### Primitive Case Build: Chronological Sequence of Undeniable Facts

Based solely on the documents provided—including the email chains and legal motions—the following timeline represents the primitive facts (i.e., raw, objective events without interpretation or analysis). This build is limited to explicitly stated actions, dates, and communications from the records.

#### June 2025: Initial Interactions
- **June 5, 2025**: Knicky Van Goetz (Petitioner's prior counsel) emails Jason Davis (Respondent) requesting his Sworn Financial Statement and mandatory disclosures, noting they are overdue. (Email chain: "Davis- financial information?")
- **June 9, 2025 (6:50 PM)**: Jason Davis responds to Knicky Van Goetz via email, stating he has reviewed Petitioner's disclosures and identified "material errors" in income levels and credit card responsibilities. He indicates he is "working on getting my documents e-filed" and attaches copies of his documents. (Email chain: "Davis- financial information?")
- **June 9, 2025 (8:34 PM)**: Knicky Van Goetz emails Jason Davis, asking if he plans to pay the mediation deposit and noting that the mediation scheduled for June 17 was cancelled due to his non-payment. (Email chain: "Davis- financial information?")
- **June 10, 2025 (11:39 AM)**: Jason Davis replies to Knicky Van Goetz, thanking her for flagging the deposit issue, stating he does not recall receiving notice, but offering to "take care of it promptly." He requests payment instructions. (Email chain: "Davis- financial information?")
- **June 10, 2025 (11:57 AM)**: Jason Davis emails Knicky Van Goetz and Debbie (mediator's scheduler), noting that the original mediation notice was not copied to him. He confirms he has paid the $150 deposit via Zelle and requests to be included in future correspondence to avoid delays. (Email chain: "FW: Reply to Confirm Receipt ~ Mediation for Davis on 6/17 at 11:00 (ah)")
- **June 10, 2025 (4:13 PM)**: Debbie (scheduler) responds to Jason Davis, acknowledging receipt of the payment and agreeing to correct his email address in the record. (Email chain: "FW: Reply to Confirm Receipt ~ Mediation for Davis on 6/17 at 11:00 (ah)")
- **June 17, 2025**: The mediation session is cancelled, as per the June 9 email from the scheduler. (Implied from emails; explicitly noted in Respondent's July 9 Opposition)

#### July 2025: Procedural Filings and Responses
- **July 9, 2025**: Jason Davis files "Respondent's Opposition to Petitioner's Motion to Waive Mediation and Set Default Hearing." He asserts that he complied with disclosure requirements on June 9 and paid the mediation deposit on June 10, accusing Petitioner's counsel of misrepresentation. (Respondent's Opposition)
- **July 11, 2025**: Petitioner's prior counsel (Knicky Van Goetz) files a "Motion to Withdraw as Counsel for the Petitioner." (Petitioner's Motion, Para 3)
- **July 16, 2025**: Jason Davis files "Respondent's Limited Response to Motion to Withdraw and Request for Findings," indicating he does not object to withdrawal but makes demands related to prior counsel's alleged misconduct. (Petitioner's Motion, Para 4)
- **July 17, 2025**: Petitioner's prior counsel files a "Reply" to Jason Davis's Response, noting his "unfounded threats" against her law license. (Petitioner's Motion, Para 5)
- **July 17, 2025**: Jason Davis files "Respondent's Motion for Sanctions Under C.R.C.P. 11 & RPC 3.3." (Petitioner's Motion, Para 6)
- **July 18, 2025**: Hanaã Obeidat (current counsel) submits a "Substitution of Counsel" for Petitioner. (Petitioner's Motion, Para 7)

#### Late July to August 2025: Escalation of Communications and Actions
- **July 26, 2025**: Jason Davis emails Petitioner's counsel demanding payment of $19,964.28 by August 11, 2025, threatening to file a police report for non-payment. (Petitioner's Motion, Para 11; Exhibit G)
- **August 4, 2025**: Petitioner's counsel responds to Jason Davis, declining the payment demand and stating the issue should be addressed through legal channels. (Petitioner's Motion, Para 12)
- **August 8, 2025**: The parties attend mediation; no agreement is reached. A Certificate of Completion is filed on August 12, 2025. (Petitioner's Motion, Para 8)
- **August 8, 2025**: Jason Davis emails Petitioner's counsel requesting a summary of mediation discussions. Counsel declines due to confidentiality. Jason then proposes a settlement agreement with terms unacceptable to Petitioner. (Petitioner's Motion, Para 13; Exhibit I)
- **August 11, 2025**: The court issues a "Delay Prevention Order" setting a deadline of September 15, 2025, for tasks to be completed. (Petitioner's Motion, Para 9)
- **August 14, 2025**: The court denies Jason Davis's Motion for Sanctions (filed July 17). (Petitioner's Motion, Para 6)
- **August 15, 2025**: Jason Davis emails Petitioner's counsel accusing prior counsel of filing a false statement with the court and demanding correction or reimbursement. (Petitioner's Motion, Para 16-17; Exhibit A)
- **August 15, 2025**: Jason Davis forwards an email to Petitioner's counsel that he sent to prior counsel, threatening a federal civil rights complaint against prior counsel and the court. He attaches an untitled motion calling for the judge's recusal and prior counsel's disbarment. (Petitioner's Motion, Para 18-19; Exhibits B, C)
- **August 15, 2025**: Jason Davis forwards an email from his mother, Kathy O'Keefe, outlining a fee schedule for storing Petitioner's Toyota RAV4. He threatens to sell or tow the vehicle unless paid. (Petitioner's Motion, Para 20; Exhibit D)
- **August 15, 2025**: Jason Davis emails Petitioner's counsel about the Toyota, stating he will relinquish control but sets a deadline of August 22, 2025, for retrieval, after which he will process it under Texas lien laws. (Petitioner's Motion, Para 21; Exhibit F)
- **August 18-19, 2025**: Jason Davis sends a series of emails to Petitioner's counsel described as "threatening" and accusing Petitioner and counsel of playing a "game." (Petitioner's Motion, Para 22; Exhibit J)
- **August 19, 2025**: Petitioner's counsel sends one email to address multiple emails from Jason Davis, urging focus on the Delay Prevention Order and requesting cessation of excessive emails. (Petitioner's Motion, Para 25)
- **August 20, 2025**: Jason Davis emails Petitioner's counsel threatening "frivolous filings" regarding the Toyota and alleging "marital waste." He falsely claims counsel agreed to a September 20 timeline. (Petitioner's Motion, Para 26)
- **August 20, 2025**: Jason Davis contacts Petitioner's counsel about preparing a media article regarding the Toyota, stating he will quote counsel's "no comment." (Petitioner's Motion, Para 27; Exhibit L)
- **August 20, 2025**: Jason Davis posts a negative Google Review for Petitioner's law firm, referencing an event from May 8, 2024. (Petitioner's Motion, Para 28; Exhibit K)
- **August 26, 2025**: Jason Davis emails prior counsel (CCing Petitioner and current counsel) with settlement terms deemed inappropriate by Petitioner. (Petitioner's Motion, Para 24; Exhibit H)
- **September 3, 2025**: Jason Davis copies Petitioner on correspondence with counsel, despite requests to communicate only through counsel. (Petitioner's Motion, Para 24)

#### September 2025: Petitioner's Motion
- **September 5, 2025**: Petitioner files "Petitioner's Motion for Admonishment, Injunctive Relief, and Attorney Fees," seeking court intervention based on the above events. (Petitioner's Motion)


The mediation session scheduled for June 17, 2025, was cancelled. This cancellation is documented in an email from Scheduler Debbie to Petitioner's prior counsel, Knicky Van Goetz, on June 9, 2025, which states: "This mediation has been canceled due to nonpayment by the other party, Jason Davis." Upon receiving notice of the cancellation via email from Knicky on June 10, 2025, Respondent Jason Davis promptly paid the $150 mediation deposit via Zelle to the mediator, Andrew Haas, and communicated with the scheduler to confirm receipt. Davis also noted that he had not been copied on the original mediation notice from May 20, 2025, which contributed to the delay in payment. In his July 9, 2025, Opposition, Davis explicitly references this cancellation, arguing that it was due to "Petitioner’s failure to pay required fees" and "Petitioner’s counsel’s disorganization," citing the scheduler's June 9 email and the mediator's June 17 email as exhibits. This point highlights the communication breakdown and disputed reasons for the cancellation, as raised in the subsequent filing.

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Absolutely. Let's meticulously document the post-June 17, 2025, period using the same disciplined, primitive-fact approach. We will anchor every point directly to the source documents, ensuring no event, date, or claim is presented without explicit support.

Here is the carefully constructed timeline of primitive facts for the period following the June 17 mediation cancellation.

### Primitive Facts: July 2025 through September 5, 2025

#### July 2025: Procedural Filings and Counsel Change
- **July 11, 2025**: Petitioner's prior counsel, Knicky Van Goetz, files a `Motion to Withdraw as Counsel for the Petitioner`. (Petitioner's Motion, Para 3)
- **July 16, 2025**: Respondent Jason Davis files `Respondent’s Limited Response to Motion to Withdraw and Request for Findings Pursuant to C.R.C.P. 121 § 1-15`. The filing indicates he does not object to the withdrawal but makes demands related to accusations of misconduct against prior counsel. (Petitioner's Motion, Para 4)
- **July 17, 2025**: Petitioner's prior counsel files a `Reply` to Respondent's July 16 filing, noting Respondent's "unfounded threats" against her license to practice law. (Petitioner's Motion, Para 5)
- **July 17, 2025**: Respondent Jason Davis files `Respondent’s Motion for Sanctions Under C.R.C.P. 11 & RPC 3.3`. (Petitioner's Motion, Para 6)
- **July 18, 2025**: Hanaã Obeidat, Esq., of The Law Office of Emily A. Jones, files a `Substitution of Counsel`, becoming Petitioner's attorney of record. (Petitioner's Motion, Para 7)
- **July 23, 2025**: The Court grants the `Motion to Withdraw` filed by Petitioner's prior counsel. (Petitioner's Motion, Para 3)
- **July 26, 2025**: Respondent Jason Davis emails Petitioner's new counsel demanding payment of $19,964.28 by August 11, 2025, and threatening to file a police report for failure to pay. (Petitioner's Motion, Para 11; Exhibit G)

#### August 2025: Escalation of Communications and Motions
- **August 4, 2025**: Petitioner's counsel responds to the July 26 email, declining the payment demand and stating the issue must be addressed through the dissolution proceedings. (Petitioner's Motion, Para 12)
- **August 4, 2025**: Respondent Jason Davis replies to counsel's August 4 email, renewing his demand for payment by August 18, 2025, and threatening further legal action. (Petitioner's Motion, Para 12; Exhibit H)
- **August 8, 2025**: The parties attend mediation. No agreement is reached. (Petitioner's Motion, Para 8)
- **August 8, 2025**: Respondent Jason Davis emails Petitioner's counsel requesting a summary of the mediation discussions. Counsel declines, citing confidentiality. Respondent then proposes a settlement agreement with terms unacceptable to Petitioner. (Petitioner's Motion, Para 13; Exhibit I)
- **August 8, 2025**: Respondent Jason Davis follows up on his demand for payment, accusing Petitioner of fraud and threatening a criminal complaint, a petition for sanctions, and a separate civil action for conversion. (Petitioner's Motion, Para 14; Exhibit I)
- **August 11, 2025**: The Court issues a `Delay Prevention Order`, setting a deadline of September 15, 2025, for specific tasks to be completed. (Petitioner's Motion, Para 9)
- **August 12, 2025**: A `Certificate of Completion` for the August 8 mediation is filed with the Court. (Petitioner's Motion, Para 8)
- **August 14, 2025**: The Court denies `Respondent’s Motion for Sanctions` filed on July 17, 2025. (Petitioner's Motion, Para 6)
- **August 14, 2025**: Respondent Jason Davis sends a proposed settlement agreement via email. (Petitioner's Motion, Para 15)
- **August 15, 2025**: Petitioner's counsel notifies Respondent via email that Petitioner declines the settlement offer. (Petitioner's Motion, Para 15)
- **August 15, 2025**: Respondent Jason Davis sends a "frenzy" of "threatening, excessive emails" to Petitioner's counsel. (Petitioner's Motion, Para 15)
- **August 15, 2025**: Respondent Jason Davis emails Petitioner's counsel accusing prior counsel of filing a false statement with the Court and claiming Petitioner is liable for frivolous filings. (Petitioner's Motion, Para 16-17; Exhibit A)
- **August 15, 2025**: Respondent Jason Davis forwards to Petitioner's counsel an email he sent to prior counsel and her paralegal, threatening a federal civil rights complaint. An untitled motion is attached, naming prior counsel and the Court as Respondents and calling for the judge's recusal and the attorney's disbarment. (Petitioner's Motion, Para 18-19; Exhibits B, C)
- **August 15, 2025**: Respondent Jason Davis forwards to Petitioner's counsel an email from his mother, Kathy O'Keefe, outlining a fee schedule for storing Petitioner's Toyota RAV4. (Petitioner's Motion, Para 20; Exhibit D)
- **August 15, 2025**: Respondent Jason Davis emails Petitioner's counsel regarding the Toyota, stating he is relinquishing control but sets a deadline of August 22, 2025, for Petitioner to retrieve the vehicle from Texas, after which it will be processed under Texas lien laws. (Petitioner's Motion, Para 21; Exhibit F)
- **August 18-19, 2025**: Respondent Jason Davis sends a series of emails to Petitioner's counsel described as displaying "threatening behavior." (Petitioner's Motion, Para 22; Exhibit J)
- **August 19, 2025**: Petitioner's counsel sends one email to address approximately nine emails received from Respondent since August 15, 2025. Counsel notes disagreement on settlement, urges focus on the Delay Prevention Order, and requests a cessation of excessive emails. (Petitioner's Motion, Para 25)
- **August 20, 2025**: Respondent Jason Davis emails Petitioner's counsel threatening "frivolous filings" regarding the Toyota and alleging "marital waste." He also falsely claims counsel had agreed to a timeline for finalizing the dissolution. (Petitioner's Motion, Para 26)
- **August 20, 2025**: Respondent Jason Davis contacts Petitioner's counsel claiming he is preparing an article for local media about the Toyota and requests a statement. He states he will post the article over the weekend and quote counsel's "no comment." (Petitioner's Motion, Para 27; Exhibit L)
- **On or about August 20, 2025**: Respondent Jason Davis posts a negative Google Review for The Law Office of Emily A. Jones, LLC. The review references an event from May 8, 2024. (Petitioner's Motion, Para 28; Exhibit K)
- **August 26, 2025**: Respondent Jason Davis emails Petitioner's prior counsel, CCing Petitioner and current counsel, threatening additional litigation and proposing settlement terms deemed inappropriate by Petitioner. (Petitioner's Motion, Para 24; Exhibit H)

#### September 2025: Final Events Preceding Motion
- **September 3, 2025**: Respondent Jason Davis copies Petitioner on correspondence with counsel, despite prior requests that all communication go through counsel. (Petitioner's Motion, Para 24)
- **September 5, 2025**: Petitioner, through counsel, files the `Petitioner’s Motion for Admonishment, Injunctive Relief, and Attorney Fees` with the Court. (Petitioner's Motion, Title)

This timeline is built exclusively from the primitive facts as stated in the source documents. Each point is tied directly to a paragraph or exhibit in the September 5, 2025, motion or the July 9, 2025, opposition. This ensures a solid, undeniable foundation for any subsequent analysis.