DF-24-18010 Litigation Record Search

...G2 https://tinyurl.com/BatteryOfficer Supports officer-battery / resisting-officer context relevant to firearm and physical-danger analysis. AIRTAG / APPLE / SAPD SOURCE RECORDS H https://tinyurl.com/AirTagStalk Shows tracking/stalking narrative inversion and source records contradicting key portions of Petitioner’s tracking allegations. FALSE POLICE REPORT SUMMARY / DPD / SAPD RECORDS I https://tinyurl.com/FalsePoliceReports Shows repeated police reports, investigations, detective contacts, Miranda warnings, and lack of substantiated tracking/stalking f...

...31st, 2025, when Petitioner testified to having less than $4k in a hearing which relief was denied to Applicant once again. Procedural delay as the mechanism of harm and source records contradicting claimed financial distress. Within days of Petitioner’s January 7, 2025 destitution narrative, Petitioner committed to N approximately $50,000 in third-party investigative, reputational-defense, security, and technology-related spending, including an approximately $24,000 payment to Jetty Partners and a minimum monthly commitment of approximately $2,000 to De...

SUMMARY STATEMENT OF RECORDS REQUEST AND RESPONSE MONITORING Petitioner, Jason McKemie, respectfully submits the following documentation in support of ongoing efforts to track, verify, and respond to the extensive volume of police reports, emergency calls, and third-party allegations that have been made against him during the course of this litigation. To ensure transparency and protect against wrongful accusation or arrest, Petitioner files open records requests every Monday with both the Dallas Police Department and the San Antonio Police Department, i...

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Signature Certificate Reference number: HK9CL-6LZWQ-2E3BR-TUZ39 Signer Timestamp Signature Luke Sloan Email: info@decisive-resources.com Sent: 16 Jan 2025 18:29:48 UTC Viewed: 16 Jan 2025 18:30:13 UTC Signed: 16 Jan 2025 18:31:29 UTC Recipient Verification: IP address: 45.134.140.47 ✔Email verified 16 Jan 2025 18:30:13 UTC Location: Atlanta, United States Gwen Ulijasz Email: gwenulijasz@proton.me Sent: 16 Jan 2025 18:29:48 UTC Viewed: 16 Jan 2025 19:09:04 UTC Signed: 16 Jan 2025 19:13:37 UTC Recipient Verification: IP address: 149.22.80.56 ✔Email verifie...

...l 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 214-868-4901 jmckemie@mckemie.net 4 of 5

...bjections; ¢ Recusal No. 2 addressed the subsequent structural collapse in the 302nd District, including broken financial-production assurances, continued concealment of source records, termination of dependent healthcare benefits through submission of a false divorce-based Qualifying Life Event (OLE), repeated healthcare noncompliance, continued discovery noncompliance, and the absence of any fair pathway to trial; and ¢ Recusal No. 3 addresses entirely new and trial-dispositive developments, including a manufactured eviction, the use of non-service and...

...evidence repositories, trial binders, Apple devices, computers, records, tools, briefcase, passport, medications, or seized litigation materials. 5. Require third-party source verification before any decree is signed or enforced, including healthcare/HSA/FSA/OLE/COBRA records, Accenture benefit/payroll records, SAPD/Dallas police records, writ/constable/bodycam/dashcam records, lease buyout records, financial institution records, contractor/vendor billing, and stolen-property chain-of-custody evidence. Il. THIS CASE BEGAN WITH A WARNING, NOT A DIVORCE D...

Vil. FALSE DESTITUTION, THIRD-PARTY CONTRACTORS, AND SOURCE- RECORD COLLAPSE Petitioner declared destitution while earning extraordinary income. Her February 7, 2026 Amended roa $150,000 signing bonus, a $34,225.57 cash bonus, Inventory and Appraisement ists Accenture equity, Accenture 401(k) value, Ameriprise IRA/Roth IRA balances, alleged loans, a BMW M340xi with a claimed $55,902 balance, and a Glock firearm. The same inventory advances a July 26, 2024 marriage date contradicted by the signed informal-marriage declaration and other relationship eviden...

...cord contains more than 120 pleadings, more than 1,400 pages of filings, repeated requests for a court reporter, repeated requests for transcripts, repeated requests for source records, repeated requests for third-party verification, more than seventy emergency filings, repeated healthcare motions, repeated enforcement motions, repeated discovery motions, repeated notices of noncompliance, repeated requests for emergency relief, repeated warnings regarding financial collapse, repeated warnings regarding healthcare obstruction, repeated warnings regarding...

...tion of Informal Marriage dated September 22, 2023. 9. The Court has been notified that healthcare/HSA/FSA/QLE/COBRA compliance remains disputed and requires third-party source verification before any decree affecting healthcare access is signed or enforced. 10.The Court has been notified that SAPD records bear on false reporting, device/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...

...16. stay rendition, signature, entry, transmission, enforcement, fee awards, sanctions, and decree action pending written recusal resolution; 17.orderimmediatethird-partysourceverification of healthcare, HSA/FSA, OLE, COBRA, plan elections, and functional benefits access; 18.ordersource-recordfinancialverification before final property division; 19.orderpreservation,sequestrationawayfromPetitionerandheragents,categorical non-use, categorical non-access, and categorical non-benefit as to all stolen evidence, stolen hard drives, stolen records, stolen Appl...

...s; COBRA, surgery, HSA/FSA access, and Accenture/OLE/COBRA CHF stability. records; medical letters Financial collapse Amended Inventory; Shows false destitution, missing source discovery deficiency filings; records, alleged loans, and Accenture compensation; concealed/omitted assets. financial matrices Third-party contractors Exhibit N2 - Jetty Partners Shows claimed poverty while deploying invoice; Decisive Resources paid proposal/signature certificate investigators/security/privacy/reputation resources. SAPD escalation SAPD26106749; Shows benefits-frau...

healthcare/OQLE/HSA/FSA issues, stolen-evidence issues, source-record issues, de novo/trial- readiness issues, and non-waiver issues identified below. Respondent will supplement exhibits and supporting records as soon as available. Respondent requests that emergency relief 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 me...

9. Respondent's source-record issues; 10.Respondent's Rule 204 issues; 11.Respondent'sfinancial-stabilizationandaccess-to-counselissues; 12.Respondent'ssanctions,contempt,civil-claim,attorney-misconduct,criminal-referral, and non-waiver issues. Respondent objects to any decree that uses a global catchall denial to dispose of Respondent's recusal objection, medical-incapacity objection, no-bridge objection, de novo request, healthcare/OLE/HSA/FSA issues, source-record issues, stolen-evidence issues, Rule 204 request, financial-relief requests, sanctions r...

...ondent also objects because newly received San Antonio Police Department 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 narcot...

..., benefit-access sabotage, or law-enforcement weaponization arising from Respondent's attempt to obtain the healthcare access the Court had already ordered restored. VI. SOURCE RECORDS, ESTATE RECONSTRUCTION, AND FINANCIAL COLLAPSE Respondent objects to any decree dividing the marital estate, confirming separate property, awarding Accenture RSUs, awarding VEIP/ESPP assets, awarding Chase accounts, awarding HSA assets, assigning debt, imposing indemnity, cutting off informal-marriage claims, or denying Respondent's reimbursement, reconstitution, dispropor...

...and litigation-access relief is entered. Respondent's financial collapse is not waiver. It is the result of Petitioner's financial strangulation, healthcare obstruction, source-record 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...

...rule on Respondent's stolen-evidence, stolen hard-drive, stolen legal-work-product, stolen trial-material, and stolen device-evidence objections; 15.rule on Respondent's source-record, forensic-accounting, estate-reconstruction, reimbursement, reconstitution, and disproportionate-division objections; 16.rule on Respondent's Rule 204 request and related threshold-discovery objections; 17.rule on Respondent's financial-stabilization, survival-level temporary relief, access-to- counsel, interim attorney-fee, litigation-expense, and parity relief requests; 1...

...ief, 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-level financial relief, interim attorney's fees, litigation expenses, access-to-counsel relief, fee shifting, sanctions, estate...

...motion under Rule 18a; 7. rule on Respondent's emergency filings, medical-incapacity objections, no-bridge objections, healthcare objections, stolen-evidence objections, source-record objections, de novo/trial-readiness objections, Rule 204 issues, financial- stabilization requests, access-to-counsel requests, sanctions requests, non-waiver filings, and proposed order; 8 . deny in full any request for fees, costs, sanctions, expert expenses, vendor expenses, protective expenses, discovery expenses, or cost shifting against Respondent; 9. preserve all sto...

...ects before seeking recusal. That procedural structure is no longer workable. Trial is set today, the stolen evidence remains unavailable, healthcare remains unresolved, source records remain concealed, Respondent is medically and financially collapsed, and once trial evidence begins Respondent's recusal rights and due-process objections may be materially impaired. begins trial mechanics. At prior trial settings, proceedings moved immediately toward witness calls and evidence. Respondent files before evidence is offered to preserve Rule 18a rights and pr...

evidence theft, hard-drive theft, trial-material theft, false reporting, source-record concealment, and refusal to restore the conditions necessary for trial. Respondent is the party fighting to survive and obtain a fair trial; he is not the source of the obstruction. Respondent files this Motion despite the known risk because the new evidence and current posture do not merely warrant recusal - they demand it. There is no possibility of fair trial when the opposing party violated mutual injunctions, unlawfully entered the residence, stole the hard drives...

...ity where the case is forced to final trial despite known structural impossibility, stolen evidence repositories, stolen hard drives, stolen trial materials, unavailable source financial records, unresolved healthcare/OLE records, unresolved de novo/trial- readiness issues, rejected or unresolved adequate-trial-time requests, and Respondent's present inability to safely appear or present evidence. NEW MATERIAL FACTS SINCE THE PRIOR RECUSAL PROCEEDINGS Since the prior recusal proceedings, Petitioner unlawfully entered the residence in violation of mutual...

...nd was recovering from spinal surgery. Petitioner then committed perjury through false sworn statements suggesting financial helplessness, while concealing substantial resources and spending heavily on counsel, vendors, investigators, and third-party litigation support. Petitioner also brought her sister from out of state to commit coordinated aggravated perjury regarding abuse, stalking, and surveillance allegations directly contradicted by sworn declarations, text messages, security-camera footage, and records subpoenaed by law enforcement. The result...

...ndent's request that no evidence be taken and no final order be signed while Respondent is medically incapacitated and while recusal, healthcare, stolen-evidence, source-record, and trial-readiness issues remain unresolved. V. HEALTHCARE OBSTRUCTION IS PART OF THE MEDICAL EMERGENCY Respondent's current medical emergency cannot be separated from Petitioner's healthcare obstruction. Page 3 of 7 Copy from re:SearchTX

...er31, 2025, despite no divorce decree existing on that date. Petitioner has repeatedly represented compliance while Respondent contests functional compliance and demands source records. The Court should not rely on Petitioner's representations regarding healthcare compliance without source records from the plan administrator, employer, third-party administrators, HSA/FSA administrators, call records, audit trails, QLE submission records, validation records, reversal workflow records, and benefit- functionality records. | ife insurance, AD&D, spouse AD&D,...

...e 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 7 Copy from re:SearchTX

...r 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, legal-work-product theft, false reporting, manufactured eviction, and abuse of process. Respondent expressly preserves and does not waive any claim, defense, objection, sanctions request, contempt request, enforcement request, fee objection, disciplinary complain...

..., fraudulent concealment, financial misrepresentation, false destitution claims, false compliance representations, false healthcare-compliance representations, and false source-record representations; 13.Tortious interference, employment interference, reputational interference, business interference, destruction of livelihood, interference with existing or prospective economic relationships, and interference with Respondent's ability to earn income; 14. Invasion of privacy, unauthorized digital access, unauthorized cloud access, unauthorized access to Bl...

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...

...cy appellate relief, appeal, de novo complaints, recusal complaints, due-process complaints, trial-readiness complaints, court-reporter complaints, discovery complaints, source-record complaints, healthcare complaints, stolen-evidence complaints, or complaints based on inadequate trial time. Respondent objects to any final trial proceeding before de novo/trial-readiness issues are heard, source financial records are produced and verified, healthcare/OQLE records are produced and verified, the signed healthcare order is functionally enforced, stolen hard...

...althcare obstruction, false OLE processing, litigation sabotage, evidence theft, hard-drive theft, stolen legal work product, stolen trial materials, stolen medications, source-record concealment, and a manufactured eviction that Respondent repeatedly warned the Court would be weaponized exactly this way. EMERGENCY RELIEF REQUESTED 1. ABATE, STAY, OR CONTINUE the June 11,2026trial before any trial evidence is taken. 2. Conduct Respondent's timely requested de novo/trial-readiness hearing before trial, with evidence and witness presentation on the specifi...

...ication, obtain safe transportation, preserve his vehicle, obtain records, obtain bodycam/video evidence, and participate meaningfully. 8. Authorize targeted third-party source-record subpoenas and written rulings for financial institutions, Accenture/Businessolver/Aetna/HSA-FSA administrators, landlord/lease-buyout records, SAPD/Dallas/constable records, U-Haul/payment records, Apple/device records, Blink/Google/Facebook/Dropbox/cloud-access records, and vendor/payment records. 9. Preserve all stolen hard drives, evidence repositories, legal work produc...

...vive 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 record also shows the June11,2026 bench trial setting, prior inability-to-pay filings, prior emergency verified continuance/abatement filings, prior healthcare filings, prior discovery filings, prior court-reporter requests, and prior recu...

...ioner's financial sabotage and to the Court's assessment of temporary relief, fee denial, sanctions, trial readiness, and due process. HEALTHCARE OBSTRUCTION, FALSE QLE, SOURCE RECORDS, AND INABILITY TO STABLIZE IF TRIAL CONTINUES Healthcare is not a collateral issue. It is a life-safety issue. Petitioner has obstructed Respondent's access to healthcare since at least December 18, 2024. Respondent has been repeatedly hospitalized with congestive heart failure. Respondent has been without consistent access to heart medications and has suffered repeated me...

...and report numbers regarding the Dallas theft were stolen from his desk. Respondent has requested open records but has not had time to receive them before today's trial. SOURCE FINANCIAL RECORDS AND HEALTHCARE RECORDS REMAIN UNAVAILABLE The financial universe necessary for trial remains concealed. The estate cannot be reconstructed, valued, traced, characterized, divided, or tested without source financial records. Petitioner and her counsel burned months and produced virtually nothing of substance. The two pages produced contained the same transactions,...

...heft, 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 stolen evidence, authorize source-record subpoenas, permit remote a...

...althcare obstruction, false QLE processing, litigation sabotage, evidence theft, hard-drive theft, stolen legal work product, stolen trial materials, stolen medications, source-record concealment, and a manufactured eviction that Respondent repeatedly warned the Court would be weaponized exactly this way. EMERGENCY RELIEF REQUESTED 1. ABATE, STAY, OR CONTINUE the June 11, 2026 trial before any trial evidence is taken. 2. Conduct Respondent’s timely requested de novo/trial-readiness hearing before trial, with evidence and witness presentation on the speci...

...ication, obtain safe transportation, preserve his vehicle, obtain records, obtain bodycam/video evidence, and participate meaningfully. 8. Authorize targeted third-party source-record subpoenas and written rulings for financial institutions, Accenture/Businessolver/Aetna/HSA-FSA administrators, landlord/lease-buyout records, SAPD/Dallas/constable records, U-Haul/payment records, Apple/device records, Blink/Google/Facebook/Dropbox/cloud-access records, and vendor/payment records. 9. Preserve all stolen hard drives, evidence repositories, legal work produc...

...vive 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 record also shows the June 11, 2026 bench trial setting, prior inability-to-pay filings, prior emergency verified continuance/abatement filings, prior healthcare filings, prior discovery filings, prior court-reporter requests, and prior re...

...ioner’s financial sabotage and to the Court’s assessment of temporary relief, fee denial, sanctions, trial readiness, and due process. HEALTHCARE OBSTRUCTION, FALSE QLE, SOURCE RECORDS, AND INABILITY TO STABLIZE IF TRIAL CONTINUES Healthcare is not a collateral issue. It is a life-safety issue. Petitioner has obstructed Respondent’s access to healthcare since at least December 18, 2024. Respondent has been repeatedly hospitalized with congestive heart failure. Respondent has been without consistent access to heart medications and has suffered repeated me...

...and report numbers regarding the Dallas theft were stolen from his desk. Respondent has requested open records but has not had time to receive them before today’s trial. SOURCE FINANCIAL RECORDS AND HEALTHCARE RECORDS REMAIN UNAVAILABLE The financial universe necessary for trial remains concealed. The estate cannot be reconstructed, valued, traced, characterized, divided, or tested without source financial records. Petitioner and her counsel burned months and produced virtually nothing of substance. The two pages produced contained the same transactions,...

...heft, 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 stolen evidence, authorize source-record subpoenas, permit remote a...

...in all respects, while declining to consider the continuance request. That ruling cannot stand without de novo review because the hearing did not reach the merits of the source-record, trial-readiness, healthcare, DF-24-18010 Request for De Novo Hearing on Respondent's: Motion for Enforcement, Sanctions, Continuance, and Leave to Issue Third-Party Subpoenas! Copy from re:SearchTX

...to Issue Third-Party Subpoenas. 2. The refusal or failure to consider Jason's continuance / abatement request despite the June 11, 2026, trial setting and the unresolved source-record, discovery, healthcare, stolen-evidence, and trial-readiness defects. 3. The denial of leave to issue third-party subpoenas for financial source records, including but not limited to bank records, credit-card records, payment-source records, overpayment/refund records, replacement-card/account-lineage records, payroll records, Accenture records, VEIP/equity records, myHoldi...

...ns, show-cause relief, adverse inferences, fee shifting against Petitioner and responsible counsel, counsel certification, forensic accounting from third-party financial source records, estate reconstitution under Texas Family Code § 7.009, and disproportionate division under Texas Family Code § 7.001. 10.The denial or failure to enforce healthcare, HSA/FSA, prescription, reimbursement, benefits-card, benefits-portal, QLE, COBRA, and healthcare-reinstatement relief. 11.Thedenial or failure to address Petitioner's healthcare interference, including blocke...

...involving Christopher McNally and Jonathan Drake Steele. 19.The denial or failure to address trial-readiness defects created by incomplete financial production, blocked source-record subpoenas, missing/stolen evidence repositories, unresolved healthcare access, lack of functional litigation infrastructure, and unresolved witness-protection issues. 20.Any finding, conclusion, recommendation, refusal, or omission that permits the June 11,2026trial to proceed before the District Judge conducts de novo review and before source-record verification, stolen-ev...

...: 1. No meaningful exhibit record was admitted. 2. No Rule 1006 summary chart was admitted and tested. 3. No complete production-gap chart was admitted and tested. 4. No source-record deficiency chart was admitted and tested. 5. No witness testimony was fully developed. 6. No complete offer of proof was made. 7. No merits adjudication occurred on the actual source-record issues. 8. No merits adjudication occurred on the stolen-evidence issues. 9. No merits adjudication occurred on the healthcare/HSA/FSA issues. 10.No merits adjudication occurred on the w...

...y; 3. Petitioner's sworn financial materials; 4. Jonathan Drake Steele's affidavit and fee/protective-expense request; 5. production indexes and Bates logs; 6. Rule 1006 source-record summary charts; 7. missing-statement and account-continuity charts; 8. VEIP/equity/payroll/Accenture compensation records; 9. HSA/FSA/healthcare/OLE/benefits records; 10.April 16 theft and chain-of-custody evidence; 11.recordsidentifyingmissing/stolenharddrives,devices,litigationrecords,trial materials, financial records, and evidence repositories; 12. prior notices and mot...

...rotective order; 5. grants or preserves Petitioner's fees, costs, protective expenses, vendor expenses, expert expenses, or cost-shifting requests; 6. blocks third-party source-record verification; 7. restricts Jason's ability to obtain financial source records; 8. restricts Jason's ability to obtain QLE/benefits/HSA/FSA/healthcare source records; 9. restricts Jason's ability to obtain April 16 chain-of-custody records; 10. allows Petitioner, counsel, experts, vendors, contractors, agents, or anyone acting for her to access, use, inspect, image, copy, re...

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

6. CONTINUE or ABATE the 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...

...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, or decline to adopt any por...

...e setting, or not reached. sanctions motion. Jason requests 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 already raised by the filings and hearing record before or at the June 1, 2026, hearing. To the extent the Court determines that any sanctions, counsel-certification, witness-protection, healthcare- enforcement, source-record verification, or trial-readiness issue was not reached by the Associate Judge's Report, Jason requ...

...was not provided the full amount of time originally allotted to present evidence and argument concerning enforcement, sanctions, continuance, third-party subpoena leave, source-record verification, healthcare enforcement, trial-readiness defects, stolen evidence repositories, and Petitioner's protective-order and fee/protective- expense requests. 7. When attempted to present evidence concerning written email communications between me and Petitioner's former counsel, Petitioner's counsel repeatedly | was attempting to identify, authenticate, objected on h...

...Inferences, And Healthcare Enforcement For Further Hearing Exhibit 2 Order Granting Leave to Issue Third-Party Subpoenas for Financial, Lease, QLE, Benefits, And Estate Source Records Exhibit 3 Order Granting Leave to Issue Third-Party Subpoenas Concerning April16 Theft, Movers, Security, Contractors, And Chain of Custody Exhibit 4 Subpoena Targets Exhibit 5 Respondent's Motion for Enforcement, Sanctions, Continuance, And Leave to Issue Third-Party Subpoenas Exhibit 6 Petitioner's Response to Respondent's Motion for Enforcement, Sanctions, Continuance,...

...ntouch Statements inability ta trace transactions. Evidence relating to HSA depletion, healthcare interference, and lack Fzhihit G $0 HSA of available medical funds. IRS-source tax records used to verify income, tax liability, Exhibit G-1 Tax Transcripts withholding, and financial disclosures. Demonstrates repeated account/card number changes, continuity issues, Exhibit K Card Flipping and tracing obstacles. Annual Snapshots Without Inflows or Illustrates production of summary balances without underlying Exhibit L Outflows transactional support. Court fi...

...I. RELIEF REQUESTED Trial is set for June 1 1, 2026. This motion requests multiple forms of relief, but the threshold issue for the June 1 hearing is trial readiness: No source records, no estate reconstruction. No estate reconstruction, no final trial. Movant requests that the Court: 1. Continue the June 11, 2026 trial setting; 2. Grant leave to issue third-party subpoenas for source records concerning financial accounts, VEIP/equity, tax records, loans, San Antonio housing/rent, lease payoff, QLE/benefits, Accenture records, legal retainers, third-part...

...when the interest of justice requires. This rule is directly implicated because new and materially changed circumstances now prevent trial readiness without third-party source records. Texas Rules of Civil Procedure 1 176 and 205.3 authorize third-party subpoenas and nonparty production of documents and tangible things. Texas Rules of Civil Procedure 215.2 and 215.3 authorize sanctions, fee shifting, adverse findings, evidentiary limits, staying proceedings, and other just orders for failure to comply with discovery orders or abuse of the discovery proc...

...monthly headers. One or both of those documents are necessarily false, inaccurate, or fabricated. That was not compliance. It was an obvious refusal to provide reliable source records. In the 302nd District Court, Cca motion to compel was granted or reflected as granted on or about January 6, 2026. Petitioner was then found noncompliant on or about January 9, January 20, and February 5, 2026. Each time, Petitioner represented with increasing force that she was finally compliant. Between January 6 and February 5, Respondent did not receive a single addit...

...lassification; 10. IRS/tax payments; 11. Loan origination and funding; 12. San Antonio housing reimbursement; 13. Lease payoff/buyout records; 14. Legal retainer payment sources; 15.Third-partycontractorpaymentsources; or 16.April 16 theft chain of custody. Only third-party source records can do that. If Petitioner has been fully forthcoming and compliant with discovery, then this will be a simple and painless process. The source records will confirm her position quickly. If she has not, the source records are the only way to prevent a final trial based...

...ortion. This cannot be tried on party summaries, tax emails, or screenshots. It requires employer-origin, payroll-origin, equity-plan-origin, tax-origin, and bank-origin source records. VII. VISUAL GAP CHART / RULE 1 006 SUMMARY Movant intends to attach a visual summary showing missing account-statement continuity and production gaps. The exhibit should be treated as: - Exhibit A Rule 006 Summary Chart of Financial Production Gaps The chart is offered to show the Court the structural record problem: no account has contiguous source-record coverage from A...

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

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

...k where community funds were used, and that third-party contractors used against Movant be added back 100% to Petitioner's side of the estate unless Petitioner proves by source records that the expenditure was disclosed, necessary, non-wasteful, and beneficial to the community. C. San Antonio Rent / Employer-Paid Housing e If San Antonio rent was work-paid or reimbursed by Accenture, those funds must be traced and reimbursed 100% to the estate or offset against Petitioner. D. Loans Petitioner paid off 100% of her loans before leaving the marriage, then t...

...or litigation- adjacent spending. e Petitioner's January 7 testimony represented that certain loans had already been received. Later claims conflict with that testimony. Source records are required. E. Tax Records e Petitioner has not produced legitimate tax transcripts sufficient to verify tax claims, tax liabilities, tax payments, withholding, refunds, or the alleged tax treatment of VEIP/equity. e Emails and printouts are not enough. e The Court should authorize subpoenas for IRS transcripts, tax preparer records, employer payroll/tax records, bank-or...

...imed $30,000 Additional dissipation / add-backs to be traced TBD Movant also asserts that approximately $650,000 went missing before the divorce proceedings and requires source-record reconstruction. These figures are not the full estate calculation. They are minimum categories proving why the estate cannot be tried without third-party records. Xil. APRIL 16 THEFT IS PART OF THE SAME PATTERN The April 16 writ event is more of the same pattern. Petitioner repeatedly requested access to the residence. Those requests were not granted in the manner she sough...

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

...t did not end because Petitioner's obstruction, false financial narratives, discovery gamesmanship, healthcare obstruction, lease/eviction manipulation, late production, source-record concealment, and April 16 theft kept expanding the dispute. Petitioner has wasted Movant's time, the Court's time, and the resources of everyone forced into this itigation. Petitioner has also caused severe harm to Movant and his parents through financial ambush, manufactured instability, and repeated emergency conditions. Parent-loan issues will be addressed in a separate...

...Court first address financial trial readiness because trial is set for June 11. The June 1 hearing should first decide: 1. Whether trial can proceed without third-party source records; N Whether subpoenas should issue; Whether discovery deadlines should be modified; Whether trial should be continued; and a Whether sanctions and healthcare enforcement should be reserved or set for immediate follow-up. Movant does not waive healthcare enforcement by asking the Court to address financial source records first. XVIII. PRAYER Movant respectfully requests that...

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

...or forensic relief on the present record. II. Relief Respondent Requests Respondent's Motion states that the threshold issue is trial readiness and uses the phrase: "No source records, no estate reconstruction. No estate reconstruction, no final trial." He asks the Court to: Page 2 of 17 Copy from re:SearchTX