Date: April 2, 2008 14 pages with cover sheet “Emergency Motion” RE: Case No. 96-D-217 From: Claudine Dombrowski Phone: (785) 845-3417 Fax: (888) 330-2059 To: Judge Joe Johnson Fax: (785) 291-4917 Don Hoffman Fax: (785) 233-2173 Jill Dykes Fax: (785) 232-0600 Clerk of the District Court Fax: (785) 291-4908 Domestic Filings Fax: (785) 291-4911Claudine Dombrowski PD Box 4974, Topeka, Kansas 66604 (785) 845-3417 Respondent, Pro Se IN THE DISTRICT COURT OF SHAWNEE COUNTY, KANSAS. DIVISION FOUR In the Matter of the Marriage of HAL RICHARDSON and Case No. 96-D-217 CLAUDINE DOMBROWSKI Emergency Motion For Immediate Intervention of this Court forthe h ind best interest of minor child Comes now, Claudine Dombrowski, requests emergency Motion for Order and implementation. In support 1. On March 30", 2008, | received the memo dated March 19", 2008 of Safe Visit's suspension of all visits. Rikki is, has and continues to suffer from a mix of emotions, and false beliefs, directly attributable to the length of time [4.5 yrs] and inability to speak ‘openly’ with her mother other than ‘neutral’ generic safe visit standards, liability of the GAL and MHP as above [paid by state to advocate for my child] and of this Court's ‘inaction’ to truly act in the best interest of the child. 2. The situation is critical and being further exasperated, [2s although ‘extremely limited’ was at jeast ‘some’ contact,] minor child is denied to see her mother at all, and requires immediate intervention on behalf of the child’s heath3. Further delays will only exasperate the damage already incurred and is not in the best interest of the child 4. | request that this court follow with out any delay the Safe Visit letter, | further request that a reunification therapist [such the attached] for child and her mother be ‘implemented’ as a ‘reunification’ process with whom ever this court wants at the states expense... and do so immediately. 5. that this court use at its disposal their Emergency contacts and implement a letter order with in a few days. 6. | am available via phone, conference and or fax to all parties to implement this for the sake of minor child and her best interest. For all parties convenience | have enclosed, the safe visit suspension memo, the last and most recent reports on the courts file: directly relating to the above instant matter; of: Paula Clanton, February 7" 2006 and Mary Ann Dugan, July 17, 2006 Respectiully, CSS Sk Claudine Dombrowski dated:4-2-2008 Mother/Respondent PD Box 4974, Topeka, Kansas 66604 P. (785) 845-3417 F (888) 330-2059 Respondent, Pro SeCERTIFICATE OF SERVICE Thereby certify that on the 2” day of April, 2008, that I fax filed a true and correct copy of the above Emergency motion in accordance with supreme court rule 119(b)(3) to the following: Judge Joe Johnson Fax: (785) 291-4917 Don Hoffman Fax: (785) 233-2173 Jill Dykes, Fax: (785) 232-0600 Clerk of the District Court Fax: (785) 291-4908 Domestie Filings Pax: (785) 291-4911 CSSe we Ok Claudine Dombrowski dated:4-2-2008 Mother/Respondent PO Box 4974, Topeka, Kansas 66604 Phone: (785) 845-3417 Respondent, Pro Seit my WV Kuehne Family YMCA — YMCA Safe Vi Satellite Office 2036NW Taylor ‘Topeka, Kansas 66608 (785)234-4677 Fax (785) 234-5466 email safevisit@kansas.net Memo To: Hal Richardson and Claudine Dombrowski From: Connie Sanchez, Safe Visit Administrator Regarding: Supervised Visitation Services Date: 3-19-08 This letter is being drafted to give notification to all parties, that effective 3-19-08; services will be suspended. Please know this decision was not made in haste, rather implemented after several cases reviews by Administration. Itis the intention of Safe Visit to be a safe, neutral, ransitional resource for families who require 3" party intervention to cnsure parent/child contact. Staff has been providing supervised visits between Ricki and her mother since September of 2004. Staff is not aware of all the specifics requested by the Court to initiate a modification or change in parenting time. However, services will not resume until the plans outlined by the court for resolution are initiated (a psychological evaluation for Claudine). Ricki is a bright, articulate, fun loving 13 year old girl. As observed by staff, during visits with her mother, Ricki shows mixed emotions, At times, she seems content with seeing her mother in the limited environment of Safe Visit; as they talknon stop, play games and eat snacks, Ricki uses the visit as atime to share stories regarding friends, school, homework etc. Claudine is very responsive to Ricki; she offers an abundance of positive support and glorifies all of Ricki’s thoughts and dreams. On other occasions, during visits Ricki is somewhat withdrawn, expresses being tired and responds coldly, critically and rudely to her mother’s comments and appears embarassed by her mother’s statements, appearance and behaviors. At times; Ricki will not answer her mother’s questions at all and talks to staff instead or tells her mother to stop the current line of conversation. It seems when Clandine tries to talk with Ricki about her work, computer knowledge or childhood memories Ricki either changes the subject o does not acknowledge her mother’s comments. Although staff believes all teenagers have differences with their parents as they grow and develop independence, Ricki is struggling with other issues related to trust. Recently, staff asked Ricki how she would feel about allowing her mother to take a photo of her (Claudine requested a photo opportunity). She expressed being uncomfortable with doing a photo as she was unsure what her mother would do with the photo as in the past her mother gave out her cel] number/email to someone her mother deemed “like her” (a ‘This program ded in part by grants provided bythe United Wie, Shawnee County, City Yat Services Fund, the State Child Exchange and Visitation Center Progran, and the Federal State Access ara Visitation Program as administered by Kansas Artormey Generel and The Governor of Kanses.victim of abuse). She told staff she wants to have a “normal” relationship with her mother “ile her friends” do with their mother’s but is concerned that her mother will embarrass her (treating her like a young child), make up stories regarding her Dad (marching in the DV parade/website), and also expressed concern regarding where her mother lives, with whom ete. ‘There is no easy resolution to re-establishing parenting time for Ricki and her mother. Ricki acts grown up but she is still a child. Ricki has been in therapy with Dr. ‘Rodenheffer on and off for several years. A GAL is also assigned to look at the best interests of Ricki Staff respectfully requests the court review the lack of movement on thi whether or not ongoing visitation at Safe Visit is the best plan for Ricki. ‘case andJuly 17, 2006 Judge Joseph D. Johnson District Court judge ‘Shawnee County Courthouse, Room 311 200 SE 7* st ‘Topeka, Kansas 66603-3696 Re: Claudine Dombrowski: (DOB 4/10/1965) Dear Hon, Johnson, 1 am writing this etter on behalf of Cluline Dombrowski. She came to my office on June 28, 2006 wanting help to regain joint custody and visitation with her daughter, Rikki. It is my ‘understanding she has been separated from her daughter for the past 6 years and has supervised “ae visits” with her twice @ month for an hour. ‘Ms. Dombrowski states she loves Rikki unconditionally and has been suffering with emotional pain since being separared from her daughter, Throughout our sessions, I ave been tod by Ms. Dombrowski thet she has never been charged with any form of child abuse toward Rikki. Tam pezplexed on why she bas only been allowed to see er daughter for two hours a month thn safe Visits. Tt makes me wonder i she has been a victio lost inthe judicial system with nowhere 10 go, If tis isthe case, it needs to be rectified immediately. [No child should be kept away from their parent Because husband and wife are ut extreme odds ‘with each other. The anger between Ms. Dombrowski and her ex husband needs to be resolved and an equitable agreement reached so that their daughter is removed from the center oftheir cont, "Throughout the years of my practice I have found in most eases; money and/or children are used to get back at one another. This is wrong and should be stopped. The only unconditional Jove is betwen a parent and their child. The child necds to have access to citer and/or parent. Children require the love, nurturing and acceptance from both parents, The parents are the modet {or the child to grow intellectually and emotionally in ordet for them to become the best person they can be. ‘When a child is abensted from either parens that child is given the often unspoken but clear message that one parent is senior to the other. Therefore, access and contact blocking by either parent noeds to be closely observed. Ms. Dombrowski, to my knowledge, has never been found cate awe proezizsee ep e0 9002/62/00hardened Tessier ‘epee Del ly adept etal ism, Aye exe ‘tl ape ties tis cash | ‘waa sce net og is co ht ita ard in in ob polit oe shred ear shnioae Oka heme eaten? ni Wie des) ete ey iii ssespivopy Ciena ctekpm eerie iene pe. ies abo sah ust pee erg inde girs ca l plege fags eis erik leydhent lire amg deedost ema smells ptt ape be oat Debs net inde, Senshi, iii tae gilt lr “Nii Dibner sh weedeat a enka lap comme aoe, it gs pico ose nt alee tg ch Ts ‘aging heme dah hit iho erie engsieeicaceepe wt Tyee ood ie. ii ere ple oh eet abate | erie cease a ig eas. lentes pa skeen Sa, ayo SOK CF, co) vty ete SalataHOFFMAN & HOFFMAN ATTORNEYS AT LAW 112 Wes Sevemh Garden Ste Topeks, Kansas 66 Donald tm felon (785) 293 Fcsimies (7459233 March 1, 2006 HAND DELIVER The Honorable Joseph Johnson District Court Judge - Division 4 Shawnee County Courthouse 200 S.E. Tih Street Topeka, Kansas 66603 RE: __Hal Richardsonv- Claudine Dombrowski ¢ No..96-D 217 ; Dear Judge Johnson: Pursuant to your instructions, we have conducted the interview of the school ‘counselor, Stacy Mickens, | am enclosing my rough notes of that conversation, along With the original of the Home Study conducted by Paula Clanton, LSCSW. I believe that this concludes the specific requirements that the Court lirected of me at our last hearing. 1 would appreciate the Court advising how you wish to have these materials dissimilated to the other parties. 1 would be happy fo mail a copy to Jill Dykes, the Guardian Ad Litem. oe Va DONALD R. HOFFMAN DRHish Ene. co: Bethany Roberts ill DykesBIOPSYCHOSOCIAL ASSESSMENT (individual Interviews and Home Re: Case: No, 26D 000217 Richardson vs. Dombrowski 1. CHIEF COMPLAINT-PRESENTING PROBLEM ‘This case was referred to me by Mr Don Hoffman who is the attorney for Mr. Ial Richardson Jr. ‘This writer conducted an individual interview with Mr. Richardson Ir and a home visit with Mr. Richardson, Ms.Julie Miller (who lives in the home with Mr. Richardson and is his significant partner), Rikki Dombrowski (DOB: 12/12/94), whom is Mr, Richardson's daughter, Dani (DOB: 09/24/92) and Chris (DOB: 11/28/90) who are the children of Ms. Miller. All individuals presented with very mild symptoms of anxiety related to the potential of Rikki being removed from her home, She voiced this concern herself and ststed that she did not want to “leave lner dad”. She further stated that she thought my role was to assess her living situation and to decide whether or not she should live with her mother or see her without anyone else. She strongly voiced her concerns about this arcl stated that she is “fearful of her mother". Rikki reports being tired of "safe visit" but is nervous and fearful of Mom without anyone else present. Her history reveals she has been afraid of her mother's actions even in the presence of an adult (i.¢., school personnel). TL PSYCHIATRIC HISTORY Upon questioning, Mr Richarson and Ms. Miller do not present with symptoms that would warrant a DSM TV diagnosis. Rikki presents with some symptoms of anxiely (apprehension and quietness) which she describes as related to my interview. She stated “I'm afraid of leaving dad” began to talk with Rikki about her relationship with her mother, | asked her how she felt her visits with her mother were going at the Safe Visit Program Rikki stated that she is “is burned out ‘on safe visits but is very afraid of seeing my mom alone.” She further stated that she is “aftaid thet, ‘mom will take me and leave,” She also states that “mom is liar”. When Tasked her why she thought her mom was a liar Riki stated that she “dressed up in a wigs and came to my troop meeting and scared me.” Rikki described that during a scout meeting her mother came to her meeting dressed in a wig and Rikki was ushered into the rest room by the scout leader whereby he: ‘mom then procceded to try to talk with her. Rikki claims she was "screaming and very afraid by this and is scared Mom will do crazy things again". She further stated that she “coes aot trast my Per Mr. Richardson's report, Ms. Claudine Dombrowski has threatened him. He further states hat she has violated court orders by seeing Rikki in disguise as in referenced 10 the above- mentioned episode. I have not had the opportunity to mect with Ms. Dombrowski and am only going, on information { have available (o me. Based on the information available to me, | would recommend that Ms, Dombrowski undergo a thorough psychiatric evaluation Both Mr. Richardson and Ms. Miller deny psychiauic problems or historyIM, SUBSTANCE ABUSE/DEPENDENCE. Upon the information available to me, Tam not aware of any substance abuse problems with Mr Richardson and Ms. Miller. They both deny tobacco use. IV. MARITAL HISTORY Both Mr Richardson and Ms. Miller have been martied previously and have children from those ‘marriages. ‘The current living situation is such that Ms, Miller's two minor children, Dani and. ‘Chuis, live in the home. On observation, the children including Rikki, Dani, and Chris all interacted appropriately with one another and with Mr Richardson and Ms. Miller, Ms, Miller states that her rclationship with her ex-husband is going weil in terms of functioning what is in the best interest of their chitdren, Mr. Richardson and Ms. Miller have been in their current relationship since 1996. This relationship appears healthy and Ms. Miller has always been an active part of Riki's lif, Mr Richardson has had custody of Rikki since 2000. 'V. SOCIAL HISTORY Rikki appears to be a welladiusted filth grader who is involved in different activities. She is a member of her scout troop and had formerly participated in Karate. When asked how come she did not participate in Karate any longer, Rikki reported that it was because her instructor had moved. Rikki also reports liking time with Julie Miller and her stepsister Dani and often times they will go and have a “girls’ day”. They will go shopping and out to lunch and do a variety of activition tugether. Aguin, by observation in the family home, everyone acted appropriately and interacted well. There were several pictures displayed on the wall of the family and the house was clean and well maintained. Dani and Rikki share a room which was appropriately maintained, Rikki also showed me many of her collections and her scouting badges. VI. VOCATIONAL HISTORY Mr. Richardson reports he has been self-employed owning two businesses for approximately August of 1989. Ms. Miller has been at her current job for 2% years. She works at Jayhawk Ares Agency on Aging, Vi. SCHOOL PERFORMANCE This writer had contact with Ms. Stacy Mickens, Rikkis high school counselor. Ms. Mickens reports that Rikki is a well-adjnsted fith grader wud hs had some visits with her since she has been attending Tecumseh North Elementary School. Her school performance is good and she is ‘well liked by her peers. Ms, Mickens reports thal (here was an incident on school grounds when Rikki was alfaid to go out at recess because her mother had come and stood by the side of the fence by the playground. Ms. Mickens worked with Rikki on problem solving approaches if mom should appea: by he feuce which included going, io the on duty teacher and standing next 10 the ‘on duty teacher at recess time. Ms. Mickens reports that over the last several years Rikki has been relatively well-adjusted and less fearful although on occasion will say she is alfaid her mother will show up and take her,CLINICAL CONCLUSIONS, ‘This writer would assess that this is a well-adjusted child and that Rikki is functioning well at this present time. This writer would be concerned with any unsupervised visitation by Ms Dombrowski with Rikki due to the information described above as well as Rikki stating directly that she is afraid of her mother and that her mother will take her away. She iileracts appropriately ‘with her father and has good telationship with him. Mr. Richardson has had residential custody of Rikld for the last six years and has taken good care of her according to consultation with the schoo! counselor, Ms. Stacy Mickens, as well as Rikki’s guardian ad litem, Jill Dykes, and my interview with the family and Rikki Rikki describes her father, Ms. Miller, Dani and Chris as family." a Respecifully submitted, Birnie Ckantor Paula J. Clanton, LSCSW Date signed. 2 - DY-_ OG 5847 SW 28th Street Topeka, KS. 66614 PCidaConversation with school counselor, Stacy Mickens- Swe (School Counsetor- Tecumseh North School) xe © Date February 7, 2006 a OS do en, Opt ce Ne He QE RE RE Hal Richardson/Ciaudine Dombrowski T had a conversation with Ms. Mickens relative to her contact with Rikki Dombrowski. She indicated that she had some direct contact with Rikki, one-on-one. Additionally, she had worked with Rikki fora time in a program at school Known "Banana Splits". This is a program for children who are in family of divorced or divorcing parents. She described that Rikki was a good student and seemed well adjusted. Rikki always appeared at school bright, fresh and ready to learn, Hor clothing, and personal hygiene were well groomed, She has a good attendance record and is not tardy to school ‘The counselor indicated that she was fami Richardson's "significant other". These children jar with the family and the child of Hal Wve altendlett classes at the school One of the concerns that Rikki expressed, from time to time, was the somewhat competitive nature of her relationship wilh the daughter of Hal's "significant « Ms. Mickens indicated that she believed that any controversy that existed between Rikki and the daughter was normal interaction and adokescent behavior Rikki has expressed, from time to time, a fair amount of fear of being alone with her mother and has expressed this in the past. She has felt threaten, i.e.. the particular event is When the mother appeared in disguise at school. These events resulted in somewhat of a wrestling match between Rikki, her mother and other adults who may have been knowing in concert with Ms. Dombrowski. Rikki is very concerned about her ‘mother obeying rules that are established for their visits and contact. Rikki has never expressed anything of a similar nature about her father, Hal cchardson, She has expressed an embarrassment about her mother’s actions, including» period of time when Ms, Dombrowski made frequent lunch time appearances at school. ‘The actions of her mother separated her from her clussmmates and friend Interference with her socialization. and was an