DF-24-18010 Litigation Record Search

...OMPLIANCE EVIDENCE M https://tinyurl.com/BenefitsOrder Existing signed healthcare order requiring healthcare-benefits compliance and restoration/reimbursement of HSA/FSA funds. PRIOR EMERGENCY-FUNDS DELAY / ABILITY-TO-PAY / FALSE CLAIMS OF DESTITUTION FOLLOWED BY $50K IN THIRD PARTY CONTRACTOR SPENDING https://tinyurl.com/DestitutionBankAccounts https://tinyurl.com/FeeShifting Shows another bank account on Oct 31st, 2025, when Petitioner testified to having less than $4k in a hearing which relief was denied to Applicant once again. Procedural delay as th...

...personally entering the residence or receiving property directly from Applicant. Applicant repeatedly stated that any remaining property transfer had to occur through a neutral third party because direct contact or direct transfer created an unacceptable risk of false allegations, planted evidence, property destruction, or further escalation. Petitioner was that she was not permitted to personally re-enter the residence and that any remaining retrieval had to occur through a neutral process. II. TIMELINE OF KNOWN APRIL 16, 2026, EVENTS 2:37 p.m. — Appli...

...removed property from the residence despite prior notice that her personal entry and direct property removal created unacceptable risk and were not permitted through any neutral process. IX. ALL MY SONS, CONCEALED THIRD-PARTY PAYMENT, AND PETITIONER’S EFFORT TO KEEP HER NAME OFF THE MOVE When Applicant returned to the residence, a 26-foot All My Sons moving truck was in front of the residence and unloading had begun. Applicant contacted the moving company manager and told him that the property on the truck was Applicant’s property, that Applicant had a s...

continuecontinue filingfiling falsefalse reports,reports, inin combinationcombination withwith otherother manipulativemanipulative tacticstactics (happy(happy toto explainexplain further),further), toto ultimatelyultimately ensureensure thethe conversionconversion ofof thethe temporarytemporary orderorder intointo aa 2yrZyr orderorder ofof protection.protection. BasedBased onon mymy research,research, andand conversationsconversationswithwith pastpast victims,victims, II amam thethe onlyonly oneone toto havehave escapedescaped eithereither thethe criminal...

MUTUAL RELEASE AND PRIVATE SETTLEMENT AGREEMENT WHEREAS, SKWERES PROPERTIES, LLC, as landlord (the “Landlord”), and GWENDOLYN ULIJASZ-MCKEMIE (the “Tenant” and sometimes “Gwen”; together with the Landlord, the “Parties”) entered into a certain Residential Lease (the “Lease”) for the property located at 5609 La Foy Blvd, Dallas, Texas 75209 (the “Premises”), the Lease having also JASON MCKEMIE as co-tenant (“Jason”); and JPC26-06838-51 (the “Lawsuit”); and WHEREAS, Landlord and Tenant desire to nonsuit the Lawsuit as to then Tenant only. NOW, THEREFORE, t...

...MOTION-LIKE APPLICATIONS) 2025 • 03/14/2025 (Entry 48) — 4 pages — MOTION - AGREED - WITHDRAW ATTORNEY - BRANT WEBB • 03/28/2025 (Entry 51) — 2 pages — NOTICE OF FAILED MEDIATION AND MOTION FOR CONTINUANCE OF APRIL 7th, 2025, PRE-TRIAL HEARING MOTION FOR CONTINUANCE-NOTICE OF FAILED MEDIATION AND OF APRIL 7th, 2025, PRE-TRIAL HEARING • 04/14/2025 (Entry 55) — 5 pages — MOTION TO STRIKE IMPROPER EXPERT DESIGNATIONS AND TO LIMIT TESTIMONY OF OPPOSING COUNSEL • 04/24/2025 (Entry 56) — 1 page — MOTION FOR NOTICE PRIOR TO ANY DISMISSAL PROPOSED ORDER ON MOTI...

...r surgery in late December, but that surgery was cancelled when Petitioner cut off his healthcare by submitting a fraudulent qualifying life event to her 4AM employers A Third Party Corroboration of Stalking Lexus: benefits group. A 24hr Emergency Reinstatement Order still has not been complied with 6 months https://tinyurl.com/DestructionDeclaration later. In pain, and physically exhausted and slept outside in a lawn chair to ensure no property was ever left unattended so that there was clearly defined possession of the property and that 2026 responsibi...

...e, including the unvested shares, together with all rights to vesting, dividends, and proceeds thereof. W-3. The Chase Checking account ending in x9259 together with all funds on deposit therein. W-4. The Accenture HSA account, together with all funds on deposit therein. W-5. The BMW automobile, together with all keys, title documents, and equipment, subject to the indebtedness thereon as allocated below. W-6. All clothing, jewelry, electronics, household furnishings, and other personal effects in Wife's possession or control. W-7. Any and all Internet d...

...enough money to maintain the marital residence for approximately three months and to obtain medically necessary rehabilitation equipment. Counsel told Jason not to drain funds for legal fees and not to take more than needed to preserve the estate. On December 12, 2024, Jason transferred approximately $30,000 to preserve the marital residence and purchased rehabilitation equipment and a Christmas gift Petitioner had requested for her sister. Petitioner texted Jason asking whether the transactions were legitimate. Jason confirmed that they were That same e...

...was the improper-service bait that required him to go to the courthouse to seek emergency relief. Jason repeatedly said Petitioner could retrieve her property through a third party. He repeatedly objected to Petitioner's personal access because he warned she would steal evidence, destroy property, plant or manipulate items, and manufacture allegations. The exact conduct he warned about then occurred. During the second writ aftermath, while Jason's remaining property was outside and Jason had to leave for the courthouse to seek emergency protective and r...

...s County case DF-24-18010. I am not contacting Gwendolyn Ulijasz, attempting to communicate with her, or attempting to communicate with her through JJason McKemie or any third party. I understand that prior protective-order language restricts contact or communication through third parties. This declaration is provided solely for court use, subpoena compliance, testimony preservation, and lawful evidentiary purposes in pending litigation. Nothing in this declaration is intended as a message to Gwendolyn Ulijasz, a request that any person contact her, or a...

...etitioner was using false reports, protective-order narratives, healthcare obstruction, financial strangulation, discovery obstruction, housing sabotage, digital access, third- party vendors, and court process to destroy his ability to survive and defend himself. The record already includes repeated requests for emergency financial relief, healthcare enforcement, HSA/FSA access, court reporter protection, source-record verification, subpoena authority, trial abatement, continuance, housing stability, due-process protection, and medical preservation. The...

...etitioner was using false reports, protective-order narratives, healthcare obstruction, financial strangulation, discovery obstruction, housing sabotage, digital access, third- party vendors, and court process to destroy his ability to survive and defend himself. The record already includes repeated requests for emergency financial relief, healthcare enforcement, HSA/FSA access, court reporter protection, source-record verification, subpoena authority, trial abatement, continuance, housing stability, due-process protection, and medical preservation. The...

...ecords. Xl. PRELIMINARY FUNDS AND CLAIMED SHARES REQUIRING PRESERVATION AND TRACING Movant identifies the following funds and shares requiring preservation, tracing, and third-party verification: Category Calculation Amount Sign-on bonus 1/2 of $300,000 $150,000 Cognizant settlement 1/2 of $156,045 $78,022.50 VEIP/equity 1/2 of $195,000 $97,500 DF-24-18010 Motion for Enforcement, Sanctions, Continuance, & Leave Page 10 of 17 Copy from re:SearchTX

...s to the residence. Those requests were not granted in the manner she sought. Movant repeatedly stated that if Petitioner wanted property, it should occur only through a neutral third party because direct access created danger, theft risk, destruction risk, allegation risk, and evidence risk. That is exactly what happened. On April 16, Petitioner stole Movant's hard drives, itigation evidence, financial records, trial materials, GPUs, network storage, music studio equipment, medication, and livelihood infrastructure. The stolen hard drives were Movant's...

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

e Accounts have been rotated, renamed, and layered; e Funds conceded in mediation were not escrowed; e Healthcare enforcement remains incomplete; e Anactive bankruptcy stay exists under Trustee oversight. These facts are extensively documented and; Proceeding to trial under these conditions would: e Convert discovery collapse into adjudication; e Freeze dissipation into final division; e Render third-party verification impossible; e Permanently impair Respondent's ability to challenge false or incomplete production. V. CONDITIONAL NATURE OF THIS MOTION R...

...nt motions & motion-like applications) 2025 03/14/2025 (Entry 48) 4 pages MOTION - AGREED - WITHDRAW ATTORNEY - BRANT WEBB 03/28/2025 (Entry 51) 2 pages NOTICE OF FAILED MEDIATION AND MOTION FOR CONTINUANCE OF APRIL7th, 2025, PRE-TRIAL HEARING MOTION FOR CONTINUANCE-NOTICE OF FAILED MEDIATION AND OF APRIL7th,2025, PRE-TRIAL HEARING 04/14/2025 (Entry 55) 5 pages MOTION TO STRIKE IMPROPER EXPERT DESIGNATIONS AND TO LIMIT TESTIMONY OF OPPOSING COUNSEL 04/24/2025 (Entry 56) 1 page MOTION FOR NOTICE PRIOR TO ANY DISMISSAL PROPOSED ORDER ON MOTION FOR NOTICE P...

...m>, Kim Jones <kjones@sullivancook.com>, Jason McKemie <mckemie76@gmail.com> Mr. McKemie, I had an emergency TRO come up today that took up most of my day and an all day mediation yesterday. Six days is too short a turnaround for the amount of items you identified. We will have a substantive response to you regarding the identified items by end of day October 7, 2025 (one week from now). Sincerely, ETHAN SCROGGINS Sullivan & Cook LLC Attorney 600 East Las Colinas Blvd, Suite TI 300 Irving, TX 75039 214) 520-7494 escrorrins@sullivancock.com From: Jason Mc...

...ees Judgment McNally.pdf GU000162 Need all legal billing accounted for. HSA HSA METLIFE 2024-12-31 MetLife HSA Summary.pdf GU000127 Release HSA Card Immediately proof of funds + notarized agmnt prior to standing / LOANS LOANS RETAINER LOANS 2025-01-11 Email re Retainer loan terms.pdf GU000134 temp orders or remove it LOANS LOANS SOFI Sofi Loan.pdf GU000230 Need Current Months Statement Why do you have your previous car loan versus your LOANS AUTO LOAN WR AUTO wellsfargo auto loan closed 2023.pdf GU000276 current? 91 of 110 Copy from re:SearchTX

...m>, Kim Jones <kjones@sullivancook.com>, Jason McKemie <mckemie76@gmail.com> Mr. McKemie, | had an emergency TRO come up today that took up most of my day and an all day mediation yesterday. Six days is too short a turnaround for the amount of items you identified. We will have a substantive response to you regarding the identified items by end of day October 7, 2025 (one week from now). Sincerely, ETHAN SCROGGINS Sullivan & Cook LLC Attorney 600 East Las Colinas Blvd, Suite 1300 Irving, TX 75039 214) 520-7494 escroggins@sullivancook.com From: Jason McKe...

...ecords. XI. PRELIMINARY FUNDS AND CLAIMED SHARES REQUIRING PRESERVATION AND TRACING Movant identifies the following funds and shares requiring preservation, tracing, and third-party verification: Category Calculation Amount Sign-on bonus 1/2 of $300,000 $150,000 Cognizant settlement 1/2 of $156,045 $78,022.50 VEIP/equity 1/2 of $195,000 $97,500 DF-24-18010 Motion for Enforcement, Sanctions, Continuance, & Leave Page 10 of 17

...s to the residence. Those requests were not granted in the manner she sought. Movant repeatedly stated that if Petitioner wanted property, it should occur only through a neutral third party because direct access created danger, theft risk, destruction risk, allegation risk, and evidence risk. That is exactly what happened. On April 16, Petitioner stole Movant’s hard drives, litigation evidence, financial records, trial materials, GPUs, network storage, music studio equipment, medication, and livelihood infrastructure. The stolen hard drives were Movant’s...

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

• Accounts have been rotated, renamed, and layered; • Funds conceded in mediation were not escrowed; • Healthcare enforcement remains incomplete; • An active bankruptcy stay exists under Trustee oversight. These facts are extensively documented and; Proceeding to trial under these conditions would: • Convert discovery collapse into adjudication; • Freeze dissipation into final division; • Render third-party verification impossible; • Permanently impair Respondent’s ability to challenge false or incomplete production. V. CONDITIONAL NATURE OF THIS MOTION...

...motion-like applications) 2025 • 03/14/2025 (Entry 48) — 4 pages — MOTION - AGREED - WITHDRAW ATTORNEY - BRANT WEBB • 03/28/2025 (Entry 51) — 2 pages — NOTICE OF FAILED MEDIATION AND MOTION FOR CONTINUANCE OF APRIL 7th, 2025, PRE-TRIAL HEARING MOTION FOR CONTINUANCE-NOTICE OF FAILED MEDIATION AND OF APRIL 7th, 2025, PRE-TRIAL HEARING • 04/14/2025 (Entry 55) — 5 pages — MOTION TO STRIKE IMPROPER EXPERT DESIGNATIONS AND TO LIMIT TESTIMONY OF OPPOSING COUNSEL • 04/24/2025 (Entry 56) — 1 page — MOTION FOR NOTICE PRIOR TO ANY DISMISSAL PROPOSED ORDER ON MOTI...

...Law Fees Judgment McNally.pdf GU00016: Need all legal billing accounted for. HSA METLIFE 2024-12-31 MetLife HSA Summary.pdf GUO0012 Release HSA Card Immediately proof of funds + notarized agmnt prior to standing / LOANS LOANS RETAINER LOANS 2025-01-11 Email re Retainer loan terms.pdf GU000134 temp orders or remove it LOANS LOANS SOFI Sofi Loan.pdf GU000230 [Need Current Months Statement Why do you have your previous car loan versus your LOANs AUTO LOAN WR AUTO wellsfargo auto loan closed 2023.pdf GU000276 current? 38 of5469of 110

...m>, Kim Jones <kjones@sullivancook.com>, Jason McKemie <mckemie76@gmail.com> Mr. McKemie, I had an emergency TRO come up today that took up most of my day and an all day mediation yesterday. Six days is too short a turnaround for the amount of items you identified. We will have a substantive response to you regarding the identified items by end of day October 7, 2025 (one week from now). Sincerely, ETHAN SCROGGINS Sullivan & Cook LLC Attorney 600 East Las Colinas Blvd, Suite 1300 Irving, TX 75039 (214) 520-7494 escroggins@sullivancook.com From: Jason McKem...

...ees Judgment McNally.pdf GU000162 Need all legal billing accounted for. HSA HSA METLIFE 2024-12-31 MetLife HSA Summary.pdf GU000127 Release HSA Card Immediately proof of funds + notarized agmnt prior to standing / LOANS LOANS RETAINER LOANS 2025-01-11 Email re Retainer loan terms.pdf GU000134 temp orders or remove it LOANS LOANS SOFI Sofi Loan.pdf GU000230 Need Current Months Statement Why do you have your previous car loan versus your LOANS AUTO LOAN WR AUTO wellsfargo auto loan closed 2023.pdf GU000276 current? 91 of 110

...m>, Kim Jones <kjones@sullivancook.com>, Jason McKemie <mckemie76@gmail.com> Mr. McKemie, I had an emergency TRO come up today that took up most of my day and an all day mediation yesterday. Six days is too short a turnaround for the amount of items you identified. We will have a substantive response to you regarding the identified items by end of day October 7, 2025 (one week from now). Sincerely, ETHAN SCROGGINS Sullivan & Cook LLC Attorney 600 East Las Colinas Blvd, Suite 1300 Irving, TX 75039 (214) 520-7494 escroggins@sullivancook.com From:From:From:Fr...

• Accounts have been rotated, renamed, and layered; • Funds conceded in mediation were not escrowed; • Healthcare enforcement remains incomplete; • An active bankruptcy stay exists under Trustee oversight. These facts are extensively documented and; Proceeding to trial under these conditions would: • Convert discovery collapse into adjudication; • Freeze dissipation into final division; • Render third-party verification impossible; • Permanently impair Respondent’s ability to challenge false or incomplete production. V. CONDITIONAL NATURE OF THIS MOTION...

...motion-like applications) 2025 • 03/14/2025 (Entry 48) — 4 pages — MOTION - AGREED - WITHDRAW ATTORNEY - BRANT WEBB • 03/28/2025 (Entry 51) — 2 pages — NOTICE OF FAILED MEDIATION AND MOTION FOR CONTINUANCE OF APRIL 7th, 2025, PRE-TRIAL HEARING MOTION FOR CONTINUANCE-NOTICE OF FAILED MEDIATION AND OF APRIL 7th, 2025, PRE-TRIAL HEARING • 04/14/2025 (Entry 55) — 5 pages — MOTION TO STRIKE IMPROPER EXPERT DESIGNATIONS AND TO LIMIT TESTIMONY OF OPPOSING COUNSEL • 04/24/2025 (Entry 56) — 1 page — MOTION FOR NOTICE PRIOR TO ANY DISMISSAL PROPOSED ORDER ON MOTI...

...Law Fees Judgment McNally.pdf GU00016: Need all legal billing accounted for. HSA METLIFE 2024-12-31 MetLife HSA Summary.pdf GUO0012 Release HSA Card Immediately proof of funds + notarized agmnt prior to standing / LOANS LOANS RETAINER LOANS 2025-01-11 Email re Retainer loan terms.pdf GU000134 temp orders or remove it LOANS LOANS SOFI Sofi Loan.pdf GU000230 [Need Current Months Statement Why do you have your previous car loan versus your LOANs AUTO LOAN WR AUTO wellsfargo auto loan closed 2023.pdf GU000276 current? 38 of5469of 110 Copy from re:SearchTX

...m>, Kim Jones <kjones@sullivancook.com>, Jason McKemie <mckemie76@gmail.com> Mr. McKemie, I had an emergency TRO come up today that took up most of my day and an all day mediation yesterday. Six days is too short a turnaround for the amount of items you identified. We will have a substantive response to you regarding the identified items by end of day October 7, 2025 (one week from now). Sincerely, ETHAN SCROGGINS Sullivan & Cook LLC Attorney 600 East Las Colinas Blvd, Suite 1300 Irving, TX 75039 (214) 520-7494 escroggins@sullivancook.com From: Jason McKem...

...ees Judgment McNally.pdf GU000162 Need all legal billing accounted for. HSA HSA METLIFE 2024-12-31 MetLife HSA Summary.pdf GU000127 Release HSA Card Immediately proof of funds + notarized agmnt prior to standing / LOANS LOANS RETAINER LOANS 2025-01-11 Email re Retainer loan terms.pdf GU000134 temp orders or remove it LOANS LOANS SOFI Sofi Loan.pdf GU000230 Need Current Months Statement Why do you have your previous car loan versus your LOANS AUTO LOAN WR AUTO wellsfargo auto loan closed 2023.pdf GU000276 current? 91 of 110 Copy from re:SearchTX

...m>, Kim Jones <kjones@sullivancook.com>, Jason McKemie <mckemie76@gmail.com> Mr. McKemie, I had an emergency TRO come up today that took up most of my day and an all day mediation yesterday. Six days is too short a turnaround for the amount of items you identified. We will have a substantive response to you regarding the identified items by end of day October 7, 2025 (one week from now). Sincerely, ETHAN SCROGGINS Sullivan & Cook LLC Attorney 600 East Las Colinas Blvd, Suite 1300 Irving, TX 75039 (214) 520-7494 escroggins@sullivancook.com From:From:From:Fr...

...dian / brokerage statements 13. Bank records for compensation deposits 14. Records for sister/family loan inflows 15. HSA/FSA/benefit custodian records IMMEDIATE MUST-HAVE THIRD PARTY RECORDS: 1. leave to subpoena Accenture HR/payroll; 2. leave to subpoena Accenture myHoldings/equity administrator; 3. leave to subpoena the VEIP plan administrator; 4. leave to subpoena the stock-plan custodian/brokerage; 5. an order compelling Gwen to produce all source records, not summaries; DF-24-18010 Accenture Compensation 14 of 16

...an / brokerage statements :3. Bank records for compensation deposits 14. Records for sister/family loan inflows 15. HSA/FSA/benefit custodian records IMMEDIATE MUST-HAVE THIRD PARTY RECORDS: 1. leave to subpoena Accenture HR/payroll; 2. leave to subpoena Accenture myHoldings/equity administrator; 3. leave to subpoena the VEIP plan administrator; 4. leave to subpoena the stock-plan custodian/brokerage; 5. an order compelling Gwen to produce all source records, not summaries; DF-24-18010 Accenture Compensation 14 of 16 Copy from re:SearchTX

• Accounts have been rotated, renamed, and layered; • Funds conceded in mediation were not escrowed; • Healthcare enforcement remains incomplete; • An active bankruptcy stay exists under Trustee oversight. These facts are extensively documented and; Proceeding to trial under these conditions would: • Convert discovery collapse into adjudication; • Freeze dissipation into final division; • Render third-party verification impossible; • Permanently impair Respondent’s ability to challenge false or incomplete production. V. CONDITIONAL NATURE OF THIS MOTION...

...motion-like applications) 2025 • 03/14/2025 (Entry 48) — 4 pages — MOTION - AGREED - WITHDRAW ATTORNEY - BRANT WEBB • 03/28/2025 (Entry 51) — 2 pages — NOTICE OF FAILED MEDIATION AND MOTION FOR CONTINUANCE OF APRIL 7th, 2025, PRE-TRIAL HEARING MOTION FOR CONTINUANCE-NOTICE OF FAILED MEDIATION AND OF APRIL 7th, 2025, PRE-TRIAL HEARING • 04/14/2025 (Entry 55) — 5 pages — MOTION TO STRIKE IMPROPER EXPERT DESIGNATIONS AND TO LIMIT TESTIMONY OF OPPOSING COUNSEL • 04/24/2025 (Entry 56) — 1 page — MOTION FOR NOTICE PRIOR TO ANY DISMISSAL PROPOSED ORDER ON MOTI...

...Law Fees Judgment McNally.pdf GU00016: Need all legal billing accounted for. HSA METLIFE 2024-12-31 MetLife HSA Summary.pdf GUO0012 Release HSA Card Immediately proof of funds + notarized agmnt prior to standing / LOANS LOANS RETAINER LOANS 2025-01-11 Email re Retainer loan terms.pdf GU000134 temp orders or remove it LOANS LOANS SOFI Sofi Loan.pdf GU000230 [Need Current Months Statement Why do you have your previous car loan versus your LOANs AUTO LOAN WR AUTO wellsfargo auto loan closed 2023.pdf GU000276 current? 38 of5469of 110

...m>, Kim Jones <kjones@sullivancook.com>, Jason McKemie <mckemie76@gmail.com> Mr. McKemie, I had an emergency TRO come up today that took up most of my day and an all day mediation yesterday. Six days is too short a turnaround for the amount of items you identified. We will have a substantive response to you regarding the identified items by end of day October 7, 2025 (one week from now). Sincerely, ETHAN SCROGGINS Sullivan & Cook LLC Attorney 600 East Las Colinas Blvd, Suite 1300 Irving, TX 75039 (214) 520-7494 escroggins@sullivancook.com From: Jason McKem...

...ees Judgment McNally.pdf GU000162 Need all legal billing accounted for. HSA HSA METLIFE 2024-12-31 MetLife HSA Summary.pdf GU000127 Release HSA Card Immediately proof of funds + notarized agmnt prior to standing / LOANS LOANS RETAINER LOANS 2025-01-11 Email re Retainer loan terms.pdf GU000134 temp orders or remove it LOANS LOANS SOFI Sofi Loan.pdf GU000230 Need Current Months Statement Why do you have your previous car loan versus your LOANS AUTO LOAN WR AUTO wellsfargo auto loan closed 2023.pdf GU000276 current? 91 of 110

...m>, Kim Jones <kjones@sullivancook.com>, Jason McKemie <mckemie76@gmail.com> Mr. McKemie, I had an emergency TRO come up today that took up most of my day and an all day mediation yesterday. Six days is too short a turnaround for the amount of items you identified. We will have a substantive response to you regarding the identified items by end of day October 7, 2025 (one week from now). Sincerely, ETHAN SCROGGINS Sullivan & Cook LLC Attorney 600 East Las Colinas Blvd, Suite 1300 Irving, TX 75039 (214) 520-7494 escroggins@sullivancook.com From:From:From:Fr...

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

...osed orders, fee applications, contempt filings, body-attachment requests, protective-order enforcement materials, settlement communications, witness communications, and third-party communications concerning Christopher McNally; f. Petitioner and counsel shall disclose under oath all pending or threatened proceedings, enforcement requests, body-attachment requests, contempt proceedings, fee-collection proceedings, protective-order modifications, or related actions involving Christopher McNally. Vill. CONTINUED FINANCIAL NONPRODUCTION AND TRIAL-READINESS...

...personally entering the residence or receiving property directly from Applicant. Applicant repeatedly stated that any remaining property transfer had to occur through a neutral third party because direct contact or direct Thursday, April 16 transfer created an unacceptable risk of false allegations, planted 139 events evidence, property destruction, or further escalation. Petitioner was that she was not permitted to personally re-enter the residence and that Back Alley 2:34PM any remaining retrieval had to occur through a neutral process. * Motion Il. T...

...removed property from the residence despite prior notice that her personal entry and direct property removal created unacceptable risk and were not permitted through any neutral process. IX. ALL MY SONS, CONCEALED THIRD-PARTY PAYMENT, AND PETITIONER'S EFFORT TO KEEP HER NAME OFF THE MOVE When Applicant returned to the residence, a 26-foot All My Sons moving truck was in front of the residence and unloading had begun. Applicant contacted the moving company manager and told him that the property on the truck was Applicant's property, that Applicant had a s...

...hall enter, access, or attempt to access the marital residence or any disputed property except by written agreement, court order, or a scheduled transfer supervised by a neutral third party, civil standby, or other person approved by the Court. Any property retrieval shall occur only by written inventory, fixed date and time, and neutral supervision. approved written channel, neither party shall initiate direct contact with the other concerning disputed facts, property access, benefits, finances, or litigation issues. j) No party shall interfere with the...

...ed to those currently owned by the Respondent via Ionos company. Those currently owned domain names and addresses will be relinquished and proof of such action sent to a neutral Third Party within three days. 8. Confirmation that Respondent's access to Petitioner's employer-sponsored health insurance and benefits plan will expire February 24, 2026 in accordance with the Plan. This further serves to confirm that the Respondent was notified of this expiration date in email provided by Petitioner's Human Resources Dept. , served on the Respondent as part of...

IV. PUBLIC INTEREST, THIRD-PARTY RELIANCE, AND INTEGRITY OF THE JUDICIAL PROCESS The issues implicated by sealing in this case extend beyond the private interests of the parties. Judicial filings asserting allegations of misconduct and safety concerns carry foreseeable consequences for third parties who rely on the accuracy of court records, including employers, family members, and professional contacts. When a party has used public filings to advance serious allegations, transparency serves an important public interest by ensuring accountability, protec...

...lly and under oath invites judicial scrutiny. The later disclosure of these agreements, combined with their subsequent characterization and use in financial disclosures, mediation representations, and employment positioning, bears directly on the reliability of sworn testimony and the integrity of representations made to the Court. Sealing the record under these circumstances would obstruct the Court's ability to evaluate sworn contradictions and would prevent the record from performing its corrective and exonerative function with respect to allegations...

...nendments, and omissions; e All of Petitioner's documented medical records and motions relating to hardship; e Any audio, video, or written evidence referenced by either party; ¢ All affidavits and sworn statements submitted by Petitioner under penalty of perjury; e The full transcript (if available) of the January 7, 2025 hearing; ¢ All filings, correspondence, and declarations from Respondent regarding: o Spousal support o Legal fees o Settlement concealment o Personal loans between Respondent and affiliated parties e Any involvement or correspondence...

...ase management. | . NOTICE OF DISCOVERY COMPLIANCE All discovery requests in this matter were fully responded to in a timely manner for both the court-ordered March 2025 mediation as well as the July 23, 2025 that the Respondent postponed for lack of readiness. On September 23, 2025 and again on October 10, 2025, Petitioner's counsel representing her at that time provided written confirmation to Respondent yet again that discovery was complete, with the sole exception of two pages inadvertently omitted due to a mechanical error. Those two pages and a dup...

...r/Judgment FOR CONTINUANCE OF APRIL 7th, 2025, PRE-TRIAL HEARI! & PROPOSED ORDER FOR CONTINUANCE OF APRIL 7... 2 : 3/28/2025 Filing Motion - Continuance NOTICE OF FAILED MEDIATION AND MOTION FOR CONTINI & MOTION FOR CONTINUANCE-NOTICE OF FAILED ME... : 3/26/2025 Filing Vacation Letter AMENDED - WILLIAM COOK A VACATION LETTER - AMENDED - WILLIAM COOK.pdf : 3/17/2025 Filing Order - Withdraw Attorney & ORDER - WITHDRAW ATTORNEY.pdf 2 : Filing Motion - Withdraw Attorney AGREED - BRANT WEBB A MOTION - AGREED - WITHDRAW ATTORNEY - BRAN... 3/14/2025 : 4 Filing...

...Nounilateral inventories/claims: No party may unilaterally inventory, designate, or claim exclusive ownership of household property during the pendency of this Order. e Neutral handling if movement becomes necessary: Any necessary removal or storage shall occur only by mutual agreement or a neutral third party and shall not constitute abandonment or waiver of claims. DF-24-18010 3 of 13 Copy from re:SearchTX

...DEADLINES A. IMMEDIATE COMPLIANCE DEADLINE. Petitioner shall fully comply with these Orders by 2:00pm on the Date of Signing. Compliance includes tender of the required funds and filing written proof of compliance via ¢- file immediately upon completion. e Compliance requires immediately available funds (same-day wire or other real-time transfer). Initiation of an ACH or other delayed-settlement transfer does not constitute compliance. B. COERCIVE INCENTIVE FOR COMPLIANCE W/ DAILY ACCRUAL. e If Petitioner fails to fully complete the funds transfer by 2:...

...'s sworn affidavit establishes that Respondent is medically incapacitated, unable to relocate, and at risk of homelessness absent timely receipt of funds acknowledged or conceded as belonging to Respondent. In the event the opposing party fails to timely comply with a court-ordered payment obligation without good cause, and such failure foreseeably places Respondent at risk of homelessness or irreparable harm, the Court may deem such noncompliance evidence of bad faith, obstruction, or litigation misconduct, and may consider such conduct in assessing cre...

...judicial review is available. | will be unable to stabilize housing or obtain necessary medical care without emergency relief. 8. Ability to Comply / Scale of Available Funds. Petitioner has the ability to comply with immediate temporary support, and any claim of "lack of funds" is not credible. Even without addressing Petitioner's ongoing salary, bonuses, or broader estate issues, there are discrete, identifiable funds already disclosed and/or previously acknowledged in this case that demonstrate ample liquidity: Sign-on bonus: $300,000 total; one-half...

e If VEIP was withdrawn: o Approximately $100,000 in liquid funds would have been received o Community portion approximately $50,000 © If VEIP was not withdrawn: o A50% employer match would have been credited as of Dec. 31, 2025 o VEIP balance would have fully vested immediately o Approximately $195,000 would be immediately accessible o Community portion approximately $97,500 e Total Identifiable Funds from Only These 3 Recent Events (Excluding Over $600,000 in Additional Marital Assets & Forms of Compensation) e Minimum identifiable assets: « (Sign-on $...

...REQUEST D. WILLINGNESS TO COOPERATE UNDER STRUCTURE. e Mr. McKemie is willing to cooperate with a lawful retrieval of specifically identified items through a controlled, neutral process. If permitted by the Court, Mr. McKemie further offers to facilitate retrieval by staging approved items in a neutral location (e.g., a garage) pursuant to a court-ordered protocol. Ill. RELIEF REQUESTED (TEMPORARY STAY OR PROTECTIVE CONDITIONS) Mr. McKemie respectfully requests that the Court enter one of the following: - E. PRIMARY RELIEF TEMPORARY STAY 1 TEMPORARY STAY...

...sonably necessary to retrieve listed items. No tracking devices, recording devices, or inspection activity of any kind. Retrieval only. 7. INVENTORY AND PHOTOGRAPHS. The neutral third party shall inventory and photograph all items removed at the time of retrieval and provide copies to both parties within twenty-four (24) hours. 8. NEGATIVE INVENTORY; NO ATTRIBUTION. Petitioner has previously removed significant items from the residence during multiple court- authorized access periods. On subsequent occasions, certain items were reported as remaining in t...

...preservation pending further order of the Court. IV. ESSENTIAL LIVING PROPERTY (EXPRESS EXCLUSION) 13. Mr. McKemie is currently medically compromised and lacks access to funds or credit. To prevent irreparable harm, any property retrieval shall expressly exclude essential living items necessary for Respondent's daily survival and medical needs, including but not limited to: a bed and bedding, mattress, pillows, basic furniture used for sleeping, clothing, personal toiletries, prescribed medical equipment or supplies, medications, food, kitchen essentials...

...NING ANY ACCESS (Applicable Regardless of Stay Determination) 3 No Access During Hospitalization. No access shall occur while Respondent is inpatient or hospitalized. 4. Neutral Third-Party Retrieval Only; No Personal Entry. Any permitted retrieval shall be conducted exclusively by a neutral third party (bonded mover and/or neutral supervisor). Petitioner shall not personally enter the residence. Petitioner shall file a written, itemized list identifying each specific item sought. Retrieval is limited strictly to 6. Defined Scope; Excluded Categories and...

...No unilateral inventories/claims: No party may unilaterally inventory, designate, or claim exclusive ownership of household property during the pendency of this Order. • Neutral handling if movement becomes necessary: Any necessary removal or storage shall occur only by mutual agreement or a neutral third party and shall not constitute abandonment or waiver of claims. DF-24-18010 3 of 13

...EADLINES A. IMMEDIATE COMPLIANCE DEADLINE. • Petitioner shall fully comply with these Orders by 2:00pm on the Date of Signing. Compliance includes tender of the required funds and filing written proof of compliance via e- file immediately upon completion. • Compliance requires immediately available funds (same-day wire or other real-time transfer). Initiation of an ACH or other delayed-settlement transfer does not constitute compliance. B. COERCIVE INCENTIVE FOR COMPLIANCE W/ DAILY ACCRUAL. • If Petitioner fails to fully complete the funds transfer by 2:...

...’s sworn affidavit establishes that Respondent is medically incapacitated, unable to relocate, and at risk of homelessness absent timely receipt of funds acknowledged or conceded as belonging to Respondent. In the event the opposing party fails to timely comply with a court-ordered payment obligation without good cause, and such failure foreseeably places Respondent at risk of homelessness or irreparable harm, the Court may deem such noncompliance evidence of bad faith, obstruction, or litigation misconduct, and may consider such conduct in assessing cre...

...judicial review is available. I will be unable to stabilize housing or obtain necessary medical care without emergency relief. 8. Ability to Comply / Scale of Available Funds. Petitioner has the ability to comply with immediate temporary support, and any claim of “lack of funds” is not credible. Even without addressing Petitioner’s ongoing salary, bonuses, or broader estate issues, there are discrete, identifiable funds already disclosed and/or previously acknowledged in this case that demonstrate ample liquidity: § Sign-on bonus: $300,000 total; one-ha...

• If VEIP was withdrawn: o Approximately $100,000 in liquid funds would have been received o Community portion approximately $50,000 • If VEIP was not withdrawn: o A 50% employer match would have been credited as of Dec. 31, 2025 o VEIP balance would have fully vested immediately o Approximately $195,000 would be immediately accessible o Community portion approximately $97,500 • Total Identifiable Funds from Only These 3 Recent Events (Excluding Over $600,000 in Additional Marital Assets & Forms of Compensation) • Minimum identifiable assets: § (Sign-on...

...Nounilateral inventories/claims: No party may unilaterally inventory, designate, or claim exclusive ownership of household property during the pendency of this Order. e Neutral handling if movement becomes necessary: Any necessary removal or storage shall occur only by mutual agreement or a neutral third party and shall not constitute abandonment or waiver of claims. DF-24-18010 3 of 13 Copy from re:SearchTX

...DEADLINES A. IMMEDIATE COMPLIANCE DEADLINE. Petitioner shall fully comply with these Orders by 2:00pm on the Date of Signing. Compliance includes tender of the required funds and filing written proof of compliance via ¢- file immediately upon completion. e Compliance requires immediately available funds (same-day wire or other real-time transfer). Initiation of an ACH or other delayed-settlement transfer does not constitute compliance. B. COERCIVE INCENTIVE FOR COMPLIANCE W/ DAILY ACCRUAL. e If Petitioner fails to fully complete the funds transfer by 2:...

...'s sworn affidavit establishes that Respondent is medically incapacitated, unable to relocate, and at risk of homelessness absent timely receipt of funds acknowledged or conceded as belonging to Respondent. In the event the opposing party fails to timely comply with a court-ordered payment obligation without good cause, and such failure foreseeably places Respondent at risk of homelessness or irreparable harm, the Court may deem such noncompliance evidence of bad faith, obstruction, or litigation misconduct, and may consider such conduct in assessing cre...

...judicial review is available. | will be unable to stabilize housing or obtain necessary medical care without emergency relief. 8. Ability to Comply / Scale of Available Funds. Petitioner has the ability to comply with immediate temporary support, and any claim of "lack of funds" is not credible. Even without addressing Petitioner's ongoing salary, bonuses, or broader estate issues, there are discrete, identifiable funds already disclosed and/or previously acknowledged in this case that demonstrate ample liquidity: Sign-on bonus: $300,000 total; one-half...

e If VEIP was withdrawn: o Approximately $100,000 in liquid funds would have been received o Community portion approximately $50,000 © If VEIP was not withdrawn: o A50% employer match would have been credited as of Dec. 31, 2025 o VEIP balance would have fully vested immediately o Approximately $195,000 would be immediately accessible o Community portion approximately $97,500 e Total Identifiable Funds from Only These 3 Recent Events (Excluding Over $600,000 in Additional Marital Assets & Forms of Compensation) e Minimum identifiable assets: « (Sign-on $...

...Nounilateral inventories/claims: No party may unilaterally inventory, designate, or claim exclusive ownership of household property during the pendency of this Order. e Neutral handling if movement becomes necessary: Any necessary removal or storage shall occur only by mutual agreement or a neutral third party and shall not constitute abandonment or waiver of claims. DF-24-18010 Copy from re:SearchTX