Professional Documents
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IN THE MATTER OF )
HALLECK G. RICHARDSON, )
AND; ) Case No. 96D-217
)
CLAUDINE DOMBROWSKI )
__________________________________ )
Pursuant to K.S.A. CHAPTER 60
respectfully moves this Court for an Order restoring primary residency of the parties’ minor
child, Rikki A. Dombrowski, dob 12-12-94, to Respondent and establishing a parenting plan
affording the Petitioner reasonable visitation. In Re: The “Best Interest of the Child” and in
accordance with Federal, State and the Shawnee County Family Guidelines 2003; and; as
‘Matter of Justice’ being served to all parties, regardless of their ability to pay for such justice
Court regarding Custody and visitation in that the Respondent has permanently changed,
and re-established her address, back to Topeka, KS. Specifically, the mother is one mile
away from Rikki’s present school, Tecumseh North and Rikki will continue to go to the
same school. The Mother also resides, approximately two miles from Rikki’s father, the
Petitioner. This, therefore, will enable the parties’ minor child to “Equal Access” to BOTH
her parents. {Shawnee County family Guidelines 2003 7.03(a)(1)(2)(4)(5)(6)(7)(8)(b) K.S.A. 60-1628 and
K.S.A.60-1610 (B)(ii)(iii)(iv)(v)(vi)(vii )
2) That a Material Change of Circumstance has occurred in that minor child of the parties is
being denied the bonding time and a meaningful, significant relationship with her mother.
Petitioner has maliciously, intentionally and fraudulently perjured himself to the Officers of
the Court, and other Law enforcement officials, hence, denying the child of her mother in
the most extreme of “Parental Interference”. {Shawnee County Family Guidelines 7.03(a)(2) and
K.S.A.60-1610(B)(vi)(vii); Ex-Parté Order of February 03, 2004, recommended by the Case Manager Lloyd
C. Swartz.}
3) That a Material Change of Circumstance has occurred in that Rikki’s primary caretaker is
not Rikki’s father, but the fathers ‘live-in” girlfriend, Julie Miller, and her mother.
4) That a Material Change of Circumstance has occurred in that the live-in girlfriend, Julie
Miller, has two children also living with Rikki. The living conditions appear to be
inadequate for the number of people living in the home, as Rikki must share her room with
Julie Miller’s daughter, Danielle Traphagen, who is five years Rikki’s senior.
5) That a Material Change of Circumstance has occurred in that Julie Miller’s 9th grade son
Christopher Traphagen has shown demonstrable violence, uncontrolled by the school and
related to his own mental diagnosis of ADD, clearly showing that if this ‘Young Adult
Male’ can NOT control his violent tendencies in school, then he can NOT be expected to
control them against Rikki, who is seven years younger than he. Petitioner has forced the
primary care of our daughter Rikki, onto a woman who is NOT related and is nothing more
than a ‘live- in’ maid, cook and child care giver. Neither Julie Miller nor her Mother are
licensed by the State to care for my child. {Shawnee County Family Guidelines 2003 7.03(a)(2)
and K.S.A.60-1610(B)(vi) }
records and documents that have been made a permanent part of this case’s Court file and
record.
7) That there are several Material Changes in Circumstance to warrant a hearing and/or Order
of the Court to make a determination that is TRULY in the “Best Interest of the Child.”
8) Rikki is coming of age and into a young lady, who needs HER mother now more than ever
as she deals with the biological changes of her body and, other life issues that Rikki will be
facing as a young lady. Such as ‘social adjustments’ in her adolescence, as she grows into
her own independence and on into a ‘healthy’ adult. It is hard enough to be a teenager,
9) Rikki needs to be comfortable and secure enough in her own self- esteem, comfortable
enough to ask intimate questions and trusting enough to ask those questions, so that Rikki
can be armed with knowledge to be in a position for sound decision making, as she begins
10) Rikki’s own mother is best suited for this developmental phase of Rikki’s upcoming life
changes as,
a MVA.
11) Rikki’s mother, the Respondent is ready, willing and capable of caring for her child.
Rikki would have her OWN room, which is an important aspect to a pre-teen, to which
12) Respondent has always promoted the relationship and bonding between the Petitioner and
Rikki (even though there has been past evidence of abuse to the mother, the Respondent by
the Petitioner).
The Respondent will continue to do so, which the Petitioner, has been ‘un-willing’ and
proved that he is ‘un-willing’ to do so in the future, with Rikki and her mother, the
13) It is in Rikki’s “Best Interest” to be with her natural mother as much as she can, as well
as to be reunited with her ‘maternal’ family, to which Rikki has been bonded all of her life
up until this past year when they were cut/removed from this child’s life as well, by the
issuance of an Ex-Parté Order, issued on February 3, 2004.
14) This Motion is being filed in accordance with the End Summer Shawnee County Family
Guidelines of July 15, 2005 deadline to file End Summer Motions for a Change in or
WHEREFORE, Respondent prays the Court to enter an Order restoring primary residency of
the minor child of the parties, Rikki A. Dombrowski, dob 12-12-94, to Respondent and
establishing a parenting plan affording Petitioner reasonable visitation and for all other relief
_________________________
Claudine Dombrowski
P.O Box 4974
Topeka, KS 66604
Facsimile (775) 806-3730
Telephone (785) 845-3417