors, investigators, contractors, third-party actors, co- conspirators, and anyone acting with or for her. NO WAIVER OF SANCTIONS, CONTEMPT, ENFORCEMENT, OR FEE OBJECTIONS Respondent does not waive any request for sa...
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2026-06-11
Respondent / Jason
Notice Of Filing
Page 4
PLEADING_BODY
NOTICE OF NON-WAIVER OF SANCTIONS, CIVIL CLAIMS, ATTORNEY MISCONDUCT CLAIMS, AND OBJECTION_2BE3851C.pdf
...st, sanctions request, civil claim, federal benefits clair, ERISA/EBSA complaint, COBRA-related claim, HSA/FSA claim, make- whole claim, medical-harm claim, or appellate/mandamus complaint related to healthcare obstruction Petitioner obstructed healthcare access beginning no later than December 18, 2024. Petitioner cut off or obstructed medical insurance, HSA access, FSA access, critical illness coverage, ife insurance, AD&D, spouse AD&D, and related benefits. Petitioner caused or participated in a false QLE process that cut off Respondent's healthcare o...
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2026-06-11
Respondent / Jason
Notice Of Filing
Page 5
PLEADING_BODY
NOTICE OF NON-WAIVER OF SANCTIONS, CIVIL CLAIMS, ATTORNEY MISCONDUCT CLAIMS, AND OBJECTION_2BE3851C.pdf
...l claims, sanctions requests, contempt requests, attorney-misconduct complaints, criminal referrals, disciplinary complaints, healthcare claims, stolen- evidence claims, mandamus complaints, appellate complaints, or claims arising from the collapse Petitioner engineered. Respectfully Submitted, Jason McKemie 539 W. Commerce St., Ste. 2010 Dallas, TX 75208 214-868-4901 jmckemie@mckemie.net Page 5 of 6 Copy from re:SearchTX
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2026-06-11
Respondent / Jason
Motion - Miscellaneous
Page 8
PLEADING_BODY
EMERGENCY MOTION TO ABATE, STAY OR CONTINUE TRIAL_F9183942.pdf
product of medical emergency, financial strangulation, evidence theft, healthcare obstruction, and transportation impossibility - not waiver. Respondent preserves mandamus, appeal, de novo, recusal, due-process, discovery, healthcare, source-record, financial-relief, court-reporter, stolen-evidence, and trial-readiness complaints. REQUEST Respondent requests that the Court grant the relief requested above, abate, stay, or continue trial, preserve healthcare, preserve stolen evidence, prohibit Petitioner and her agents from accessing or benefiting from st...
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2026-06-11
Respondent / Jason
Motion - Miscellaneous
Page 8
PLEADING_BODY
005 - DF-24-18010_FINAL_Emergency_Motion_Manufactured_Collapse_2026-06-11.pdf
product of medical emergency, financial strangulation, evidence theft, healthcare obstruction, and transportation impossibility - not waiver. Respondent preserves mandamus, appeal, de novo, recusal, due-process, discovery, healthcare, source-record, financial-relief, court-reporter, stolen-evidence, and trial-readiness complaints. REQUEST Respondent requests that the Court grant the relief requested above, abate, stay, or continue trial, preserve healthcare, preserve stolen evidence, prohibit Petitioner and her agents from accessing or benefiting from st...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 73
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...lthcare order through verified plan-administrator confirmation or escrow replacement; 3 The Court sets a sanctions/compliance hearing prior to trial; 4. The Court enters written rulings clarifying compliance. If those actions occur, Respondent will proceed. If they do not, Respondent has no procedural remedy remaining within this Court, and recusal becomes necessary to preserve due process and appellate review. VI. VERIFIED UNSWORN DECLARATION (TEX. CIV. PRAC. & REM. CODE § 132.001) VERIFIED MOTION TO RECUSE DF-24-18010 5 2269 110 Copy from re:SearchTX
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 73
EXHIBIT_CONTINUATION
DF-24-18010 - Respondent's De Novo Hearing Request (CMP) (3).pdf
...thcare order through verified plan-administrator confirmation or escrow replacement; 3. The Court sets a sanctions/compliance hearing prior to trial; 4. The Court enters written rulings clarifying compliance. If those actions occur, Respondent will proceed. If they do not, Respondent has no procedural remedy remaining within this Court, and recusal becomes necessary to preserve due process and appellate review. VI. VERIFIED UNSWORN DECLARATION (TEX. CIV. PRAC. & REM. CODE § 132.001) VERIFIED MOTION TO RECUSE DF-24-18010 5 of2269of 110
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2026-06-01
Respondent / Jason
Response
Page 22
EXHIBIT_CONTINUATION
RESPONSE TO PETITIONER (FNL)_17D5B70E.pdf
...thcare order through verified plan-administrator confirmation or escrow replacement; 3. The Court sets a sanctions/compliance hearing prior to trial; 4. The Court enters written rulings clarifying compliance. If those actions occur, Respondent will proceed. If they do not, Respondent has no procedural remedy remaining within this Court, and recusal becomes necessary to preserve due process and appellate review. VI. VERIFIED UNSWORN DECLARATION (TEX. CIV. PRAC. & REM. CODE § 132.001) VERIFIED MOTION TO RECUSE DF-24-18010 5 of2269of 110 Copy from re:Search...
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2026-06-01
Respondent / Jason
Response
Page 22
EXHIBIT_CONTINUATION
DF-24-18010 - RESPONSE TO PETITIONER (FNL).pdf
...thcare order through verified plan-administrator confirmation or escrow replacement; 3. The Court sets a sanctions/compliance hearing prior to trial; 4. The Court enters written rulings clarifying compliance. If those actions occur, Respondent will proceed. If they do not, Respondent has no procedural remedy remaining within this Court, and recusal becomes necessary to preserve due process and appellate review. VI. VERIFIED UNSWORN DECLARATION (TEX. CIV. PRAC. & REM. CODE § 132.001) VERIFIED MOTION TO RECUSE DF-24-18010 5 of2269of 110
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2026-05-15
Filer unknown
Notice Of Hearing / Fiat 21 HEARING
Page 1
PLEADING_START_FILE_MARKED
SUPPLEMENTAL NOTICE OF TRIAL READINESS ETC_5EBF9125.pdf
...cement, subpoena leave, preservation, sanctions, fee shifting, continuance, abatement, court-reporter access, written rulings, adverse inference, exclusion, or appellate/mandamus preservation. 4. Respondent files this supplement because trial remains set for June 11, 2026, and Respondent is facing immediate survival collapse, trial-capacity collapse, missing/stolen evidence repositories, unresolved healthcare access, lack of counsel funding, and active witness-interference concerns involving Christopher McNally and newly admitted or proposed out-of-state...
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2026-05-15
Filer unknown
Notice Of Hearing / Fiat 21 HEARING
Page 11
CERTIFICATE_OF_SERVICE
SUPPLEMENTAL NOTICE OF TRIAL READINESS ETC_5EBF9125.pdf
...terial to trial readiness, financial tracing, credibility, impeachment, rebuttal, property division, sanctions, healthcare enforcement, and preservation of appellate and mandamus rights. Jason McKemie Rules of Civil Procedure on May 15th, 2026. Jason McKemie 11 of 13 DF-24-18010 Copy from re:SearchTX
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2026-05-14
Respondent / Jason
Order
Page 2
PROPOSED_ORDER_OR_ORDER
2026.05.14 Pleading History.pdf
Filing > 227 A A A A A Share of All 21-40 ‹ • •Select/Deselect Owned Owned Owned Owned Owned Owned Owned Owned Owned Owned Owned Owned Owned Owned Owned Owned Owned Price Free Free Free Free Free Free Free Free Free Free Free Free Free Free Free Free Free 3 Pages 5 2 3 3 8 3 3 24 2 4 7 38 6 34 : : : : : : : : : : : : : : ... LI... ... F... STAT... COM... PR... MOTI... IN OF OB... ORDER.... ON PRO... ISSUE... AUTHORI... COMPL... STANDING... PROPERTY OF MOTION NOTICE FORMAL UNIFIED ORDER COMPEL DISCOVERY PRIOR ORDER AMENDED VERIFIED STATUS TO PRESERVATION....
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2026-05-12
Respondent / Jason
Motion - Miscellaneous
Page 2
PLEADING_BODY
SUPPLEMENTAL MOTION STABILIZATION -OBJECTIONS TO PHV ADMISSION_02F920EF.pdf
...ndent faces imminent homelessness, loss of vehicle access, loss of phone access, utility interruption, inability to obtain medication, lack of food, lack of gas to reach court, lack of printing capacity, lack of working office equipment, and impaired ability to prepare for trial. This is not ordinary inconvenience. This is trial-capacity collapse. A party cannot meaningfully prepare for trial, review financial records, respond to new counsel, examine witnesses, organize exhibits, or preserve appellate issues while simultaneously facing homelessness, medi...
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2026-05-11
Respondent / Jason
Motion - Miscellaneous
Page 1
PLEADING_START_FILE_MARKED
MOTION WRITTTEN DISCOVERY RULINGS ETC_D0F7BBA4.pdf
5/11/2026 4:23 PM DALLAS CO., TEXAS DF-24-18010 NO. MARRIAGE OF § § § RESPONDENT'S EMERGENCY MOTION FOR WRITTEN DISCOVERY RULINGS, SUBPOENA LEAVE, EVIDENCE PRESERVATION, AND IMMEDIATE HEARING TO THE HONORABLE JUDGE OF SAID COURT: | , Respondent McKemie, Respondent pro se, files this Emergency Motion to Convert Prior Motion-to- Compel Compliance Hearings Into Written Rulings, Enforce Certified Financial Discovery, Grant Leave to Issue Third-Party Subpoenas, Preserve Evidence, and Set Immediate Hearing, and respectfully shows the Court as follows: I. EMERG...
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2026-05-11
Respondent / Jason
Motion - Miscellaneous
Page 2
EXHIBIT_START
MOTION WRITTTEN DISCOVERY RULINGS ETC_D0F7BBA4.pdf
...plicate or recycled production, editable activity exports, missing account continuity, and lack of institution-origin certified records. 12. Respondent requests that the Court enter written rulings on the prior motion-to-compel and compliance issues, including findings and enforceable deadlines. 13 Written rulings are required because oral comments, informal compliance discussions, and unresolved proposed orders cannot force production, preserve appellate review, or prevent Petitioner from continuing to claim compliance. 14. Without written rulings, Peti...
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#190
2026-02-06
Respondent / Jason
Notice Of Filing
Page 1
PLEADING_START_FILE_MARKED
NOTICE ON STATUS OF PROPOSED ORDER_9BFB63F9.pdf
...§ NOTICE REGARDING STATUS OF PROPOSED ELEVATED ORDER, RISK OF SAFETY-BASED ALLEGATIONS, AND MATTERS BEARING ON JUDICIAL MANAGEMENT AND RECORD INTEGRITY TO THE HONORABLE COURT OF THE 302ND DISTRICT COURT: Respondent, Jason McKemie, respectfully submits this Notice to advise the Court of matters bearing directly on judicial management, evidentiary integrity, and the reliability of adjudication at the present procedural stage of this case, including the status of the proposed order requested during the discovery enforcement hearing held on Thursday, Februa...
#190
2026-02-06
Respondent / Jason
Notice Of Filing
Page 3
PLEADING_BODY
NOTICE ON STATUS OF PROPOSED ORDER_9BFB63F9.pdf
...ciated with prolonged interruption of prescribed medications following the termination of health coverage. These hospitalizations occurred during the period in which the Court had ordered Petitioner to reinstate Respondent's healthcare. Although nominal coverage was only recently restored, current benefits summaries from the plan administrator reflect that HSA contributions have been reduced to de minimis levels, the FSA was terminated, and other policies (including Life, AD&D, and Critical IlIness/Critical Care) in which Respondent was a beneficiary or...
#190
2026-02-06
Respondent / Jason
Notice Of Filing
Page 5
PROPOSED_ORDER_OR_ORDER
NOTICE ON STATUS OF PROPOSED ORDER_9BFB63F9.pdf
...ed upon for fee shifting or any credibility-sensitive ruling. 4. STATUS UPDATE: PROPOSED ORDER AND UPCOMING FILINGS TO NARROW ISSUES AND PREVENT AVOIDABLE RETRIAL At the Court's direction, Respondent is completing a proposed order reflecting the Court's evaluation from the February 5 hearing and will file that proposed order promptly. In parallel, Respondent is finalizing a consolidated submission identifying specific gaps in the financial disclosures, benefits administration, and discovery record, and explaining how those omissions materially impair the...
#190
2026-02-06
Respondent / Jason
Notice Of Filing
Page 23
EXHIBIT_CONTINUATION
NOTICE ON STATUS OF PROPOSED ORDER_9BFB63F9.pdf
ACCORDINGLY, PETITIONER RESPECTFULLY REQUESTS THAT THE COURT: 1. IMMEDIATELY CONTINUE THE BENCH TRIAL To prevent further procedural and constitutional harm resulting from discovery obstruction, strategic denial of counsel, and active deprivation of due process. 2. IMMEDIATELY APPROVE EMERGENCY FINANCIAL RELIEF Approve Petitioner's emergency request for $20,000 in immediate housing and Eviction During Medical Hardship. Petitioner will be rendered homeless if this request is not ruled upon this week. 3. PRESERVE THE FOLLOWING MATERIALS AND RECORDS To ensur...
#190
2026-02-06
Respondent / Jason
Notice Of Filing
Page 25
EXHIBIT_START
NOTICE ON STATUS OF PROPOSED ORDER_9BFB63F9.pdf
PETITIONER'S REQUEST Petitioner respectfully requests that this Court issue a Statement of Fact regarding the contradictory sworn testimony and the video evidence submitted as Exhibit A. The contradiction is not nuanced-it is direct, visible, and undeniable. Should the Court decline to acknowledge the evidence or rule upon it, Petitioner reserves the right to seek judicial review, oversight, or formal complaint through all appropriate administrative and appellate channels. The procedural integrity of this Court and the dignity of its rulings depend on it...
#190
2026-02-06
Respondent / Jason
Notice Of Filing
Page 26
EXHIBIT_START
NOTICE ON STATUS OF PROPOSED ORDER_9BFB63F9.pdf
- Exhibit A Perjury Under Oath by Pamela Woodman Petitioner challenges this Court to watch the video and issue a Statement of Fact. The contradiction is direct, visible, and already in the record. If no such statement is issued, Petitioner reserves the right to raise this omission in all appellate and judicial oversight forums as a failure to acknowledge material fraud upon the Court. At the January 7, 2025, hearing, Pamela Woodman Respondent's sister and a financially interested party in this litigation-testified under oath that a "former police officer...
#155
2026-01-05
Respondent / Jason
Notice Of Filing
Page 5
PLEADING_BODY
NOTICE PRIOR COURT REPORTER REQUEST & OBJECTION TO OFF RECORD HEARING_179CB3AF.PDF
10/29/2025 1:13 PM DALLAS CO., TEXAS NOTICE: DOCUMENT CONTAINS DF-24-18010 NO. SENSITIVE INFORMATION. MARRIAGE OF § § & § STANDING FOR COURT REPORTER FOR REQUEST OCT. 31, 2025 HEARING AND ALL SUBSEQUENT PROCEEDINGS I, Jason McKemie, Respondent, appearing pro se, respectfully request that a licensed court reporter be present to record the following proceeding and all future hearings and trial in this cause pursuant to Texas Rule of Appellate Procedure 13.1(a). Requested Proceeding e Date: Friday, October 31, 2025 e Time: 9:30 a.m. e Judge: Hon. Tamika Bha...
#151
2025-12-29
Respondent / Jason
Motion - Seal - SEALED SUBMISSION FOR IN CAMERA
Page 45
EXHIBIT_START
MOTION SEAL SUBMISSION FOR CAAMERA REVIEW_E7F45A60.pdf
- EXHIBIT C CHRIS MCNALLY + EVIDENCE IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT-DOMESTIC RELATIONS DIVISION CHRISTOPHER MCNALLY, Petitioner Case No. GWENDOLYN ULUASZ, Respondent AFFIDAVIT IN SUPPORT OF EMERGENCY PETITION FOR ORDER OF PROTECTION Petitioner, CHRISTOPHER MCNALLY, being first sworn under oath, deposes and states as follows in support of his Emergency Petitionfor Order ofProtection: 1. Respondent, GWENDOLYN ULUASZ and | met in group therapy February 2014 at Hazelden-BettyFord Chicago and have maintained a combination of f...
#123
2025-10-29
Respondent / Jason
Notice Of Filing
Page 1
PLEADING_START_FILE_MARKED
REQUEST FOR COURT REPORTER FOR HEARING AND ALL SUBSEQUENT PROCEEDINGS_B01C1D04.pdf
10/29/2025 1:13 PM DALLAS CO., TEXAS NOTICE: DOCUMENT CONTAINS DF-24-18010 NO. SENSITIVE INFORMATION. MARRIAGE OF § § & § STANDING FOR COURT REPORTER FOR REQUEST OCT. 31, 2025 HEARING AND ALL SUBSEQUENT PROCEEDINGS I, Jason McKemie, Respondent, appearing pro se, respectfully request that a licensed court reporter be present to record the following proceeding and all future hearings and trial in this cause pursuant to Texas Rule of Appellate Procedure 13.1(a). Requested Proceeding e Date: Friday, October 31, 2025 e Time: 9:30 a.m. e Judge: Hon. Tamika Bha...
#084
2025-07-16
Respondent / Jason
Motion - Sanctions
Page 2
PLEADING_BODY
M_SANCTIONS_A954416F.pdf
Gwendolyn Ulijasz-McKemie, payable directly to Petitioner Jason McKemie, as a remedy for fraud upon the court, abuse of process, and material perjury under oath. B. These sanctions are not fines or criminal penalties, but civil monetary sanctions imposed pursuant to Tex. R. Civ. P. 215, and are designed to compensate Petitioner for documented legal and financial harm resulting from the false testimony. Texas Attorney General's Office for review and investigation of aggravated perjury and fraud upon the court; D. Gwendolyn Ulijasz-McKemie will be deemed u...
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2025-07-16
Respondent / Jason
Motion - Sanctions
Page 2
PLEADING_BODY
MSANCTIONS_A954416F.pdf
Gwendolyn Ulijasz-McKemie, payable directly to Petitioner Jason McKemie, as a remedy for fraud upon the court, abuse of process, and material perjury under oath. B. These sanctions are not fines or criminal penalties, but civil monetary sanctions imposed pursuant to Tex. R. Civ. P. 215, and are designed to compensate Petitioner for documented legal and financial harm resulting from the false testimony. Texas Attorney General's Office for review and investigation of aggravated perjury and fraud upon the court; D. Gwendolyn Ulijasz-McKemie will be deemed u...
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#086
2025-07-16
Respondent / Jason
Motion - Miscellaneous
Page 7
PLEADING_BODY
EMERGENCY MOTION TO PRESERVE EVIDENCE_086EEE12.pdf
ACCORDINGLY, PETITIONER RESPECTFULLY REQUESTS THAT THE COURT: 1. IMMEDIATELY CONTINUE THE BENCH TRIAL To prevent further procedural and constitutional harm resulting from discovery obstruction, strategic denial of counsel, and active deprivation of due process. 2. IMMEDIATELY APPROVE EMERGENCY FINANCIAL RELIEF Approve Petitioner's emergency request for $20,000 in immediate housing and Eviction During Medical Hardship. Petitioner will be rendered homeless if this request is not ruled upon this week. 3. PRESERVE THE FOLLOWING MATERIALS AND RECORDS To ensur...
#086
2025-07-16
Respondent / Jason
Motion - Miscellaneous
Page 9
EXHIBIT_START
EMERGENCY MOTION TO PRESERVE EVIDENCE_086EEE12.pdf
PETITIONER'S REQUEST Petitioner respectfully requests that this Court issue a Statement of Fact regarding the contradictory sworn testimony and the video evidence submitted as Exhibit A. The contradiction is not nuanced-it is direct, visible, and undeniable. Should the Court decline to acknowledge the evidence or rule upon it, Petitioner reserves the right to seek judicial review, oversight, or formal complaint through all appropriate administrative and appellate channels. The procedural integrity of this Court and the dignity of its rulings depend on it...
#086
2025-07-16
Respondent / Jason
Motion - Miscellaneous
Page 10
EXHIBIT_START
EMERGENCY MOTION TO PRESERVE EVIDENCE_086EEE12.pdf
- Exhibit A Perjury Under Oath by Pamela Woodman Petitioner challenges this Court to watch the video and issue a Statement of Fact. The contradiction is direct, visible, and already in the record. If no such statement is issued, Petitioner reserves the right to raise this omission in all appellate and judicial oversight forums as a failure to acknowledge material fraud upon the Court. At the January 7, 2025, hearing, Pamela Woodman Respondent's sister and a financially interested party in this litigation-testified under oath that a "former police officer...
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No filing date
Respondent / Jason
Proposed Order
Page 2
PLEADING_BODY
v2 - DF-24-18010_FINAL_Proposed_Order_Manufactured_Collapse_2026-06-11.pdf
...equests for fees, costs, protective expenses, vendor expenses, sanctions, or any cost shifting against Respondent arising from this emergency are DENIED IN FULL. 12. All mandamus, appellate, de novo, due-process, healthcare, discovery, stolen-evidence, financial-relief, trial-readiness, court-reporter, and recusal complaints are preserved. SIGNED on ______________________, 2026. ___________________________________________________ JUDGE PRESIDING Page 2 of 2
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Respondent / Jason
Notice
Page 31
EXHIBIT_CONTINUATION
eFile_UNDER SEAL_DB-24-18010_JUDICIAL REVIEW IN CAMERA_25MB (optimized) (3).pdf
EXHIBITEXHIBITCC- CHRIS- CHRISMCNALLYMCNALLY+ EVIDENCE+ EVIDENCE ININTHETHECIRCUITCIRCUIT COURTCOURT OFOF COOKCOOK COUNTY,COUNTY, ILLINOISILLINOIS COUNTYCOUNTY DEPARTMENT-DOMESTICDEPARTMENT-DOMESTIC RELATIONSRELATIONS DIVISIONDIVISION CHRISTOPHERCHRISTOPHER MCNALLY,MCNALLY, ) PetitionerPetitioner ) ) V.v. ) CaseCase No.No. GWENDOLYNGWENDOLYNULUJASZ,ULIJASZ, ) RespondentRespondent ) AFFIDAVIT IN SUPPORT OF EMERGENCY AFFIDAVIT IN SUPPORT OF EMERGENCY PETITIONPETITIONFORFOR ORDERORDER OFOF PROTECTIONPROTECTION Petitioner,Petitioner,CHRISTOPHERCHRISTOPHER MC...
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Respondent / Jason
Proposed Order/Judgment
Page 5
EXHIBIT_CONTINUATION
[DF-24-18010] Emergency Motion for Recusal.pdf
...thcare order through verified plan-administrator confirmation or escrow replacement; 3. The Court sets a sanctions/compliance hearing prior to trial; 4. The Court enters written rulings clarifying compliance. If those actions occur, Respondent will proceed. If they do not, Respondent has no procedural remedy remaining within this Court, and recusal becomes necessary to preserve due process and appellate review. VI. VERIFIED UNSWORN DECLARATION (TEX. CIV. PRAC. & REM. CODE § 132.001) VERIFIED MOTION TO RECUSE DF-24-18010 5 of 69
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Respondent / Jason
Motion
Page 31
EXHIBIT_START
UNDER SEAL_DB-24-18010_FOR JUDICIAL IN CAMERA REVIEW_URGENT (2).pdf
EXHIBIT C - CHRIS MCNALLY + EVIDENCE IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT-DOMESTIC RELATIONS DIVISION CHRISTOPHER MCNALLY, ) Petitioner ) ) v. ) Case No. GWENDOLYN ULIJASZ, ) Respondent ) AFFIDAVIT IN SUPPORT OF EMERGENCY PETITION FOR ORDER OF PROTECTION Petitioner, CHRISTOPHER MCNALLY, being first sworn under oath, deposes and states as follows in support of his Emergency Petition for Order of Protection: 1. Respondent, GWENDOLYN ULIJASZ and I met in group therapy February 2014 at Hazelden-BettyFord Chicago and have maintained...
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Respondent / Jason
Motion
Page 14
EXHIBIT_CONTINUATION
Respondents Emergency Supplement to Pending Recusal.pdf
...medical continuity, COBRA, storage preservation, transportation preservation, and emergency property protection before decree action; 23. preserve Jason’s objections for mandamus, appeal, due process, recusal, stolen-evidence, healthcare, discovery, source-record, sanctions, contempt, financial-relief, false-reporting, witness-suppression, and trial-readiness review. XXIII. SOURCE MAP / EXHIBITS FOR IMMEDIATE REVIEW Issue Primary source/exhibit Why it matters before decree Recusal No. 3 Verified Motion to Recuse Procedural bar/mandatory written ruling Ja...
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Respondent / Jason
Proposed Order/Judgment
Page 2
PLEADING_BODY
PROPOSED ORDER ON RESPONDENT'S VERIFIED EMERGENCY MOTION TO ABATE, STAY, OR CONTINUE TRIAL_9E703AF8.pdf
...equests for fees, costs, protective expenses, vendor expenses, sanctions, or any cost shifting against Respondent arising from this emergency are DENIED IN FULL. 12. All mandamus, appellate, de novo, due-process, healthcare, discovery, stolen-evidence, financial-relief, trial-readiness, court-reporter, and recusal complaints are preserved. SIGNED on .2026. JUDGE PRESIDING Page 2 of 2 Copy from re:SearchTX
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Respondent / Jason
Proposed Order/Judgment
Page 2
PROPOSED_ORDER_OR_ORDER
PROPOSED MOTION SANCTION FOR AGGRAVATED PERJURY AND FRAUD UPON THE OCURT AGAINST_83A6ADBD.pdf
...etary sanctions in the amount of $25,000 + $ are hereby imposed upon witness Pamela Woodman, payable directly to Petitioner Jason McKemie, as a remedy for fraud upon the court, abuse of process, and material perjury under oath. B. Said sanctions are not fines or criminal penalties, but civil monetary sanctions imposed pursuant to Tex. R. Civ. P. 215, and are designed to compensate Petitioner for documented legal and financial harm resulting from the false testimony. Texas Attorney General's Office for review and investigation of aggravated perjury and fr...
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Respondent / Jason
Motion - Miscellaneous
Page 9
PLEADING_BODY
MOTION TO PRESERVE DISCOVERY AND TRIAL RIGHTS_92A422FA.pdf
...ension of discovery; n. additional subpoenas; neutral forensic accounting; neutral forensic imaging; return of evidence; r. chain-of-custody orders; s. written findings; mandamus or appellate preservation; u. disproportionate division based on concealment, dissipation, fraud, waste, obstruction, or abuse of process. v. Respondent further preserves objections to trial proceeding while discovery remains incomplete, witnesses remain unidentified, subpoenas remain unavailable, healthcare enforcement remains unresolved, and April 16 evidence/property issues r...
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Respondent / Jason
Motion - Miscellaneous
Page 9
PLEADING_BODY
MOTION TO PRESERVE DISCOVERY AND TRIAL RIGHTS.pdf_92A422FA.pdf
...ension of discovery; n. additional subpoenas; neutral forensic accounting; neutral forensic imaging; return of evidence; r. chain-of-custody orders; s. written findings; mandamus or appellate preservation; u. disproportionate division based on concealment, dissipation, fraud, waste, obstruction, or abuse of process. v. Respondent further preserves objections to trial proceeding while discovery remains incomplete, witnesses remain unidentified, subpoenas remain unavailable, healthcare enforcement remains unresolved, and April 16 evidence/property issues r...
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Respondent / Jason
Proposed Order/Judgment
Page 5
EXHIBIT_CONTINUATION
MOTION - RECUSE_D09376D0.pdf
...thcare order through verified plan-administrator confirmation or escrow replacement; 3. The Court sets a sanctions/compliance hearing prior to trial; 4. The Court enters written rulings clarifying compliance. If those actions occur, Respondent will proceed. If they do not, Respondent has no procedural remedy remaining within this Court, and recusal becomes necessary to preserve due process and appellate review. VI. VERIFIED UNSWORN DECLARATION (TEX. CIV. PRAC. & REM. CODE § 132.001) VERIFIED MOTION TO RECUSE DF-24-18010 5 of 69 Copy from re:SearchTX
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#207
No filing date
Respondent / Jason
Proposed Order/Judgment
Page 5
EXHIBIT_CONTINUATION
MOTION - RECUSE.pdf
...thcare order through verified plan-administrator confirmation or escrow replacement; 3. The Court sets a sanctions/compliance hearing prior to trial; 4. The Court enters written rulings clarifying compliance. If those actions occur, Respondent will proceed. If they do not, Respondent has no procedural remedy remaining within this Court, and recusal becomes necessary to preserve due process and appellate review. VI. VERIFIED UNSWORN DECLARATION (TEX. CIV. PRAC. & REM. CODE § 132.001) VERIFIED MOTION TO RECUSE DF-24-18010 5 of 69 Copy from re:SearchTX
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No filing date
Respondent / Jason
Notice
Page 62
EXHIBIT_CONTINUATION
EVIDENCE AND EXIBITS_AC9E1D67.pdf
IN THE CIRCUIT COURT OF COOK COUNTY, ILLINOIS COUNTY DEPARTMENT-DOMESTIC RELATIONS DIVISION GWEN ULIJASZ, Petitioner Case No. CHRISTOPHER MCNALLY, Respondent. AFFIDAVIT IN SUPPORT OF EMERGENCY PETITION FOR ORDER OF PROTECTION Petitioner, GWEN ULIJASZ, being first sworn under oath, deposes and states as follows in support of her Emergency Petitionfor Order ofProtection: 1. Respondent, CHRISTOPHER MCNALLY (hereinafter "Christopher''), and I had a dating relationship from 2015-2022. Christopher has three children of a prior relationship, namely: Gweneth (ag...
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Respondent / Jason
Motion
Page 2
PLEADING_BODY
DF-24-18010_FINAL_Verified_Motion_to_Recuse_2026-06-11 (1).pdf
...Motion, a clear statement of the legal basis and good cause on the record before any evidence is offered. 4. Preservation of Respondent’s objections, including recusal, mandamus, de novo, due process, stolen-evidence, healthcare, 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, disclosur...
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Respondent / Jason
Motion
Page 5
EXHIBIT_START
DF-24-18010_FINAL_Verified_Motion_to_Recuse_2026-06-11 (1).pdf
...Court proceeds despite this Motion, Respondent requests a clear ruling on the record and states that he appears, if at all, under objection and without waiving recusal, mandamus, de novo, due- process, healthcare, discovery, stolen-evidence, trial-readiness, financial-relief, court-reporter, or appellate complaints. Respectfully submitted, Jason McKemie 539 W. Commerce St., Ste. 2010 Dallas, TX 75208 214-868-4901 jmckemie@mckemie.net Page 5 of 6
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Respondent / Jason
Motion
Page 8
PLEADING_BODY
DF-24-18010_FINAL_Emergency_Motion_Manufactured_Collapse_2026-06-11 (1).pdf
product of medical emergency, financial strangulation, evidence theft, healthcare obstruction, and transportation impossibility - not waiver. Respondent preserves mandamus, appeal, de novo, recusal, due-process, discovery, healthcare, source-record, financial-relief, court-reporter, stolen-evidence, and trial-readiness complaints. REQUEST Respondent requests that the Court grant the relief requested above, abate, stay, or continue trial, preserve healthcare, preserve stolen evidence, prohibit Petitioner and her agents from accessing or benefiting from st...
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Respondent / Jason
Notice
Page 2
PLEADING_BODY
DF-24-18010 - Supplemental Emergency Filing.pdf
...onsenting to trial. Respondent is not consenting to evidence being taken in his absence. Respondent is not consenting to final orders. Respondent is not waiving recusal, mandamus, appellate rights, due process, de novo/trial- readiness issues, healthcare objections, stolen-evidence objections, discovery objections, source- record objections, court-reporter objections, or financial-relief objections. Page 2 of 7
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Respondent / Jason
Notice
Page 5
EXHIBIT_CONTINUATION
DF-24-18010 - Supplemental Emergency Filing.pdf
...email; 9. Rule on Respondent’s recusal motion before evidence is received; 10. Rule on Respondent’s emergency motion to abate, stay, or continue trial; 11. Preserve all mandamus, appellate, recusal, due-process, healthcare, stolen-evidence, discovery, source-record, court-reporter, de novo, financial-relief, and trial-readiness objections. Respondent further requests any other relief to which Respondent is entitled. Respectfully submitted, Jason McKemie 539 W. Commerce St., Ste. 2010 Dallas, TX 75208 214-868-4901 jmckemie@mckemie.net Page 5 of 7
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Court
Exhibit
Page 73
EXHIBIT_CONTINUATION
DF-24-18010 - Respondent's De Novo Hearing Request (CMP).pdf
...thcare order through verified plan-administrator confirmation or escrow replacement; 3. The Court sets a sanctions/compliance hearing prior to trial; 4. The Court enters written rulings clarifying compliance. If those actions occur, Respondent will proceed. If they do not, Respondent has no procedural remedy remaining within this Court, and recusal becomes necessary to preserve due process and appellate review. VI. VERIFIED UNSWORN DECLARATION (TEX. CIV. PRAC. & REM. CODE § 132.001) VERIFIED MOTION TO RECUSE DF-24-18010 5 of2269of 110
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Respondent / Jason
Order
Page 1
PLEADING_START
DF-24-18010 - Recusal Notice_Written Ruling_Objection to Decree Action (1).pdf
...ble to him. Because decree signature would materially affect property division, debt allocation, healthcare access, benefits, enforcement, sanctions, fees, and appellate/mandamus rights, Jason requests that the Court clarify the Rule 18a status before any decree action. Texas Rule of Civil Procedure 18a. 1 of 5
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Respondent / Jason
Order
Page 2
EXHIBIT_START
DF-24-18010 - Recusal Notice_Written Ruling_Objection to Decree Action (1).pdf
...Jason is asking the Court to confirm whether the pending verified recusal has been ruled on, referred, denied, or otherwise addressed in a manner sufficient to preserve mandamus and appellate review before any decree is signed. IV. OBJECTION TO DECREE ACTION BEFORE RULE 18a STATUS IS CLARIFIED 2 of 5
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