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Unsupported loans
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 13
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
It took approximately 36 hours to bring the property back inside. By approximately 4:00 a.m., Applicant was physically exhausted and slept outside in a lawn chair to watch the property. At approximately 7:00 a.m., Applicant woke to the same blue Lexus stopped approximately 15 to 20 feet away, with the driver photographing Applicant through an open window using a DSLR camera. This was continued surveillance during physical vulnerability, not ordinary neighborhood activity. XI. BROADER FINANCIAL, LEASE, HEALTHCARE, AND LITIGATION CONTEXT The April 16 event...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 94
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
Residential+ / Lease" + Application))/ concerning( 5 56095609LaLa FoyFoy Blvd,Blvd, Dallas,Dallas, TXTX 7520975209 Received on (date) at (time) ER TEXAS REALTORS RESIDENTIAL LEASE APPLICATION ER TEXAS REALTORS USE OF THIS FORM BY PERSONS WHO ARE ©TexasNOT MEMBERSAssociationOF THEof REALTORS®,TEXAS ASSOCIATIONInc.! 2018! OF REALTORS®," #$ INC.!% IS NOT AUTHORIZED.& '% 5 6 7 2 8 Each occupant and co-applicant 18 years or older must submit a separate application. AUTHORIZATION TO RELEASE INFORMATION RELATED TO A RESIDENTIAL LEASE APPLICANT ISE OF THIS FORM...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 120
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
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...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 137
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
DF-24-18010 NO.__________________________________________ THE MARRIAGE OF § § & § RESPONDENT’S REQUESTS FOR RELIEF & NOTICE OF EXPONENTIALLY COMPOUNDING HARM 1. AFFIDAVITS / DECLARATIONS / CHARACTER REFERENCES 2025 • 07/10/2025 (Entry 81) — 43 pages — FINANCIAL RELIEF, ENFORCEMENT OF STANDING ORDERS, PROTECTION AGAINST PROCEDURAL ABUSE, AND HEARING ON SPOUSAL SUPPORT, LEGAL FEES, MARITAL DEBT AND EARLY LOAN REPAYMENT DUE TO MEDICAL HARDSHIP – DECLARATION OF CHRISTINA SEGURA IN SUPPORT OF JASON MCKEMIE RESPONDENT’S WARNINGS TO THE COURT, AND REQUESTS FOR...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 139
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
• 04/24/2025 (Entry 59) — 1 page — MOTION TO DESIGNATE PRO SE REPRESENTATION AND REQUEST FOR EQUAL ACCESS PROPOSED ORDER ON MOTION TO DESIGNATE PRO SE REPRESENTATION AND REQUEST FOR EQUAL ACCESS • 06/24/2025 (Entry 66) — 8 pages — EMERGENCY MOTION FOR TEMPORARY FINANCIAL RELIEF DUE TO IMMINENT HOUSING LOSS, MEDICAL HARDSHIP EMERGENCY M/FINANCIL • 06/27/2025 (Entry 67) — 4 pages — MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPEL DISCOVERY RESPONSES MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPELL DISCOVERY RESPONSES • 06/27/2025 (Entry 69) — 5 pages — OBJECT...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 142
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
• 06/27/2025 (Entry 67) — 4 pages — MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPEL DISCOVERY RESPONSES MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPELL DISCOVERY RESPONSES • 07/10/2025 (Entry 75) — 2 pages — ORDER TO PREVENT ANY FURTHER OBSTRUCTION AND TO COMPEL ACCESS TO HSA CARD/ FUNDS PROPOSED ORDER/JUDGMENT • 07/10/2025 (Entry 72) — 1 page — ORDER ON MOTION TO COMPELL DISCOVERY AND REQUEST FOR SANCTIONS PROPOSED ORDER/JUDGMENT • 07/10/2025 (Entry 73) — 1 page — ORDER ON MOTION TO COMPEL DISCOVERY AND REQUEST FOR SANCTIONS PROPOSED ORDER/JUDGMENT • 12/...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 143
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
• 07/10/2025 (Entry 76) — 1 page — ORDER TO ENFORCE STANDING ORDERS AND PREVENT LITIGATION INTERFERENCE PROPOSED ORDER/JUDGMENT • 07/10/2025 (Entry 77) — 1 page — ORDER GRANTING EMERGENCY MOTION TO STAY EXECUTION OF WRIT OF POSSESSION PROPOSED ORDER/JUDGMENT • 07/10/2025 (Entry 79) — 26 pages — FINANCIAL RELIEF, ENFORCEMENT OF STANDING ORDERS, PROTECTION AGAINST PROCEDURAL ABUSE, AND HEARING ON SPOUSAL SUPPORT, LEGAL FEES, MARITAL DEBT AND EARLY LOAN REPAYMENT DUE TO MEDICAL HARDSHIP – FINANCIAL RELIEF, CONTINUANCE, ENFORCEMENT OF STANDING ORDERS • 07/10...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 145
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
• 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...
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2026-06-16
Respondent / Jason
Notice Of Filing
Page 148
EXHIBIT_CONTINUATION
Exhibit Map - Recusal Supplement.pdf
• 01/14/2026 (Entry 180) — 11 pages — MOTION TO ABATE TRIAL, ENFORCE DISCOVERY ORDERS AND HEALTHCARE REINSTATEMENT • 01/26/2026 (Entry 185) — 5 pages — NOTICE OF PRESERVATION OF WITNESSES, & LARGE DISCOVERY PRODUCTION IN FINAL HOUR NOTICE OF PRESERVATION OF WITNESSES, & LARGE DISCOVERY PRODUCTION IN FINAL HOUR 7. DUE PROCESS / RECORD PRESERVATION / EX PARTE CONCERNS / COURT REPORTER / VERBATIM RECORD 2025 • 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 (En...
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2026-06-16
Petitioner / Gwendolyn
Order
Page 11
PROPOSED_ORDER_OR_ORDER
2026-06-16 OUR Motion to Enter Final Decree Final.pdf
WD-2. The indebtedness secured by the BMW awarded to her above. WD-3. Any and all other debts, charges, liabilities, and obligations incurred solely by Wife from and after the date of marriage, except as expressly provided otherwise herein. F. Debts Divided Equally Between the Parties IT IS ORDERED AND DECREED that, notwithstanding any other provision of this Decree, the following community debts shall be divided equally between the parties, with each party ordered to pay fifty percent (50%) of the outstanding balance of each such debt, together with the...
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 5
PLEADING_BODY
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
Domestic Partnership, joint accounts, joint financial conduct, reciprocal powers of attorney, Ameriprise beneficiary documentation identifying the parties as spouses, and multiple witnesses, including the wedding officiant, confirming the relationship timeline. This evidence destroys the "short marriage" fiction. The decree should not be signed on a Marital timeline contradicted by signed declarations, domestic-partnership documents, powers of attorney, joint investment activity, joint accounts, beneficiary records, and witness testimony. VI. FINANCIAL I...
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 6
EXHIBIT_START
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
...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 evidence. Petitioner claimed she was living in her car, using public transportation, and unable to afford rent without loans while earning approximately $125,000 per month, while...
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2026-06-15
Respondent / Jason
Motion - Recuse
Page 15
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY SUPPLEMENT TO PENDING RECUSAL_DE538026.pdf
...OBRA 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-fraud allegation rejected SAPD26108224; by officer and esc...
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2026-06-12
Respondent / Jason
Objections - Misc
Page 7
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY OBJECTION TO PROPOSED FINAL DECREE, NOTICE OF RECUSAL & MANDAMUS_55158B69.pdf
healthcare obstruction, false QLE processing, HSA/FSA obstruction, and functional-access noncompliance remain unresolved. functional benefit denial, refusal to produce the administrative record, HSA/FSA obstruction, and medical harm. Respondent has repeatedly advised this Court that healthcare is not collateral. It is life-safety. A signed healthcare order exists. Petitioner has represented compliance while functional access remained obstructed. Respondent has evidence that Petitioner produced false or nonfunctional HSA compliance, retained control over...
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2026-06-12
Respondent / Jason
Objections - Misc
Page 8
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY OBJECTION TO PROPOSED FINAL DECREE, NOTICE OF RECUSAL & MANDAMUS_55158B69.pdf
...pondent further objects because he is in total financial collapse. There is no gas, no food money, no medication money, no working phone service, no available credit, no loans, no stable housing, no litigation funding, no printer, no trial materials, no access to stolen evidence repositories, and no ability to meaningfully participate unless emergency financial and litigation-access relief is entered. Respondent's financial collapse is not waiver. It is the result of Petitioner's financial strangulation, healthcare obstruction, source-record concealment,...
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2026-06-12
Respondent / Jason
Objections - Misc
Page 11
EXHIBIT_CONTINUATION
RESPONDENT'S EMERGENCY OBJECTION TO PROPOSED FINAL DECREE, NOTICE OF RECUSAL & MANDAMUS_55158B69.pdf
without stolen evidence repositories, and without meaningful litigation infrastructure because of the manufactured collapse described in Respondent's filings. IX. NON-WAIVER Respondent does not waive any objection, claim, defense, request, relief, sanctions request, contempt request, mandamus issue, appellate issue, civil claim, criminal-referral issue, attorney-misconduct issue, healthcare-obstruction issue, source-record issue, stolen-evidence issue, financial-sabotage issue, false-reporting issue, digital-intrusion issue, Rule 204 issue, protective-re...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 2
PLEADING_BODY
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...RSU events, or deferred/equity compensation were concealed, mislabeled, or treated as tax withholding to distort the marital estate. 8. The denial or failure to address unsupported loan claims, including family-loan claims, LightStream, SoFi, alleged cyber/security/vendor obligations, and any claimed debt 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
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 8
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
Jason therefore requests that the Court immediately continue or 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...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 16
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...t: 1. Continue the June 11, 2026 trial setting; 2. Grant leave to issue third-party subpoenas for source records concerning financial accounts, VEIP/equity, tax records, loans, San Antonio housing/rent, lease payoff, QLE/benefits, Accenture records, legal retainers, third-party contractors, April 16 theft, movers, security contractors, All My Sons, Merritt McClayton, Decisive Resources, Jetty Partners, and all related custodians; 3. Modify the discovery deadline for the limited purpose third-party source-record discovery and related follow-up discovery;...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 19
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
3. Credit-card balances paid off multiple times per month; 4. Significant overpayments to cards; 5. At least one card with approximately $67,000 in overpayments; 6. No reliable way to determine payment source from party-produced statements; 7. No reliable way to determine whether overpayments generated refunds, credits, transfers, or concealed liquidity; 8. No reliable account-lineage records connecting old card numbers, new card numbers, reissued cards, replacement cards, or linked accounts; 9. No single account with contiguous statements from August 20...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 20
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
6.. Payroll deductions; 7.. Employer reimbursements; 8. VEIP/equity investment activity; 9. Tax withholding versus equity contribution classification; 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. T...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 22
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...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 Antonio housing records requir...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 23
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
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...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 24
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...aid 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 took out multiple "loans" immediately after Movant obtained counsel. e These loans require source records because the current record lacks: 1. Loan origination documents; 2. Proof of funds transfer: 3. Proof of disbursement; 4. Proof of repayment; 5. Proof of lender capacity; 6.. Proof that alleged family loans...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 25
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...of that any loan was not used for elective cosmetic surgery, legal warfare, 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...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 28
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
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...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 29
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...e it cannot identify. The Court cannot classify property it cannot trace. The Court cannot evaluate dissipation without payment-source records. The Court cannot evaluate loans without loan origination and transfer records. The Court cannot evaluate VEIP/equity without employer and equity-plan records. The Court cannot evaluate tax claims without tax transcripts and bank-origin tax payments. The Court cannot evaluate San Antonio housing reimbursement without employer and landlord records. The Court cannot evaluate April 16 theft without movers, security,...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 30
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
XVII. REQUEST TO SEQUENCE THE JUNE 1 HEARING Movant urgently needs healthcare enforcement. However, Movant requests that the 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 healthcar...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 36
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
1. continue the June 11, 2026 trial setting; 2. grant leave to issue third-party subpoenas for financial accounts, VEIP/equity, tax records, loans, San Antonio housing/rent, lease payoff, QLE/benefits, Accenture records, legal retainers, third-party contractors, April 16 theft, movers, security contractors, All My Sons, Merritt McClayton, Decisive Resources, Jetty Partners, and all related custodians; 3. modify the discovery deadline for third-party source-record discovery and related follow- up discovery; 4. enforce alleged prior discovery rulings and o...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 52
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
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...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 53
CERTIFICATE_OF_SERVICE
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...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, missing tax records, or source-record concealment. 2 of 1 10 DF-24-18010 Reply in Support of Enforcement, Sanctions, Continuance, and Leave Copy from re:SearchTX
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 55
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...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. The April 16 records either explain what happened or they do not. That is why source-record verification matters. And that is why Petitioner is fighting so hard to stop it. lil. THE RECORD SHOWS REPEATED NOTICE, REPEATED COMPEL E...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 57
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
That is the litigation strategy Petitioner has used from the beginning: obstruct, accuse, delay, manufacture collapse, then blame Jason for the collapse Petitioner created. IV. STEELE'S AFFIDAVIT DOES NOT PROVE COMPLIANCE. IT CERTIFIES THE FALSEHOOD. Jonathan Drake Steele voluntarily placed counsel review and certification directly at issue. His affidavit states that he was actively involved in the preparation and review of Petitioner's discovery production. He identifies a production index and Bates range. He does not identify a single complete continuo...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 58
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
Jason expressly seeks sanctions against Petitioner, Jonathan Drake Steele, Rebecca L. Armstrong, Sullivan & Cook, and any attorney who certified, sponsored, presented, defended, relied upon, or attempted to shield materially incomplete financial production from verification. V. PETITIONER'S PROTECTIVE ORDER IS BAD-FAITH DISCOVERY OBSTRUCTION. in n full. Petitioner's protective order should be denied Petitioner is not asking the Court to protect privileged communications. She is asking the Court to protect missing source records from being tested. She wan...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 59
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...rt records, and bank-origin tracing. Petitioner's attempt to block those records is not a burden objection. It is fraud protection. VII. PETITIONER'S LOAN CLAIMS ARE NOT LOANS WITHOUT TRACEABLE FUNDS TRANSFERS. Petitioner cannot simultaneously claim financial hardship, claim the need for undocumented family loans, funnel five-figure sums into VEIP equity investments, accumulate employer-matched stock compensation, and schedule elective cosmetic procedures at a uxury aesthetic clinic. Those positions are mutually incompatible. If sufficient funds existed...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 60
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...nto the community without tracing. If Petitioner insists the marriage was a "five-month fling" with no commingled assets, then she cannot simultaneously use pre-marriage loans and opaque pre-marriage liabilities to burden Jason. - - one-half of the total $100,000 investment was a joint The $50,000 Advantigen investment investment event. Attempts to recast it and othe rjoint investment activity as Petitioner's separate property while using incomplete records and missing source proof is bad faith. Petitioner cannot have it both ways: no marriage when asset...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 63
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
10. litigation conduct designed to convert missing records into trial advantage. Jason further requests that the Court require sworn counsel certification within three calendar days identifying: 1. every financial account known to Petitioner or counsel; 2. every account number, replacement account number, replacement card number, closed account, successor account, and related account lineage; 3.. every month for which a complete institution-origin statement was produced; 4. every month missing or incomplete; 5 every document Petitioner claims is a source...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 64
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...A final trial without source records would force Jason to defend against a financial narrative built from missing statements, rotated accounts, unexplained overpayments, unsupported loans, mislabeled equity, missing tax transcripts, missing payroll records, missing VEIP records, missing myHoldings records, missing loan funding records, missing contractor payment records, and stolen evidence repositories. e Petitioner created the evidentiary collapse. e Petitioner now seeks protection from the cure. e The Court should not permit that. Xill. PRAYER Jason M...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 65
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...ncial accounts, credit cards, overpayments, payment sources, account continuity, replacement-card lineage, VEIP/equity, Accenture payroll, myHoldings, RSUs, tax records, loans, GLU Distribution LLC, San Antonio housing, lease payoff, rent ledgers, QLE/benefits, HSA/FSA functionality, legal retainers, third-party contractors, vendors, April 16 theft, movers, security, bodyguards, All My Sons, Merritt McClayton, Decisive Resources, Jetty Partners, landlord records, constable records, and related source-record custodians; 5. MODIFY discovery deadlines for t...
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2026-06-04
Court
REQUEST FOR DE NOVO HEARING
Page 76
EXHIBIT_CONTINUATION
RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
RESPONDENT'S HISTORICAL PLEADINGS REQUESTING MEDICAL STABILIZATION, HOUSING STABILITY, ENFORCEABLE RELIEF, AND THIRD-PARTY VERIFICATION Category Count : Pages 1. Affidavits / Declarations / Character-type statements 7 135 2. Motions (all) 61 807 3. Motions seeking to "compel" 7 50 4. Healthcare / Medical / HSA / Abatement or Stay / Standing or 41 507 Temporary Orders 5. Financial relief I/ reimbursements / fraud / rent / stabilization / 39 354 Standing or Temporary Orders 6. Discovery obstruction / compel / subpoenas / enforcement 24 199 7. Due process /...
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RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
© 06/24/2025 (Entry 66) 8pages EMERGENCY MOTION FOR TEMPORARY FINANCIAL RELIEF DUE TO IMMINENT HOUSING LOSS, MEDICAL HARDSHIP EMERGENCY M/FINANCIL e 06/27/2025 (Entry 67) 4pages MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPEL DISCOVERY RESPONSES MOTION TO PRESERVE DISCOVERY RIGHTS AND COMPELL DISCOVERY RESPONSES e 06/27/2025 (Entry 69) 5pages OBJECTIN MATERIAL DISCOVERY NOTICE OF MATERIAL DISCOVERY NOTICE OF MATERIAL DISCOVERY e 07/10/2025 (Entry 70) 1page FINANCIAL RELIEF, ENFORCEMENT OF STANDING ORDERS, PROTECTION AGAINST PROCEDURAL ABUSE, AND HEARING O...
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RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
e 12/27/2024 (Entry 24) 3pages REQUEST FOR TEMPORARY ORDERS NOTICE OF COURT - PROCEEDING REQUEST FOR TEMPORARY ORDERS 2025 06/24/2025 (Entry 66) 8 pages EMERGENCY MOTION FOR TEMPORARY FINANCIAL RELIEF DUE TO IMMINENT HOUSING LOSS, MEDICAL HARDSHIP EMERGENCY M/FINANCIL 07/10/2025 (Entry 70) 1 page FINANCIAL RELIEF, ENFORCEMENT OF STANDING ORDERS, PROTECTION AGAINST PROCEDURAL ABUSE, AND HEARING ON SPOUSAL SUPPORT, LEGAL FEES, - MARITAL DEBT AND EARLY LOAN REPAYMENT DUE TO MEDICAL HARDSHIP ESERVED COPY OF ORDER DENYING JASON MCKEMIE'S RELIEF 07/10/2025 (En...
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RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
e 01/20/2026 (Entry 184) 34pages RESPONDENT'S NOTICE OF DISCOVERY AND HEALTHCARE COMPLIANCE, REQUEST FOR REMOTE APPEARANCE, REQUEST FOR ACCESS TO PERSONAL PROPERTY, REQUEST FOR CONSOLIDATION & HEARING LIMITS, AND CASE MANAGEMENT CLARIFICATION 5. Financial relief / reimbursements / fraud / rent & stabilization / standing or temporary orders 2025 06/24/2025 (Entry 66) 8 pages EMERGENCY MOTION FOR TEMPORARY FINANCIAL RELIEF DUE TO IMMINENT HOUSING LOSS, MEDICAL HARDSHIP EMERGENCY M/FINANCIL 07/10/2025 (Entry 70) 1 page FINANCIAL RELIEF, ENFORCEMENT OF STAND...
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RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
CONDITIONAL SANCTIONS, AND THIRD-PARTY SUBPOENA AUTHORITY (QLE RECORDS) PROPOSED ORDER e 01/14/2026 (Entry180) 11pages MOTION TO ABATE TRIAL, ENFORCE DISCOVERY ORDERS AND HEALTHCARE REINSTATEMENT e 01/26/2026 (Entry185) 5pages NOTICE OF PRESERVATION OF WITNESSES, & LARGE DISCOVERY PRODUCTION IN FINAL HOUR NOTICE OF PRESERVATION OF WITNESSES, & LARGE DISCOVERY PRODUCTION IN FINAL HOUR 7. Due process / record preservation / ex parte concerns / court reporter / verbatim record 2025 e 04/24/2025 (Entry 56) 1 page MOTION FOR NOTICE PRIOR TO ANY DISMISSAL PROP...
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RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
e 07/10/2025 (Entry 80) 149pages FINANCIAL RELIEF, ENFORCEMENT OF STANDING ORDERS, PROTECTION AGAINST PROCEDURAL ABUSE, AND HEARING ON SPOUSAL SUPPORT, LEGAL FEES, - MARITAL DEBT AND EARLY LOAN REPAYMENT DUE TO MEDICAL HARDSHIP EVIDENCE AND EXHIBITS e 07/24/2025 (Entry 91) 8pages RESPONDENT VERIFIED M/RECUSE e 07/24/2025 (Entry100) 11pages EMERGENCY MOTION FOR IMMEDIATE RELIEF, OBJECTION TO TRIAL, AND REQUEST FOR ACKNOWLEDGEMENT e 08/06/2025 (Entry 104) 7pages EMERGENCY MOTION TO ABATE TRIAL SETTING AND WITHHOLD FINAL ORDERS PENDING RESOLUTION OF OUTSTAN...
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RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
Jason McKemie Wednesday, December 3, 2025 at 1:51:20AM Central Standard Time Subject: Discovery Date: Friday, October 10, 2025 at 1:33:20PM Central Daylight Time From: Ethan Scroggins <escroggins@sullivancook.com> To: Jason McKemie <jmckemie@mckemie.net>, Jason McKemie <mckemie76@gmail.com> cc: Will Cook <weook@sullivancook.com>, Chandler Alt <calt@sullivancook.com> Attachments: 2025-10-09 Exhibit A - Discovery Log.xlsx, Dec 2024 Page 3.pdf, Nov 2024 Page 3.pdf Mr. McKemie, Your "exhibits" to your requests for information appear to be based only on the 2...
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RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
EXHIBIT A GWENS PRODUCTION non Start End Date Prodbeed To RFP 20226-22 AdvantiGen Su 'GU000001 22425 tA 2023-03-19 AdvantGen Subscription GU000003 GU000004 2425 TA 2024 AIG 401(k) pdf GUO0000S GU 10 22425 2024 AMEX Platinurn 6008 Statements. GU000011 GU00003 | 2/24/25 TA 2024 Chase Ace x3898 G Fz GU000075 BAS TA 2024 Chase Acct x6893 $ GUNO0O7E G 2724/25 TA 2024-07 through 2025-01 Chase Suphire GU000126 D425 IA 2024-12-31 MetLife HSA Si GW000127 GU000127 22425 [A 2025 GU000128 Agentur HSA Election Details pdf GU000128 A 2025 GU000133 224/25 GU000129 tA L...
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RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
Jason McKemie Wednesday, December 3, 2025 at 1:53:10AM Central Standard Time Subject: Re: Subject: Court-Ordered Financials - Immediate Production Required Date: Thursday, September 25, 2025 at 2:20:51 PM Central Daylight Time From: Jason McKemie <jmckemie@mckemie.net> To: Ethan Scroggins <escroggins@sullivancook.com> c: Will Cook <weook@sullivancook.com>, Chandler Alt <calt@sullivancook.com>, Kim Jones <kjones@sullivancook.com>, Jason McKemie <mckemie76@gmail.com> Priority: High Attachments: Disc DemandGwen - Disc List (Master).pdf Ethan, know there' a...
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RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...The individual(s) who inspected Respondent's vehicle and allegedly discovered a device. This information is required so that subpoenas may be issued timely for trial. C. Loans, Contributions, and Non-community Items 1, Loans. Any loan your client intends to list must be supported by: a. Executed, notarized loan agreement dated prior to issuance; and b. Proof offunds transfer into your client's account (wire/ACH/canceled check). 1, Loans incurred after December 16, 2024 are excluded from this production as taken against standing/temporary orders and will...
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RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
$10,000/month, ~$130,000/year) to equity funds initiated after entry of the orders are inconsistent with any asserted loan-based "need" and must be fully disclosed in the statements and accountings. 3. Elective cosmetic procedures. Elective cosmetic surgery is not a community obligation and must be excluded from community expense accounting. 4, GLU Distribution (...8627). Produce monthly statements in the same consolidated, sequential, complete manner as all other accounts. 5. Reimbursements and allowances. Provide a full accounting of all reimbursements...
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RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
Please ensure produced statements do not have omitted pages of transaction distory, 2. AIG 401{(k) - Only a 06/22/2024 one-day snapshot and a 01/01/2025- 06/01/2025 roll-up were produced. These are not monthly statements. Please produce consecutive monthly statements (all pages) from Sept 2023-present and the CSV/Excel export with date, posting date, description, source code, amount, and running balance. 3. GLU Distribution LLC (Chase) - Monthly statements June 2023-present have not been produced. The fee-only report is not a monthly statement. Chase con...
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RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
Jason McKemie Wednesday, December 3, 2025 at 1:51:20AM Central Standard Time Subject: Discovery Date: Friday, October 10, 2025 at 1:33:20PM Central Daylight Time From: Ethan Scroggins <escroggins@sullivancook.com> To: Jason McKemie <jmckemie@mckemie.net>, Jason McKemie <mckemie76@gmail.com> cc: Will Cook <wcook@sullivancook.com>, Chandler Alt <calt@sullivancook.com> Attachments: 2025-10-09 Exhibit A - Discovery Log.xlsx, Dec 2024 Page 3.pdf, Nov 2024 Page 3. pdf Mr. McKemie, Your "exhibits" to your requests for information appear to be based only on the...
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RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
Jason McKemie Wednesday, December 3, 2025 at 1:53:10AM Central Standard Time - Immediate Production Required Subject: Re: Subject: Court-Ordered Financials Date: Thursday, September 25, 2025 at 2:20:51 PM Central Daylight Time From: Jason McKemie <jmckemie@mckemie.net> To: Ethan Scroggins <escroggins@sullivancook.com> cc: Will Cook <wcook@sullivancook.com>, Chandler Alt <calt@sullivancook.com>, Kim Jones <kjones@sullivancook.com>, Jason McKemie <mckemie76@gmail.com> Priority: High - Attachments: Disc Demand_Gwen Disc List (Master).pdf Ethan, | know there...
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RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...egal 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
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RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
...The individual(s) who inspected Respondent's vehicle and allegedly discovered a device. This information is required so that subpoenas may be issued timely for trial. C. Loans, Contributions, and Non-community Items 1. Loans. Any loan your client intends to list must be supported by: a. Executed, notarized loan agreement dated prior to issuance; and b. Proof of funds transfer into your client's account (wire/ACH/canceled check). 1. Loans incurred after December 16, 2024 are excluded from this production as taken against standing/temporary orders and will...
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RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
$10,000/month, ~$130,000/year) to equity funds initiated after entry of the orders are inconsistent with any asserted loan-based "need" and must be fully disclosed in the statements and accountings. 3. Elective cosmetic procedures. Elective cosmetic surgery is not a community obligation and must be excluded from community expense accounting. 4. GLU Distribution (...8627). Produce monthly statements in the same consolidated, sequential, complete manner as all other accounts. 5. Reimbursements and allowances. Provide a full accounting of all reimbursements...
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RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
Please ensure produced statements do not have omitted pages of transaction history. 2. AIG 401(k) - Only a 06/22/2024 one-day snapshot and a 01/01/2025- 06/01/2025 roll-up were produced. These are not monthly statements. Please produce consecutive monthly statements (all pages) from Sept 2023-present and the CSV/Excel export with date, posting date, description, source code, amount, and running balance. - 3. GLU Distribution LLC (Chase) Monthly statements June 2023-present have not been produced. The fee-only report is not a monthly statement. Chase conf...
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RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
Category Amount (S$) Frequency TV & Streaming S 250 Monthly The financial Verizon Phone S 120 Monthly disclosures T-Mobile Phone S 160 Monthly systematically Toiletries & Makeup S 80 Monthly transform assets into Dry Cleaning S 70 Monthly Charitable Contributions S 120 Monthly liabilities and wealth Hair (Quarterly) S 200 Monthly accumulation into Car Wash S 40 Monthly apparent financial Nails $ 150 Monthly Prescriptions S 30 Monthly Apple Subscriptions S 100 Monthly House Cleaning S 260 Monthly Gas S 90 Monthly Car Insurance (Semi-Annual) 267 Monthly Ca...
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RESPONDENT'S REQUEST FOR DE NOVO HEARING_25BAEB2D.pdf
Name of owner: Gwendolyn Ulijasz Type of insurance: Term Life Amount of premiums [monthly/quarterly/ semiannually]: Company-paid, unknown. Date of issue: 10/16/2024 Face amount: $1,500,000 Cash surrender value on date of marriage: 0 Current cash surrender value: $0 Designated beneficiary(ies): Jason McKemie Balance of loan against policy: n/a Value of community interest: $0 Source(s) of value: Accenture employer contract. 12.B. Annuities 12.B.1. None. 12.C. Health Savings Accounts 12.C.1. Institution holding account: MetLife Account number: MEC1796C36172...
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DF-24-18010 - Respondent's De Novo Hearing Request (CMP) (3).pdf
...RSU events, or deferred/equity compensation were concealed, mislabeled, or treated as tax withholding to distort the marital estate. 8. The denial or failure to address unsupported loan claims, including family-loan claims, LightStream, SoFi, alleged cyber/security/vendor obligations, and any claimed debt DF-24-18010 Request for De Novo Hearing on Respondent’s: Motion for Enforcement, Sanctions, Continuance, and Leave to Issue Third-Party Subpoenas
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DF-24-18010 - Respondent's De Novo Hearing Request (CMP) (3).pdf
Jason therefore requests that the Court immediately continue or abate the June 11, 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/QLE/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 marita...
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DF-24-18010 - Respondent's De Novo Hearing Request (CMP) (3).pdf
...t: 1. Continue the June 11, 2026 trial setting; 2. Grant leave to issue third-party subpoenas for source records concerning financial accounts, VEIP/equity, tax records, loans, San Antonio housing/rent, lease payoff, QLE/benefits, Accenture records, legal retainers, third-party contractors, April 16 theft, movers, security contractors, All My Sons, Merritt McClayton, Decisive Resources, Jetty Partners, and all related custodians; 3. Modify the discovery deadline for the limited purpose of third-party source-record discovery and related follow-up discover...
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DF-24-18010 - Respondent's De Novo Hearing Request (CMP) (3).pdf
3. Credit-card balances paid off multiple times per month; 4. Significant overpayments to cards; 5. At least one card with approximately $67,000 in overpayments; 6. No reliable way to determine payment source from party-produced statements; 7. No reliable way to determine whether overpayments generated refunds, credits, transfers, or concealed liquidity; 8. No reliable account-lineage records connecting old card numbers, new card numbers, reissued cards, replacement cards, or linked accounts; 9. No single account with contiguous statements from August 20...
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DF-24-18010 - Respondent's De Novo Hearing Request (CMP) (3).pdf
6. Payroll deductions; 7. Employer reimbursements; 8. VEIP/equity investment activity; 9. Tax withholding versus equity contribution classification; 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-party contractor payment sources; 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...
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DF-24-18010 - Respondent's De Novo Hearing Request (CMP) (3).pdf
...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 Antonio housing records requi...
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DF-24-18010 - Respondent's De Novo Hearing Request (CMP) (3).pdf
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 • 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 th...
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DF-24-18010 - Respondent's De Novo Hearing Request (CMP) (3).pdf
...aid Housing • 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 took out multiple “loans” immediately after Movant obtained counsel. • These loans require source records because the current record lacks: 1. Loan origination documents; 2. Proof of funds transfer; 3. Proof of disbursement; 4. Proof of repayment; 5. Proof of lender capacity; 6. Proof that alleged family loan...
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DF-24-18010 - Respondent's De Novo Hearing Request (CMP) (3).pdf
...of that any loan was not used for elective cosmetic surgery, legal warfare, or litigation- adjacent spending. • 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 • Petitioner has not produced legitimate tax transcripts sufficient to verify tax claims, tax liabilities, tax payments, withholding, refunds, or the alleged tax treatment of VEIP/equity. • Emails and printouts are not enough. • The Court should authorize subpoenas for...
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DF-24-18010 - Respondent's De Novo Hearing Request (CMP) (3).pdf
13. Bodycam/dashcam/open-records custodians; 14. Jetty Partners; 15. Decisive Resources; 16. Any contractor involved in planning, 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....
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DF-24-18010 - Respondent's De Novo Hearing Request (CMP) (3).pdf
...annot identify. • The Court cannot classify property it cannot trace. • The Court cannot evaluate dissipation without payment-source records. • The Court cannot evaluate loans without loan origination and transfer records. • The Court cannot evaluate VEIP/equity without employer and equity-plan records. • The Court cannot evaluate tax claims without tax transcripts and bank-origin tax payments. • The Court cannot evaluate San Antonio housing reimbursement without employer and landlord records. • The Court cannot evaluate April 16 theft without movers, se...
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DF-24-18010 - Respondent's De Novo Hearing Request (CMP) (3).pdf
XVII. REQUEST TO SEQUENCE THE JUNE 1 HEARING Movant urgently needs healthcare enforcement. However, Movant requests that the 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; 2. Whether subpoenas should issue; 3. Whether discovery deadlines should be modified; 4. Whether trial should be continued; and 5. Whether sanctions and healthcare enforcement should be reserved or set for immediate follow-up. Movant does not waive h...
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DF-24-18010 - Respondent's De Novo Hearing Request (CMP) (3).pdf
1. continue the June 11, 2026 trial setting; 2. grant leave to issue third-party subpoenas for financial accounts, VEIP/equity, tax records, loans, San Antonio housing/rent, lease payoff, QLE/benefits, Accenture records, legal retainers, third-party contractors, April 16 theft, movers, security contractors, All My Sons, Merritt McClayton, Decisive Resources, Jetty Partners, and all related custodians; 3. modify the discovery deadline for third-party source-record discovery and related follow- up discovery; 4. enforce alleged prior discovery rulings and o...
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DF-24-18010 - Respondent's De Novo Hearing Request (CMP) (3).pdf
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...
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DF-24-18010 - Respondent's De Novo Hearing Request (CMP) (3).pdf
...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, missing tax records, or source-record concealment. 2 of 110DF-24-18010 Reply in Support of Enforcement, Sanctions, Continuance, and Leave
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DF-24-18010 - Respondent's De Novo Hearing Request (CMP) (3).pdf
...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. The April 16 records either explain what happened or they do not. That is why source-record verification matters. And that is why Petitioner is fighting so hard to stop it. III. THE RECORD SHOWS REPEATED NOTICE, REPEATED COMPEL E...
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