IN THE CIRCUIT COURT OF JACKSON COUNT, MISSOURI

AT KANSAS CITY
FAMILY COURT DIVISION
MICHAEL MCKINZY,
Petitioner,
and

Case No. 02-FC200809-04

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, and
3. Petitioners First Request for Admissions to Respondent Carletha R. McKizyGaston, by U.S. First Class Mail postage prepaid at the following address:
Carletha R. McKinzy-Gaston
8904 Cambridge
Apt. 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. 86th St. Apt. D
Overland Park, Kansas 66212
(913) 742-3621
michaelmckinzy@gmail.com
Petitioner, Pro se

AFFIDAVIT
STATE OF KANSAS
COUNTY OF JOHNSON

)
) ss:
)

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 and
knowledge 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:

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CERTIFICATION OF SERVICE

I hereby certify that on this 10th May 2016, I mailed Petitioners 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) 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 100
Kansas City, Missouri 64108
Telephone: (816) 531-6055
Facsimile: (816) 221-2508
sgrant@kc.rr.com
Attorney for Respondent
(pursuant to Limited Scope Entry)
/s/Michael E. McKinzy, Sr.
Michael McKinzy, Sr.

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