Petitioner's Reply to Respondent Suggestions in Opposition to Default Judgment-Case No....

7/26/2019 Petitioner's Reply to Respondent Suggestions in Opposition to Default Judgment-Case No. 02fc200809-04 Case Ca

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IN THE CIRCUIT COURT OF JACKSON COUNT, MISSOURI

AT KANSAS CITY

FAMILY COURT DIVISION

MICHAEL MCKINZY,

Petitioner, Case No. 02-FC200809-04

and Division 43

CARLETHA MCKINZY

Respondent.

PETITIONERS REPLY TO RESPONDENTS ANSWER AND INCORPORATED

SUGGESTIONS IN OPPOSITION TO MOTION AND ORDER FOR ENTRY OF DEFAULT

JUDGMENT PURSUANTTO MISSOURI SUPREME COURT RULE 61.01(b)(2)

Comes now Petitioner, Michael E McKinzy, Sr. (Petitioner), submits his Reply to Respondents

Answer and Incorporated Suggestions in Opposition to Petitioners Motion and Order for Entry of

Default Judgment Pursuant to Missouri Supreme Court Rule 61.01(b)2), effective January 1, 2016, and

states as follows:

1. Respondent, by and through her limited-scope attorney, Sandra Grant Hessenflow, once

again attempts to turn back the hands of time in this proceeding when Respondent was

preceding pro se, to undo damage done by her client, something which if allowed would

undermine the very fabric of Equal justice under law.Binder v. Throne-Binder, 186 S.W. 3d

864,868 (Mo. Ct. App. 2006).

2. Pursuant to Missouri Supreme Court Rule 43(d)Service - When Complete.

Service by mail is complete upon mailing.

On March 12, 2016, I served the following:

1. Petitioners First Interrogatories to Respondent Carletha R. McKinzy-Gaston,

2. Petitioners First Request for Production of Documents to Respondent Carletha R.

McKinzy, and3. Petitioners First Request for Admissions to Respondent Carletha R. McKizy-

Gaston, by U.S. First Class Mail postage prepaid at the following address:

Carletha R. McKinzy-Gaston

8904 CambridgeApt. 3205

Kansas City, Missouri 64138 [sic]


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WHEREFORE, Petitioner, requests that Default Judgment pursuant to Missouri Supreme Court

Rule 61.01(b)(2) be entered against Respondent; to be award Petitioner attorney fees and cost incurred

in these proceedings; and for such further orders, judgments, and decrees, as are deemed just and

proper in this matter.

Respectfully submitted,

/s/Michael E. McKinzy, Sr.Michael E. McKinzy, Sr.

9606 W. 86thSt. Apt. DOverland Park, Kansas 66212

(913) [email protected]

Petitioner, Pro se

AFFIDAVIT

STATE OF KANSAS )

) ss:

COUNTY OF JOHNSON )

I, Michael E. McKinzy, Sr., being fully sworn upon my oath, state that I have read the above

Reply, and the information contained herein is true, accurate and correct to my best belief andknowledge as of todays date.

/s/Michael E. McKinzy,Sr.

Michael E. McKinzy, Sr.

Subscribed and sworn to before me, the undersigned Notary, on June 10, 2016.

/s/Notary Public

Notary Public

My Commission Expires:
mailto:[email protected]:[email protected]:[email protected]


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CERTIFICATION OF SERVICE

I hereby certify that on this 10th May 2016, I mailed Petitioners Reply to Respondents Answer andIncorporated Suggestions in Opposition to PetitionersMotion and Order for Entry of Default

Judgment Pursuant to Missouri Supreme Court Rule 61.01(b)(2) to Attorney for Respondent (pursuant

to Limited Scope Entry) by First Class Mail postage prepaid to the following addresses:

Sandra Grant Hessenflow, #40346

2029 Wyandotte Street, Suite 100Kansas City, Missouri 64108

Telephone: (816) 531-6055Facsimile: (816) 221-2508

[email protected] for Respondent

(pursuant to Limited Scope Entry)

/s/Michael E. McKinzy, Sr.Michael McKinzy, Sr.

Petitioner's Reply to Respondent Suggestions in Opposition to Default Judgment-Case No....

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