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PLAINTIFF’S REPLY TO DEFENDANT’S RESPONSE TO PLAINTIFF’S COMPLAINT – 1
Paris Shie Daniel Blake
314 Palmetto Drive
Edgewood, MD 21040
Phone | Fax
Email
Plaintiff in pro per
IN THE CIRCUIT COURT FOR BALTIMORE CITY
STATE OF MARYLAND
PARIS SHIE DANIEL BLAKE,
Plaintiff,
vs.
KENDRA MASSEY,
Defendant
Case No.: 24D-22000315
PLAINTIFF’S REPLY TO DEFENDANT’S
RESPONSE TO PLAINTIFF’S
COMPLAINT
NOW COMES Paris Shie Daniel Blake, Plaintiff, and files this Reply to Defendant’s Response
to Plaintiff’s Complaint, and for cause would show this Honorable Court as follows:
1. Md. R. Civ. P. Cir. Ct. 2-321(a) provides: “A party shall file an answer to an original
complaint, counterclaim, cross-claim, or third-party claim within 30 days after being
served, except as provided by sections (b) and (c) of this Rule.”
2. The only exception to this rule is filing within 60 days if the defendant has been filed out
of state.
3. Defendant was served with Plaintiff’s Complaint on [Insert Date]. She was served within
the State of Maryland.
4. Going by the above rule, Defendant was supposed to have filed her answer by [Insert 30 th
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PLAINTIFF’S REPLY TO DEFENDANT’S RESPONSE TO PLAINTIFF’S COMPLAINT – 2
date after the date above]. However, Defendant filed her answer on September 22, 2022.
The answer should be struck for being filed in an untimely manner, way beyond the
stipulated deadline by the foregoing rule.
5. Defendant claims that she filed and served her answer to Plaintiff on July 6, 2022. She
does not have any proof of filing or proof of serving upon Plaintiff.
6. Defendant’s answer is based on lies, falsities, misrepresentations and is filed in bad faith.
She attempts to use those lies, falsities and misrepresentations as grounds for not granting
Plaintiff custody of the Minor Child.
7. Defendant falsely states that Plaintiff’s fiance’s 10-year-old son takes care of Plaintiff’s
and Defendant’s Minor Child while Defendant and his fiancé are at work. Plaintiff has
never left the Minor Child with his fiance’s 10-year-old son. Plaintiff and his fiancé have
work schedules that are first shift and third.
8. Defendant falsely states that Plaintiff has not kept up with the Minor Child’s hygiene and
that he comes home unbathed and without clean teeth. To the contrary, Plaintiff and his
fiancé always take care of the Minor Child and ensure that he is well fed, bathed and
clothed. Plaintiff has the Minor Child’s set of clothes, shoes and under garments. The
false claim that the Minor Child’s teeth are never clean is absurd. Plaintiff ensures that
the Minor Child brushes his teeth. Being a child, he is likely to eat and snack a lot during
the day, hence his teeth cannot stay squeaky clean throughout the day.
9. Defendant falsely claims that Plaintiff never enrolled the Minor Child for the whole week
that Plaintiff stayed with him and that there is lack of support from Plaintiff. As a matter
of fact, the Minor Child missed only a day of school that week. That is because the Minor
Child was in Pre-K in 2020 and Plaintiff did not have the login information to use the
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PLAINTIFF’S REPLY TO DEFENDANT’S RESPONSE TO PLAINTIFF’S COMPLAINT – 3
portal. He did not have it because Defendant did not give it to him, and Plaintiff did not
have the contacts of any of the Minor Child’s teachers.
10. It would be unreasonable for Defendant to claim that she does not receive any support
from Plaintiff, yet Plaintiff pays child support in the sum of $764 every month.
11. Defendant has threatened Plaintiff not to go to the Minor Child’s school, saying that she
will call the police if he does. It is unfair for Defendant to become judge, jury, and
executioner who proceeds to unilaterally limit Plaintiff’s parenting rights when she has
absolutely no authority or jurisdiction to do so.
REASONS WHEREFORE, Plaintiff respectfully requests this Honorable Court to STRIKE
Defendant’s answer from the record, GRANT all of the prayers in Plaintiff’s Complaint, and
AWARD Plaintiff such equitable and further legal relief as this Court deems fair and proper
under the circumstances.
Dated this ____ day of September, 2022.
Respectfully Submitted,
___________________________________
Paris Shie Daniel Blake,
Plaintiff in pro per
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PLAINTIFF’S REPLY TO DEFENDANT’S RESPONSE TO PLAINTIFF’S COMPLAINT – 4
VERIFICATION
I, Paris Shie Daniel Blake, do certify that I am the Plaintiff in the above-entitled action. That I
have read the foregoing Reply to Defendant’s Response to Plaintiff’s Complaint, and know the
contents thereof. That the same is true of my knowledge except as to those things stated upon
information and belief, which I believe to be true.
Dated this ____ day of September, 2022.
Respectfully Submitted,
___________________________________
Paris Shie Daniel Blake,
Plaintiff in pro per
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