Custody And Maintenance Reply

I am a lawyer. I am acting on behalf of the applicant in a custody and child maintenance application. I want your help in drafting the reply to the respondent's reply to the applicant's application. I will upload the respondent's reply as a pdf, and then I will provide you with email text from the applicant of his response to the respondent's reply. I want you to use the same format and style of response that the respondent used in the pdf, just making the changes to the perspective of the applicant and using the email text reply from the applicant to write the reply.

I can provide you with the applicant's reply to the respondent's reply to the applicant's application

This is the applicant's Response after reading the respondent's reply to the application: #* she return to her mother house because she wanted to keep committing adulterous behavior many males and dressing uncommonly which her mother told her to move out of the house when I go to work but I found out and I didn’t go to work which I told her that she doesn’t have to wait until I go work to pack up and leave… #* on many accounts I call and text her about being with our child and she always has a excuse saying that he sleeping in high daytime or he was sick or she just doesn’t reply or answer my calls and text.i will then send her a verses from the bible about her behavior. Because the only time I ever did get him is if she has no one home to keep him especially at night So that is verbal abuse and controlling to her -* Corinthians chp *..I never allowed her to come to my house meeting me somewhere was always the deal because she is not to be trusted. #* I never ever told her or wanted her to come to my house for money she’s not trustworthy so I would meet her halfway or by the shop with his money mostly weekly until her mother told her not to take any money from me which she started doing so #* she or someone in her house took away my son tablet so he can’t call me and his father family and when I ask her for it she told me to call the police which I did and they came and was ashamed that big ppl took away a */5 year old toddler tablet from communicating with his family the she was told to give me it back which I received it. #* is as #* #* the call app my family used is name Skype calls which she and her household stopped our son from communicating with his father family #* is #* and it was not homework reasons and her dates are wrong #* on many occasions I help our son with homework and it was correct she is confused with her other child who doesn’t do any homework then get expelled from school for his bad behavior and abuse of teachers and students #* a plastic bag with toys and a tablet can’t be hidden #* is #* #* is #* with wrong dates she wrote.she didn’t wash and plated his hair for about two and more weeks it was smelling and locks matted I was told by a teacher at his school and caregiver then I told her about it and she and her mother cursed and threatened me I took our son to school because he said he needed me to because he wasn’t allowed to be with and speak with me for weeks because of the bad treatment of his mother and her household taking away his tablet and deleting the Skype call app so me and his family from my side from communicating I took him home by my house and undone his hair and wash it and unlocking it then took him to a saloon to get it twisted it wasn’t tight she and her mother was jealous and vex that I got it fix I took him back around * pm that someday #* our son was being force to finish school at 1pm because of two teachers accused his of be disruptive and they were abusing him also and she never told me this so I was told this by another teacher because I’m known at the school as a decent trustworthy parent but when this started I was informed by the teacher which I’m promised not to say her name because of what will happen afterwards to my son the two teachers would beat him with cou cou sticks and hangers and rulers until his fingers were swollen. #* is #* behavior of her #* is #* again #* is * again #* is #* with additional information she afterwards I collected him that morning to school she was told to go to the police station by her mother and men friends to get a protection order so I can’t see our son but the court found out that her claims were false and untrue and she was unfit to guide our son life and she was sent to a parent consulting at parados and she refused and then the magistrate told her it’s mandatory because the child care board is involved then she said ok and I then told the court that I need to go as well because of the torment I was going through just to be with our son #* like #* my son would call me crying saying he missed me and don’t want to be at his mother house he would say he missed his sister and brother and grandma while crying then she would shout at him and slap him and turn off his tablet and take it away from him #* when we were living together in my house our son didn’t had those cavities that happened way afterwards when she returned home and was neglecting brushing teeth and not taking care hair then his face got swollen large and gyms and teeth infection and eyesight was affected then only she call me because he couldn’t go school he was home for 2days in tremendous tooth and face pain I told her where to go to my family dentist but she when other places and couldn’t get it done so then she when to where I told her and got advice from the dentist The cost was told to us then I told her it’s her fault she has to pay for it and I then went to the child care board to report her child neglect #* is #* with she received funds for our son at the little to no access I got with him #* I paid for all his online supplies and computer supplies and school uniforms and at home supplies from textbooks to large black and white board everything I bought and delivered to her house the next year she went ahead and bought stuff not telling me anything about the list of things that he got which was very disrespectful trying to make me look like bad I didn’t buy anything for my son #* his brother kawsie has anger issues and abuse to others from primary school age on to secondary which he was expelled for disrespecting teachers and abusing other class members and would skip school many times and be outside smoking and driving around at night with wanted males also he would take my son outside on the block and blow drug smoke in my son face as some people and my son told me of this I told her not to let him take my son anyway because of his bad behavior and company but she nevertheless listen to me #* she only bought the bicycle because I told him in front of her and her mother that I will buy a bicycle on Friday for him she ran and buy it the day before and it wasn’t even assembled properly I had to make things tighter it was dangerous #* he grew drugs in the backyard of her mother house google Jerry Haynes halls village st James drugs court and see on the internet and her mother knew about it and accepted it plus she doesn’t believe in the bible #* is #* #* her son threatened me in front of * persons on republic day saying he got shots fa me his uncle was they to witness this and push him and slap him and told him to go home and keep away from me because I’m living my life without his mother and I never threatened him I went to the police station and made a complaint and the police went and warn him but then the next year he attacked me on the pasture and then he is now charged with assaulting me the case is still pending to start soon. #* shows #* #* #* #* her family and his mother is unfit unhealthy unstable unsafe mentally and physically unhappy environment he needs a safe peaceful loving healthy environment playful educational fun and godly mostly protective environment and only with me it can happen before it’s to late he might ended up like his uncle and brother a nonsense and hazardous to society #* like #* I would call and she never communicate response on anything that I text her about any camp until I saw her at the shop and told her and she told me her mother will keep him home inside like always #* lack of communication on her side her mother couldn’t collect him from school and told her then she call a 3rd cousin that my son doesn’t know to collect him he was found by police officers behind queen’s college school husband’s trying to find his way home the police recognized his uniform and took him back to the school he was 5 years old missing for 1hr and * minutes after this she call me asking me if I see my son he missing she never ask anyone why this happened but she and her family curse and threatened me because I went to the police and child care board about what happened #* my mother name is one of the name with her mother to collect him nobody else at the school office #* I told her that my mother will collect my son because her mother was unreliable and I then let the school office know then when my mother went to collect him her mother show up cursing and threatening and wanted to beat my mother because she came to collect my son my mother walk away from her crazy behavior on the school property in front of other kids and parents unsatisfactory behavior she knew my mother was going to collect him this behavior is from a christian? #* she hide up our son get badly abused by * teachers and also beating him and damaging his fingers swollen with cou cou sticks and cloth hangers and also not letting him go to the bathroom then to soil himself in class I went child care board and the ministry of education and police to report this and she knew what I was doing I told her and she told me that she can’t do anything about it that I would make it was for our son so I went full ahead and the teachers were told not to hit my son ever again if they did it they were going to be charged.many parents has complaints about the same teachers abusing young 5 years old mostly boys at that school #* that teacher was unprofessional and wanted a newly turn 5year old to sit down beside her and talk to her that’s impossible cause he doesn’t know her and wanted to sit down with me but she the teacher was forcing him to sit which made him more scared of behind next to her #* that meeting was a last minute decision and I told them to schedule a meeting date and time and the next meeting one of the teachers would was abusing him deny beating him and I show her the evidence and she got piss off and walk out of the meeting unprofessional #* I saw her and our son at the school gate he was crying and scared saying that he will get beat up again by the teachers I ask her when she will investigate this and she said she has to go to work and got back into her man car and drove off i took my son with me that day to work because I was allowed a conversation with the principal about the teachers the next day I return and got no audience so I went to the ministry education and laid a complaint and file a report on this matter. #* only when the child care board and the ministry of education and police attended the school and told the principal and the two teachers to never hit the child again they will be charged because it’s against the law to hit children at school then he settled down again and wasn’t scared of getting beat up for helping other children with they work she did nothing to stop the abuse on our son #* she is unfit to rise and guide him her family also is a hazard to his development #*-a -b-c can’t never work with her as what she let happened to him .she’s not fit and cooperative before nor will she be now #*-e is what I’m to receive from her for the maintenance of our son to my bank account #*-f my son needs no Psychologist it’s her and her family mother and brother and her older son that need it nothing is wrong with him this is why I need full custody of my son before they do something harmful hurtful life threatening to him #*-g this was happening before then after a meeting that evening I was attacked by her son because she was piss off that day because of the questions she was being asked by the parados officer so I wouldn’t be in that situation again #*-h she does need a psychologist but she does hold herself accountable for her actions and behavior and taking bad advice from unkind people #* what she wrote in this Affidavit was untrue untrustworthy lacking a lot of evidence and incorrect information and this shows that she is unfitting to rise our son. Any married person who doesn’t like or take responsibility and lack empathy and make foolish lifetime decisions for short time pleasures not protecting and risking their child life with crazy ungodly people should not be allowed to rise a child there is only one road they can lead it down a life of crime and violence and death . I am the only one who was and still fought and protected him throughout his pain and suffering he received..she will abandon him when things get bad she is known for this…

is there anything that the applciant has said that i cannot include?