DF-24-18010 Litigation Record Search

PROTECTIVE ORDER EXHIBIT MAP Each exhibit uses a 3-row block: ID | NAME | LINK 1 / LINK 2 | DESCRIPTION. Add new exhibits by copying any complete 3-row block. LEASE BUYOUT / MANUFACTURED EVICTION EVIDENCE K https://tinyurl.com/LeaseFraud Supports manufactured eviction/access pressure, housing instability, predicted cleanout, and third-party access setup. DESTROYED AT&T MODEM / SECURITY-SYSTEM DISABLEMENT L https://tinyurl.com/DestroyedModem Shows destruction/disablement of internet, security, alarm, and camera infrastructure during or after April 16. SIG...

...m what we personally observed, Jason was the person in fear at that time, not Gwendolyn. 21. Jason later informed us that he had found documentation showing a pattern of protective-order filings and that he had paid a legal retainer. The next thing we learned was that Gwendolyn had reported his legal retainer as fraud and stated it was an accident; while simultaneously filing for a protective order. 22. The past sixteen months have been difficult to watch. Jason has not been allowed to stabilize. He has struggled to maintain access to medical care and pr...

...ong- term care needs escalated for Applicant’s father following approximately $50,000 loaned to Applicant beginning in December 2024 to defend against Petitioner’s false protective order application—an Petitioner has stated that Applicant would never see inside her bank accounts and that he “will die trying” in connection with third-party subpoena rights. 7 of 19

...bench trial in the 254th District Court. The report states that Petitioner was not licensed for that firearm. The firearm issue is directly relevant to this request for protective relief and to the requested Rule 204 psychological examination. Petitioner’s acquisition of a firearm in connection with a property dispute involving community assets, while simultaneously engaging in escalating property interference, false reporting, financial obstruction, litigation obstruction, and coordinated entry into the marital residence, presents a serious and immedia...

...rm that there has been no break-in, no forced entry, no damaged locks, and no unauthorized access to either storage unit following the separation of property. PATTERN OF FALSE POLICE REPORTS & CULMATIVE EFFECT ON RESPONDENT DF-24-18010 1 of 7

...equest that this context be noted, as the stated need for protection is premised on allegations that are demonstrably false and unsupported by objective evidence. 11. NO PROTECTIVE ORDER / NO VIOLENT HISTORY. A protective order sought by Petitioner against me was denied. I have no history of violence, no history of domestic violence, and no criminal history involving threats or harm to any person. I have never assaulted, threatened, or injured anyone. 12. PURPOSE OF CLARIFICATION. I submit this clarification to ensure the report accurately reflects the f...

on the date and to the persons listed below. The rules governing Envelope ID: 109910688 Filing Code Description: Affidavit Filing Description: AFFIDAVIT ON PUBLIC STORAGE THEFT ACCUSATIONS AND PETITIONERS ACQUISITION OF WEAPON DURING PROCEEDINGS Status as of 1/12/2026 3:43 PM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Jason McKemie jmckemie@mckemie.net 1/12/2026 4:12:09 AM SENT Gwendolyn Ulijasz McKemie GUlijasz@gmail.com 1/12/2026 4:12:09 AM SENT

...edevice NARRATIVENARRATIVE OnOn thethe listedlisted date,date, II waswas dispatcheddispatched toto thethe listedlisted locationlocation forfor aa violationviolation ofof protectiveprotective orderorder report.report. UponUpon arrivalarrival toto thethe listedlisted location,location, II mademade contactcontact withwith V1.V1. II waswas advisedadvised V1V1 foundfound thethe listedlisted trackingtracking devicedevice onon inin herher vehiclevehicle betweenbetween thethe driver'sdriver's seatseat andand centercenter consoleconsole onon thethe listedlisted d...

TORN HE KEN PAXTON ATTORNEY GENERAL OF TEXAS MarchMarch 25,25, 20252025 Mr.Mr. JamesJames KoppKopp AssistantAssistant CityCity AttorneyAttorney CityCity ofof SanSan AntonioAntonio P.O.P.O. BoxBox 839966839966 SanSan Antonio,Antonio, TexasTexas 78283-396678283-3966 OR2025-010505OR2025-010505 Re:Re: RequestRequest forfor W671378-013025.W671378-013025. DearDear Mr.Mr. Kopp:Kopp: TheThe OfficeOffice ofof thethe AttorneyAttorney GeneralGeneral hashas receivedreceived youryour requestrequest forfor aa rulingruling andand assignedassigned youryour requestreques...

...des:includes: •• OverOver20 20yearsyearsof ofdocumenteddocumentedfalsefalseaccusations,accusations,fraudulentfraudulentpolicepolicereports,reports,andandbaselessbaseless protectiveprotective orderorder requestsrequests againstagainst formerformer partners,partners, employers,employers, andand others.others. •• At leastAt least11 11knownknownmaliciousmaliciousprotectiveprotectiveorderorderfilings,filings,whichwhichsheshehashasbeenbeenexceptionallyexceptionally successfulsuccessful atat obtaining.obtaining. GwenGwen utilizesutilizes aa aa processprocess ofo...

...ith pastpast victims,victims, II amam thethe onlyonly oneone toto havehave escapedescaped eithereither thethe criminalcriminal accusationsaccusations mademadeoror thethe protectiveprotective orders;orders; eveneven moremore both.both. ThisThis protectiveprotective orderorder shieldsshields GwenGwen whilewhile atat thethe samesame timetime createscreates significantsignificant vulnerabilitiesvulnerabilities forfor herher targetstargets whichwhich sheshe persistentlypersistently exploitsexploits overover thethe yearsyears toto follow.follow. •• A documented...

...ON TO STRIKE IMPROPER EXPERT DESIGNATIONS AND TO LIMIT TESTIMONY OF OPPOSING COUNSEL • 04/24/2025 (Entry 56) — 1 page — MOTION FOR NOTICE PRIOR TO ANY DISMISSAL PROPOSED ORDER ON MOTION FOR NOTICE PRIOR TO ANY DISMISSAL • 04/24/2025 (Entry 60) — 3 pages — MOTION TO DESIGNATE PRO SE REPRESENTATION AND REQUEST FOR EQUAL ACCESS • 04/24/2025 (Entry 57) — 4 pages — MOTION FOR NOTICE PRIOR TO ANY DISMISSAL NOTICE PRIOR TO ANY DISMISSAL • 04/24/2025 (Entry 58) — 1 page — ORDER ON MOTION TO DESIGNATE PRO SE REPRESENTATION AND REQUEST FOR EQUAL ACCESS PROPOSED OR...

...s — PROPOSED ORDER ON EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS • 01/12/2026 (Entry 173) — 10 pages — EMERGENCY MOTION TO TEMORARY STAY OR IN THE ALTERNATIVE, IMPOSE PROTECTIVE CONDITIONS ON COURT-AUTHORIZED PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY • 01/12/2026 (Entry 172) — 5 pages — PROPOSED ORDER ON EMERGENCY MOTION TO TEMPORARILY STAY OR, IN THE ALTERNATIVE, IMPOSE PROTECTIVE CONDITIONS ON COURT-AUTHORIZED PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY • 01/12/2026 (Entry 170) — 4 pages — ORDER ON EMERGENCY TRO PROPOSED ORDER FOR EMERGENCY TRO...

• 01/12/2026 (Entry 168) — 3 pages — ORDER ON EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS EXTEND RENT REGISTRY DEADLINE, AND PRESERVE PROPERTY PROPOSED ORDER ON EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS • 01/12/2026 (Entry 166) — 4 pages — AFFIDAVIT ON MANUFACTURED ALLEGATIONS & CONCERN FOR PROPERTY RETRIEVAL / CLEAN OUT AFFIDAVIT - MANUFACTURED ALLEGATIONS • 01/12/2026 (Entry 164) — 6 pages — EMERGENCY MOTION ON MEDICAL HARM • 01/12/2026 (Entry 162) — 4 pages — ORDER ON EMERGENCY TRO PROPOSED ORDER/JUDGMENT • 01/12/2026 (Entry 180) — 11 pages — MO...

...EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS • 01/12/2026 (Entry 172) — 5 pages — PROPOSED ORDER ON EMERGENCY MOTION TO TEMPORARILY STAY OR, IN THE ALTERNATIVE, IMPOSE PROTECTIVE CONDITIONS ON COURT-AUTHORIZED PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY • 01/12/2026 (Entry 168) — 3 pages — ORDER ON EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS EXTEND RENT REGISTRY DEADLINE, AND PRESERVE PROPERTY PROPOSED ORDER ON EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS • 01/12/2026 (Entry 166) — 4 pages — AFFIDAVIT ON MANUFACTURED ALLEGATIONS & CONCERN FOR PROPE...

...e spinal surgery. On December11,2024, while recovering from surgery, Jason discovered substantial documentation showing along documented pattern of malicious litigation, protective-order use, false allegations, settlement concealment, retaliation, and silencing tactics involving Petitioner's former romantic partners, spouses, spouses of former spouses, neighbors, a landlord, and at least three prior employers. Jason contacted law enforcement on December11,2024. He warned that Petitioner would come after him through the same pattern: false police reports,...

ll. THE FIRST RECORDED EVENT IN THIS CASE MATTERS On January 7, 2025, at the protective-order hearing, Donna Tomlinson of Hargrave Family Law appeared and moved to withdraw from representing Petitioner. Judge Sandra Jackson expressed concern because serious allegations had been made, the matter involved a protective order, and a continuance had already been granted. Donna Tomlinson then stated on the record that proceeding forward with her representation of Gwendolyn Ulijasz-McKemie would violate her ethical oath as an officer of the court. That was not...

...STATEMENTS, AND POST-DECREE DANGER The Court should not assume that signing a decree ends this. Jason has repeatedly warned that Petitioner will not stop until she has a protective order, criminal leverage, or a felony-level narrative capable of silencing him. Petitioner's own inventory lists a Glock semi-automatic gun acquired in October 2025. Jason has identified a police report where Petitioner stated she needed a gun due to a property dispute. Jason has also identified writings in the sealed submission for in-camera review concerning murder fantasies...

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

Jason cannot leave this litigation without enforceable protection against knowingly false criminal allegations, stolen-property-based accusations, healthcare interference, and witness suppression. Without intervention, this does not end. XIX. THE RECORD HAS BEEN SCREAMING FOR EIGHTEEN MONTHS The issue before the Court is no longer whether the parties disagree. The issue is whether this record can honestly be described as ordinary. This record contains more than 120 pleadings, more than 1,400 pages of filings, repeated requests for a court reporter, repea...

...care access is signed or enforced. 10.The Court has been notified that SAPD records bear on false reporting, device/tracking allegations, healthcare-benefit allegations, protective-order misuse, credibility, trial readiness, and chain of custody for stolen property. 11. The Court has been notified that financial source records remain incomplete, structurally defective, and inadequate for final property division absent institution-origin verification. 12.The Court has been notified that recent McNally filings bear on witness suppression, protective-order...

..., source-record, de novo, Rule 204, sanctions, financial-relief, and non-waiver issues before any decree is signed. IV. THE PROPOSED DECREE WOULD REWARD STOLEN EVIDENCE, FALSE REPORTING, HEALTHCARE OBSTRUCTION, AND SOURCE- RECORD CONCEALMENT This was not a neutral default event. Petitioner's proposed decree attempts to convert Petitioner's manufactured collapse into final relief. Respondent has repeatedly placed before the Court that Petitioner unlawfully entered the residence, stole hard drives, stole evidence repositories, stole legal work product, sto...

...trangulation, healthcare obstruction, source-record concealment, evidence theft, hard-drive theft, legal-work-product theft, trial-material theft, 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...

...ink, itigation equipment, medications, or device evidence. 6. Denial in full of any request by Petitioner or her counsel for attorney's fees, costs, sanctions, expenses, protective expenses, vendor costs, or any other fee shifting against Respondent. THIS MOTION IS NOT BASED MERELY ON ADVERSE RULINGS This Motion is not based merely on adverse rulings. It is based on the current record, the appearance of prejudgment, and new material developments since the prior recusal proceedings, including evidence theft, stolen hard drives, stolen trial materials, sto...

...ator or person acting with, for, at the direction of, or for the benefit of Petitioner. Respondent objects to any award of fees, costs, expert expenses, vendor expenses, protective- order expenses, discovery expenses, travel expenses, pro hac vice expenses, or sanctions against Respondent. Any claim that Respondent caused delay is false. The delay was caused by Petitioner's fraud, perjury, concealment, discovery obstruction, source-record concealment, healthcare obstruction, financial sabotage, evidence theft, trial-material theft, hard-drive theft, lega...

15. Financial sabotage, financial strangulation, concealment or dissipation of marital assets, source-record concealment, account wipeouts, disguised transfers, false characterization of equity/investment compensation, and obstruction of estate reconstruction; 16. Manufactured eviction, concealed lease buyout, landlord/lease-buyout concealment, county court, bankruptcy, or civil remedies; 17.Attorneymisconduct,counselparticipation,former-counselparticipation,current-counsel participation, pro hac vice counsel conduct, law-firm conduct, discovery obstruct...

...ATE NOTICE Petitioner and her counsel will say this is late. That is false. Respondent has warned the Court for seventeen months that Petitioner 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 ve...

and Jason Parro. Those matters are relevant because this case follows the same pattern: false narratives, police involvement, protective-order weaponization, financial strangulation, reputational destruction, healthcare interference, and itigation used as a method of control and destruction. Respondent told law enforcement that he feared for his safety and future because he had discovered extensive documentation showing a long pattern of malicious litigation and that Petitioner was going to file false police reports and a false protective order against h...

If trial proceeds today and final orders terminate or impair healthcare coverage, Respondent may lose the surgeries and medical care that Petitioner's healthcare obstruction already delayed. Final trial today would reward healthcare obstruction and place Respondent's survival at risk. EVIDENCE THEFT, NOT A PROPERTY DISPUTE Petitioner was not authorized to enter the residence. She was barred from entering and had been repeatedly identified as a risk for theft, destruction, manufactured allegations, law- enforcement escalation, and evidence sabotage. This...

...ATE NOTICE Petitioner and her counsel will say this is late. That is false. Respondent has warned the Court for seventeen months that Petitioner 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 ve...

and Jason Parro. Those matters are relevant because this case follows the same pattern: false narratives, police involvement, protective-order weaponization, financial strangulation, reputational destruction, healthcare interference, and litigation used as a method of control and destruction. Respondent told law enforcement that he feared for his safety and future because he had discovered extensive documentation showing a long pattern of malicious litigation and that Petitioner was going to file false police reports and a false protective order against...

If trial proceeds today and final orders terminate or impair healthcare coverage, Respondent may lose the surgeries and medical care that Petitioner’s healthcare obstruction already delayed. Final trial today would reward healthcare obstruction and place Respondent’s survival at risk. EVIDENCE THEFT, NOT A PROPERTY DISPUTE Petitioner was not authorized to enter the residence. She was barred from entering and had been repeatedly identified as a risk for theft, destruction, manufactured allegations, law- enforcement escalation, and evidence sabotage. This...

...enial or failure to order return of Jason McKemie's stolen evidence repositories and stolen property. 16.The denial or failure to address Petitioner's Counter-Motion for Protective Order in full, including the need to deny any protective order that blocks third-party source-record verification. 17.The denial, grant, implied grant, carry-forward, reservation, or failure to reject Petitioner's request for attorney's fees, costs, protective expenses, expert/vendor expenses, discovery expenses, or any cost shifting against Jason McKemie. Jason specifically r...

...the trial-readiness issues. 12.No merits adjudication occurred on the sanctions/counsel-certification issues. 13.No merits adjudication occurred on whether Petitioner's protective order seeks protection from improper discovery or protection from verification. The Associate Judge's denial therefore rests on a procedurally incomplete presentation, not on a full evidentiary determination of the merits. Texas Family Code § 201.015 exists for this exact reason: the District Judge must conduct a fresh hearing on the specified issues and permit the parties to...

...xpands the Associate Judge's Report; 2. adds findings not made at the hearing; 3. converts the denial into a trial-readiness finding; 4. grants or preserves Petitioner's protective order; 5. grants or preserves Petitioner's fees, costs, protective expenses, vendor expenses, expert expenses, or cost-shifting requests; 6. blocks third-party source-record verification; 7. restricts Jason's ability to obtain financial source records; 8. restricts Jason's ability to obtain QLE/benefits/HSA/FSA/healthcare source records; 9. restricts Jason's ability to obtain...

...e June 11,2026, trial setting until the marital estate can be reconstructed from complete, continuous, source-verifiable records; 7. DENY Petitioner's Counter-Motion for Protective Order in full to the extent it blocks, restricts, burdens, delays, chills, or prevents source-record verification; 8. DENY Petitioner's request for attorney's fees, court costs, protective expenses, expert/vendor expenses, discovery expenses, or any cost shifting against Jason McKemie in full, with no later prove-up, no reserved entitlement, and no cost shifting; 9. ORDER Peti...

...h Jason McKemie is entitled. 19. Jason further requests that the District Judge conduct de novo review of the sanctions, show-cause, counsel-certification, fee-shifting, protective-order abuse, and source- record verification issues to the extent those issues were raised by Petitioner's response, Petitioner's Counter-Motion for Protective Order, Jonathan Drake Steele's or the Associate Judge's denial, refusal, failure to hear, failure to consider, or failure to rule. 20.Jason further requests that, after de novo review, the District Judge reject, modify,...

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

...bpoenas Exhibit 6 Petitioner's Response to Respondent's Motion for Enforcement, Sanctions, Continuance, And Leave to Issue Third-Party Subpoenas, And Counter- Motion for Protective Order And For Other Appropriate Relief Exhibit -7 Respondent's Reply in Support of Enforcement, Sanctions, Continuance, And Leave; Objection to Petitioner's Bad-Faith Protective Order And Fee Request; And Request for Sanctions, Show-Cause, Counsel Certification, Fee Shifting, Forensic Accounting, Estate Reconstitution, Disproportionate Division, And Source-Record Verification...

...EMIE JASON MCKEMIE PETITIONER'S RESPONSE TO RESPONDENT'S MOTION FOR ENFORCEMENT, SANCTIONS, CONTINUANCE, AND LEAVE TO ISSUE THIRD-PARTY SUBPOENAS, AND COUNTER-MOTION FOR PROTECTIVE ORDER AND FOR OTHER APPROPRIATE RELIEF TO THE HONORABLE JUDGE OF SAID COURT: Petitioner Gwendolyn Ulijasz-McKemie ("Petitioner" or "Gwen") files this Response to Respondent Jason McKemie's May 26, 2026 Motion for Enforcement, Sanctions, Continuance, and Leave to Issue Third-Party Subpoenas (the "Motion") and this Counter-Motion for Protective Order, and respectfully shows the...

...). Respondent's failure to pursue available nonparty discovery during the discovery period is not good cause to continue the trial. B. Discovery, nonparty subpoenas, and protective orders. Rule 190.5 permits modification of a discovery control plan only when the interest of justice requires it. Rule 191.2 requires a meaningful effort to resolve discovery disputes before court intervention. Rules 192.3 and 192.4 require discovery to be relevant, nonprivileged, reasonably tailored, and proportional. Rule 192.6 authorizes protective orders to prevent undue...

...deny those requests without prejudice to properly noticed, evidence-supported motion practice if a proper record is later developed. VI. Petitioner's Counter-Motion for Protective Order Petitioner moves under Rules 192.6, 176.7, and 215.3 for a protective order. The requested order is necessary to prevent undue burden, unnecessary expense, harassment, annoyance, invasion of privacy and property rights, and invasion of attorney-client privilege, attorney work product, consulting-expert protections, and litigation strategy. Petitioner requests that the pr...

...l 16 theft, spoliation, stay violation, turnover, estate-property damages, property ownership, or forensic relief on the present record. VII. Attorney's Fees, Costs, and Protective Expenses Petitioner requests an award of reasonable attorney's fees, court costs, expenses, and protective expenses incurred in responding to the Motion and prosecuting this Counter-Motion for Protective Order under Texas Rule of Civil Procedure 215.3, the Court's discovery and protective-order authority, and applicable Family Code fee provisions, including Family Code §§ 6.50...

...althcare enforcement, property return, compensation, April 16 theft remedies, forensic seizure, non-use relief, and spoliation findings on the current record; 6. enter a protective order prohibiting overbroad, privileged, harassing, and litigation-vendor discovery, and prohibiting renewed or expanded nonparty subpoena practice absent a separate, properly supported motion, service of actual proposed subpoenas, and a privilege protocol; 7. enter mutual preservation language with no findings of wrongdoing, theft, spoliation, property theft, evidence suppres...

...from the automatic stay under 11 U.S.C. § 362(b)(2) proceeding on June 11, 2026 as scheduled; 9. award Petitioner reasonable attorney's fees, court costs, expenses, and protective expenses incurred in responding to the Motion and obtaining protective relief, with the amount reserved for later prove-up if necessary; and 10. grant Petitioner all further relief to which she may be justly entitled. Respectfully submitted, Jonathan D. Steele BEERMANN LLP 161 N. Clark Street, Suite 3000 Chicago, Illinois 60601 ARDC No. 6308171 jsteele@beermannlaw.com By: /s/...

...ar No. 24062589 terra@armstronglawtexas.com Envelope ID: 115516576 Filing Code Description: Response Filing Description: TO MOTION FOR ENFORCEMENT AND COUNTER MOTION FOR PROTECTIVE ORDER Status as of 6/1/2026 10:16 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Kim Jones kjones@sullivancook.com 5/29/2026 3:42:21 PM SENT Jeffrey ECook jcook@sullivancook.com 5/29/2026 3:42:21 PM SENT Tiffany Castenada tcastenada@sullivancook.com 5/29/2026 3:42:21 PM SENT William CCook wcook@sullivancook.com 5/29/2026 3:42:21 PM SENT Rebecca LArmstrong...

DF-24-18010 NO. THE MARRIAGE OF § § § RESPONDENT'S REPLY IN SUPPORT OF ENFORCEMENT, SANCTIONS, CONTINUANCE, AND LEAVE; OBJECTION TO PETITIONER'S BAD-FAITH PROTECTIVE ORDER AND FEE REQUEST; AND REQUEST FOR SANCTIONS, SHOW-CAUSE, COUNSEL CERTIFICATION, FEE SHIFTING, FORENSIC ACCOUNTING, ESTATE RECONSTITUTION, DISPROPORTIONATE DIVISION, AND SOURCE-RECORD VERIFICATION TO THE HONORABLE JUDGE OF SAID COURT: Jason McKemie files this Reply in Support of his Motion for Enforcement, Sanctions, Continuance, and Leave to Issue Third-Party Subpoenas, and objects to P...

...e the third-party contractor payment records? Where are the April 16 chain-of-custody records? Petitioner does not want those questions answered. That is why she seeks a protective order. The problem is not merely that records are missing. The problem is that Petitioner's conduct is fundamentally inconsistent with the narrative she asks this Court to accept. e A person genuinely seeking protection does not need missing account statements, missing payroll records, unsupported loan claims, disguised equity investments, rotating credit-card accounts, missin...

e Apperson genuinely seeking protection does not report a legal retainer as fraud, cut off access to counsel, and then escalate into protective-order litigation. e Aperson genuinely seeking protection does not testify that she has not and will not interfere with healthcare and then submit a Qualifying Life Event terminating coverage before a scheduled surgery. e Aperson genuinely seeking protection does not report a Health Savings Account card ost or stolen while the other party is hospitalized and actively seeking medical treatment. e Aperson genuinely...

...production. Any attorney who certified, sponsored, presented, defended, relied upon, or failed to correct this production belongs in the sanctions inquiry. Petitioner's protective order is the tell. She is not seeking protection from improper discovery. She is seeking protection from the records that will determine whether her disclosures are true. The books either reconcile or they do not. The loans either have funded transfers or they do not. The VEIP records either exist or they do not. The tax transcripts either support her position or they do not....

...d not cure. Instead, Petitioner and counsel defended the defective production, demanded trial, sought fees against the party harmed by the obstruction, and now ask for a protective order to prevent third-party source verification. That is not a procedural defect by Jason. 5 of 1 10 DF-24-18010 Reply in Support of Enforcement, Sanctions, Continuance, and Leave Copy from re:SearchTX

...attorney who certified, sponsored, presented, defended, relied upon, or attempted to shield materially incomplete financial production from verification. V. PETITIONER'S PROTECTIVE ORDER IS BAD-FAITH DISCOVERY OBSTRUCTION. in n full. Petitioner's protective order should be denied Petitioner is not asking the Court to protect privileged communications. She is asking the Court to protect missing source records from being tested. She wants protection from banks, payroll custodians, Accenture, equity administrators, VEIP records, tax records, loan records, l...

...ks protection from the cure. e The Court should not permit that. Xill. PRAYER Jason McKemie respectfully requests that the Court: 1. DENY Petitioner's Counter-Motion for Protective Order in full; 2 DENY Petitioner's request for attorney's fees, costs, protective expenses, expert/vendor expenses, and any cost shifting against Jason McKemie in full, with no later prove-up and no reservation; 3 FIND that Petitioner's protective-order request is a bad-faith attempt to block source-record verification after prolonged noncompliance; 13 of 110 DF-24-18010 Reply...

...would convert Petitioner's noncompliance, false certification, discovery obstruction, and evidence theft into litigation advantage. 10. | request denial of Petitioner's protective order, denial all fees/costs/protective expenses against me, authorization of third-party subpoenas, sworn counsel certification, trial continuance, and a sanctions/show-cause hearing. Jason McKemie 539 W. Commerce St., Suite 2010 Dallas, Texas 75208 214-868-4901 jmckemie@mckemie.net accordance with the Texas Rules of Civil Procedure on June .2026. Cf Jason McKemie 16 of 110 D...

...s MOTION TO STRIKE IMPROPER EXPERT DESIGNATIONS AND TO LIMIT TESTIMONY OF OPPOSING COUNSEL 04/24/2025 (Entry 56) 1 page MOTION FOR NOTICE PRIOR TO ANY DISMISSAL PROPOSED ORDER ON MOTION FOR NOTICE PRIOR TO ANY DISMISSAL 04/24/2025 (Entry 60) 3 pages MOTION TO DESIGNATE PRO SE REPRESENTATION AND REQUEST FOR EQUAL ACCESS 04/24/2025 (Entry 57) 4 pages MOTION FOR NOTICE PRIOR TO ANY DISMISSAL NOTICE PRIOR TO ANY DISMISSAL 04/24/2025 (Entry 58) 1 page ORDER ON MOTION TO DESIGNATE PRO SE REPRESENTATION AND REQUEST FOR EQUAL ACCESS PROPOSED ORDER ON MOTION TO D...

...) 3 pages PROPOSED ORDER ON EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS 01/12/2026 (Entry 173) 10 pages EMERGENCY MOTION TO TEMORARY STAY OR IN THE ALTERNATIVE, IMPOSE PROTECTIVE CONDITIONS ON COURT-AUTHORIZED PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY 01/12/2026 (Entry 172) 5 pages PROPOSED ORDER ON EMERGENCY MOTION TO TEMPORARILY STAY OR, IN THE ALTERNATIVE, IMPOSE PROTECTIVE CONDITIONS ON COURT-AUTHORIZED PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY 01/12/2026 (Entry 170) 4 pages ORDER ON EMERGENCY TRO PROPOSED ORDER FOR EMERGENCY TRO 01/12/2026 (...

...ER ON EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS e 01/12/2026 (Entry 172) 5pages PROPOSED ORDER ON EMERGENCY MOTION TO TEMPORARILY STAY OR, IN THE ALTERNATIVE, IMPOSE PROTECTIVE CONDITIONS ON COURT-AUTHORIZED PROPERTY RETRIEVAL DUE TO MEDICAL INCAPACITY e 01/12/2026 (Entry 168) 3pages ORDER ON EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS EXTEND RENT REGISTRY DEADLINE, AND PRESERVE PROPERTY PROPOSED ORDER ON EMERGENCY MOTION TO STAY EVICTION PROCEEDINGS ¢ 01/12/2026 (Entry 166) 4pages AFFIDAVITON MANUFACTURED ALLEGATIONS & CONCERN FOR - PROPERTY RETRI...

...imum exposure cannot exceed two weeks of charges, and | bear none. Other Legal Expenses Pald COGNIZANT SETTLEMENT All Billing needed from all law offices Legal Costs for Protective Order, Contempt, Extenstlon of Protective Order; Billing Statements Needed. MISSING VEIP SUMMARY Monthly Statements Required RETIREMENT AIG AIG GU000005 Daily Snapshots, 6mo Summary are Not Acceptable, Lacks Monthly Statemnents RETIREMENT AMERIPRISE AMERIP 2025-02-0 Ameriprise IRA & Roth IRA Acct. Summary.pdf GUOO0155 Annual Reports are not Acceptable Require Monthoy Statement...

...SURGERY REHABILITATION EQUIPMENT, AND APPROXIMATELY $30,000 IN SURVIVAL FUNDS AS "FRAUD" « PROMISED AN AMICABLE RESOLUTION WHILE SIMULTANEOUSLY RUSHING COUNSEL TO FILE A PROTECTIVE ORDER BASED UPON ALLEGATIONS RESPONDENT CONTENDS WERE FALSE THIS IS NOT A PICTURE OF FINANCIAL DISTRESS. IT IS A PATTERN OF FINANCIAL DEPRIVATION, NARRATIVE MANUFACTURING, AND STRATEGIC ESTATE DEVALUATION. ahd] GU Copy from re:SearchTX

...nial or failure to order return of Jason McKemie’s stolen evidence repositories and stolen property. 16. The denial or failure to address Petitioner’s Counter-Motion for Protective Order in full, including the need to deny any protective order that blocks third-party source-record verification. 17. The denial, grant, implied grant, carry-forward, reservation, or failure to reject Petitioner’s request for attorney’s fees, costs, protective expenses, expert/vendor expenses, discovery expenses, or any cost shifting against Jason McKemie. Jason specifically...

...he trial-readiness issues. 12. No merits adjudication occurred on the sanctions/counsel-certification issues. 13. No merits adjudication occurred on whether Petitioner’s protective order seeks protection from improper discovery or protection from verification. The Associate Judge’s denial therefore rests on a procedurally incomplete presentation, not on a full evidentiary determination of the merits. Texas Family Code § 201.015 exists for this exact reason: the District Judge must conduct a fresh hearing on the specified issues and permit the parties to...

...xpands the Associate Judge’s Report; 2. adds findings not made at the hearing; 3. converts the denial into a trial-readiness finding; 4. grants or preserves Petitioner’s protective order; 5. grants or preserves Petitioner’s fees, costs, protective expenses, vendor expenses, expert expenses, or cost-shifting requests; 6. blocks third-party source-record verification; 7. restricts Jason’s ability to obtain financial source records; 8. restricts Jason’s ability to obtain QLE/benefits/HSA/FSA/healthcare source records; 9. restricts Jason’s ability to obtain...

...June 11, 2026, trial setting until the marital estate can be reconstructed from complete, continuous, source-verifiable records; 7. DENY Petitioner’s Counter-Motion for Protective Order in full to the extent it blocks, restricts, burdens, delays, chills, or prevents source-record verification; 8. DENY Petitioner’s request for attorney’s fees, court costs, protective expenses, expert/vendor expenses, discovery expenses, or any cost shifting against Jason McKemie in full, with no later prove-up, no reserved entitlement, and no cost shifting; 9. ORDER Peti...

...h Jason McKemie is entitled. 19. Jason further requests that the District Judge conduct de novo review of the sanctions, show-cause, counsel-certification, fee-shifting, protective-order abuse, and source- record verification issues to the extent those issues were raised by Petitioner’s response, Petitioner’s Counter-Motion for Protective Order, Jonathan Drake Steele’s or the Associate Judge’s denial, refusal, failure to hear, failure to consider, or failure to rule. 20. Jason further requests that, after de novo review, the District Judge reject, modify...

...nd misleading record, because the evidence exists; it simply was not noticed, reached, admitted, or fully presented at that hearing. 16. I request denial of Petitioner’s protective order, denial of all fees, costs, protective expenses, and cost shifting against me, authorization of third-party subpoenas, sworn counsel certification, trial continuance or abatement, healthcare enforcement, stolen-evidence non-access, non-use, preservation, and return relief, and a sanctions/show-cause hearing. 17. Due to the broken laptop screen, my inability to output to...

...bpoenas Exhibit 6 Petitioner's Response to Respondent's Motion for Enforcement, Sanctions, Continuance, And Leave to Issue Third-Party Subpoenas, And Counter- Motion for Protective Order And For Other Appropriate Relief Exhibit 7 Respondent’s Reply in Support of Enforcement, Sanctions, Continuance, And Leave; Objection to Petitioner’s Bad-Faith Protective Order And Fee Request; And Request for Sanctions, Show-Cause, Counsel Certification, Fee Shifting, Forensic Accounting, Estate Reconstitution, Disproportionate Division, And Source-Record Verification C...

...EMIE JASON MCKEMIE PETITIONER'S RESPONSE TO RESPONDENT'S MOTION FOR ENFORCEMENT, SANCTIONS, CONTINUANCE, AND LEAVE TO ISSUE THIRD-PARTY SUBPOENAS, AND COUNTER-MOTION FOR PROTECTIVE ORDER AND FOR OTHER APPROPRIATE RELIEF TO THE HONORABLE JUDGE OF SAID COURT: Petitioner Gwendolyn Ulijasz-McKemie ("Petitioner" or "Gwen") files this Response to Respondent Jason McKemie's May 26, 2026 Motion for Enforcement, Sanctions, Continuance, and Leave to Issue Third-Party Subpoenas (the "Motion") and this Counter-Motion for Protective Order, and respectfully shows the...

...). Respondent's failure to pursue available nonparty discovery during the discovery period is not good cause to continue the trial. B. Discovery, nonparty subpoenas, and protective orders. Rule 190.5 permits modification of a discovery control plan only when the interest of justice requires it. Rule 191.2 requires a meaningful effort to resolve discovery disputes before court intervention. Rules 192.3 and 192.4 require discovery to be relevant, nonprivileged, reasonably tailored, and proportional. Rule 192.6 authorizes protective orders to prevent undue...

...deny those requests without prejudice to properly noticed, evidence-supported motion practice if a proper record is later developed. VI. Petitioner's Counter-Motion for Protective Order Petitioner moves under Rules 192.6, 176.7, and 215.3 for a protective order. The requested order is necessary to prevent undue burden, unnecessary expense, harassment, annoyance, invasion of privacy and property rights, and invasion of attorney-client privilege, attorney work product, consulting-expert protections, and litigation strategy. Petitioner requests that the pr...

...l 16 theft, spoliation, stay violation, turnover, estate-property damages, property ownership, or forensic relief on the present record. VII. Attorney's Fees, Costs, and Protective Expenses Petitioner requests an award of reasonable attorney's fees, court costs, expenses, and protective expenses incurred in responding to the Motion and prosecuting this Counter-Motion for Protective Order under Texas Rule of Civil Procedure 215.3, the Court's discovery and protective-order authority, and applicable Family Code fee provisions, including Family Code §§ 6.50...

...althcare enforcement, property return, compensation, April 16 theft remedies, forensic seizure, non-use relief, and spoliation findings on the current record; 6. enter a protective order prohibiting overbroad, privileged, harassing, and litigation-vendor discovery, and prohibiting renewed or expanded nonparty subpoena practice absent a separate, properly supported motion, service of actual proposed subpoenas, and a privilege protocol; 7. enter mutual preservation language with no findings of wrongdoing, theft, spoliation, property theft, evidence suppres...

...from the automatic stay under 11 U.S.C. § 362(b)(2) proceeding on June 11, 2026 as scheduled; 9. award Petitioner reasonable attorney's fees, court costs, expenses, and protective expenses incurred in responding to the Motion and obtaining protective relief, with the amount reserved for later prove-up if necessary; and 10. grant Petitioner all further relief to which she may be justly entitled. Respectfully submitted, Jonathan D. Steele BEERMANN LLP 161 N. Clark Street, Suite 3000 Chicago, Illinois 60601 ARDC No. 6308171 jsteele@beermannlaw.com By: /s/...

...ar No. 24062589 terra@armstronglawtexas.com Envelope ID: 115516576 Filing Code Description: Response Filing Description: TO MOTION FOR ENFORCEMENT AND COUNTER MOTION FOR PROTECTIVE ORDER Status as of 6/1/2026 10:16 AM CST Case Contacts Name BarNumber Email TimestampSubmitted Status Kim Jones kjones@sullivancook.com 5/29/2026 3:42:21 PM SENT Jeffrey ECook jcook@sullivancook.com 5/29/2026 3:42:21 PM SENT Tiffany Castenada tcastenada@sullivancook.com 5/29/2026 3:42:21 PM SENT William CCook wcook@sullivancook.com 5/29/2026 3:42:21 PM SENT Rebecca LArmstrong...

...____________________________ THE MARRIAGE OF § § & § RESPONDENT’S REPLY IN SUPPORT OF ENFORCEMENT, SANCTIONS, CONTINUANCE, AND LEAVE; OBJECTION TO PETITIONER’S BAD-FAITH PROTECTIVE ORDER AND FEE REQUEST; AND REQUEST FOR SANCTIONS, SHOW-CAUSE, COUNSEL CERTIFICATION, FEE SHIFTING, FORENSIC ACCOUNTING, ESTATE RECONSTITUTION, DISPROPORTIONATE DIVISION, AND SOURCE-RECORD VERIFICATION TO THE HONORABLE JUDGE OF SAID COURT: Jason McKemie files this Reply in Support of his Motion for Enforcement, Sanctions, Continuance, and Leave to Issue Third-Party Subpoenas, a...

...e the third-party contractor payment records? Where are the April 16 chain-of-custody records? Petitioner does not want those questions answered. That is why she seeks a protective order. The problem is not merely that records are missing. The problem is that Petitioner’s conduct is fundamentally inconsistent with the narrative she asks this Court to accept. • A person genuinely seeking protection does not need missing account statements, missing payroll records, unsupported loan claims, disguised equity investments, rotating credit-card accounts, missin...