IN THE CIRCUIT COURT OF JACKSON COUNTY, MISSOURI FAMILY COURT DIVISION AT KANSAS CITY In Re the Marriage of: MICHAEL MCKINZY, SR. Petitioner, Case No, 02FC-200809-04 and i Division 43 > CARLETHA GASTON = Respondent. S PETITIONER’S REPLY TO RESPONDENT’S MOTION FOR CONTINUANCE AND COORDNATING REQUESTS e & COMES NOW the Petitioner, Michael E. McKinzy, Sr, and submits Petitioner’s Reply to Respondent’s Motion for Continuance and Coordinating Requests, and states: 1. Purusant to Respondent's attorney, Sandra Grant Hessenflow, Entry of Appearance for Limited Scope of Representation pursuant to Missouri Supreme Court Rule 55.03(b)(3) filed with the Court on April 26, 2016, the limited appearance on behalf of Carletha Gaston (McKinzy), the Respondent is for the exclusive purposes of (L)preparing the Respondent's Request for Continuance and (2) Coordinating Relief, and (3)for representing the Respondent during a hearing regarding the same in Division 43, The Entry of Appearance for Limited Scope of Representation also states as follows: “Undersigned Counsel is representing Respondent only with regard to those portions of Pending case number 02-FC200804-04 specifically set forth above, and for no other purposes. Any pleadings, motions or other papers or proceedings concerning existing, subsequent or Collateral matters not covered by this Entry of Limited Appearance shall be directed to the Respondent individually and must be served upon her personally, as well as provided to Undersigned Counsel, in accordance with the applicable Missouri Supreme Court Rules.” 2, Respondent’s retained Limited Scope of Representation attorney, Sandra Grant 1|PageHessenflow, has exceeded her scope of work pursuant the her Entry of ‘Appearance as filed with the Court and her pleadings regarding the summary judgment motion proceedings and motion to compel discovery from respondent should be stricken from the record as being in excess of her Entry of Limited Scope of Appearance. » . Furthermore, Respondent's Motion for Continuance filed on May 2, 2016, must be stricken due to failure to properly serve Petitioner pursuant to Missouri Supreme Court Rule 43.01(¢) no copy of said pleading was attached to email received on May 2, 2016 from respondent's attorney. x |. Respondent state number of continues is inaccurate, Respondent has requested two continuances to retain counsel, and again on April 15, 2016, the last trial setting for the above captioned case, . Due to the deemed Admissions currently on record before the Court, Petitioner believes there remains no genuine issues of material facts regarding the emancipation dates of all children born of the macriage, as being: Barbara J. MeKinzy, January 6, 2004; Deon M. McKinzy, June 8, 2006; Deron T. McKinzy, June 8, 2006; and Michael E. McKinzy, Jr., October 16, 2007, furthermore, the date of Decemeber 31, 2005, establishing termination of Petitioner's maintenance obligation to Respondent, Rohner v. Long, 57 $.W. 3d 920 (2001) espectfully submitted hs Fall Michail OT hen Sala abMidas 6. Mest phe efshaw, Michael E. McKinzy, Sr. 9606 W. 86" St. Apt. D Overland Park, KS 66216 (913) 742-3621 michaelmekinzy@pmail.com Petitoner, Pro se CERTIFICATE OF SERVICE I hereby certify that on this 3“ May 2016, I mailed Petitioner's Motion and Order to Have Requests for Admissions Deemed Admitted to Attorney for Respondent (pursuant to Limited Scope Entry) and Respondent by First Class Mail postage prepaid to the following addresses: Carletha R. McKinzy-Gaston 8904 Cambridge ‘Apt. 3205 Kansas City, Missouri 64138 Sandra Grant Hessenflow, #40346 2029 Wyandotte Street, Suite 100 Kansas City, Missouri 64108 Telephone: (816) 531-6055 Facsimile: (816) 221-2508 sgrant(@ke.r.com Attorney for Respondent (pursuant to Limited Scope Entry) ied tai Sr 3|Page