FACSIMILE

CASE NO. 96-D-217

4 pages with cover sheet

Transmitted February 4th, 2008

From: Claudine Dombrowski

Fax: 888.330.2059 Phone: 785.845.3417

to:
• Judge Joe Johnson
Fax: (785) 291-4917

• Clerk of the District Court

[Please file on court record- Case No. 96-D-217]
Fax: (785) 291-4908

• Domestic Filings
Fax: (785) 291-4911

Courtesy Copies:
Roger Scurlock- BSRB; Governor [grants], Dorthy Halley [executor of grants] Attorney Generals
Office, Jacquie Spradling [KS Domestic Violence task Force], Battered Women’s Justice Project,
Kansas Coalition Against Sexual Assault Domestic Violence; Shawnee County District Attorneys
Office’s, Battered Women’s Task Force, KOVA, Sen. Vicki Schmidt, Rep: Jim Morrison [Senate
Judiciary investigative cmtee], Sen. Derek Schmidt, Sen. Jan Pauls [Judiciary cmtee]Family Court
Reform Coalition, StopFamilyViolence.org, Jackie Williams, Battered Mothers Custody Conference.

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An error does not become truth by reason of multiplied propagation, nor

does truth become error because nobody will see it. -Mahatma Gandhi

www.AngelFury.org

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 IN THE DISTRICT COURT
THIRD JUDICIAL DISTICT, SHAWNEE COUNTY, KANSAS
DIVISION FOUR

IN THE MATTER OF
HALLECK G. RICHARDSON,
AND; Case No. 96-D-217

CLAUDINE DOMBROWSKI
___________________________
Pursuant to K.S.A. CHAPTER 60

MOTION FOR IMMEDIATE ORDER RESTORING AND

REINSTATING WITHOUT RESTRICTION CHILD AND PARENT
ACCESS.
A VIOLATION OF THE CIVIL AND CONSTITUIONAL
RIGHTS OF BOTH CHILD AND PARENT

February 4, 2008

COMES NOW, Claudine Dombrowski, Mother/Respondent, without counsel, and demands that

this court enter an Order IMMEDIATELY restoring the rights of child and parent to equal

access, as has been denied under the K.S.A, and CONSTITION, and that a restoration of those

FUNDAMENTAL RIGHTS be RESTORED with out any further delay.

IN SUPPORT;

1. It has been four years and one day since the above February 3, 2004 ‘EX-PARTE’ Order

was forced upon mother and her child denying both of their civil rights.

2. To date of this filing, February 4, 2008, four years later, there still has yet to be an

evidentiary hearing, to deny or restrict those rights, although has been requested since the

admission of ‘ex-parte’ order February 3, 2004.

 3. Mother has complied with every instruction of this and past courts, requests.

4. There exists NO FINDING of FACT anywhere, not even in the courts own ‘social’ file

to deny or restrict nor to continue to deny or restrict the rights of the minor child’s access

to her mother.

5. It is a denial of BOTH child and mothers rights under the constitution and bill of rights

and violates the fundamental rights and liberties of both child and parent.

WHEREFORE, Mother/Respondent requests that an ORDER be entered IMMEDIATELY

NUNC PRO TUNC [as it was before] the February 3, 2003 ‘ex-parte’ order that unethically and

unconstitutionally imposed upon mother and daughter, and as a matter justice, human and civil

liberties, a restoration of those rights without restriction must be acted upon without any

further delays.

Submitted,

CERTIFICATE OF SERVICE FOLLOWS

 CERTIFICATE OF SERVICE

MOTION FOR IMMEDIATE ORDER RESTORING AND

REINSTATING WITHOUT RESTRICTION CHILD AND PARENT EQUAL ACCESS.
A VIOLATION OF THE CIVIL AND CONSTITUIONAL
RIGHTS OF BOTH CHILD AND PARENT

I the undersigned hereby certify that on the 4th day of February, 2008, served a true and correct
copy of the above and foregoing pleading;, with the Clerk of the District Court, Judge
Johnson, and Domestic Filings, 200 SE 7th Street, Topeka, Kansas 66603, by facsimile in
accordance with Supreme Court Rule 119(b)(3) and sent a copy of the forgoing document, by
U.S. Mail, postage prepaid to:

Don Hoffman
100 E. 9th Street
Topeka, KS 66612

Jill Dykes
1243 SW Topeka Blvd.
Topeka, KS 66612

Cc: Roger Scurlock- BSRB; Governor [grants], Dorthy Halley [executor of grants] Attorney Generals
Office, Jacquie Spradling [KS Domestic Violence task Force], Battered Women’s Justice Project,
Kansas Coalition Against Sexual Assault Domestic Violence; Shawnee County District Attorneys
Office’s, Battered Women’s Task Force, KOVA, Sen. Vicki Schmidt, Rep: Jim Morrison, Sen. Derek
Schmidt, Sen. Jan Pauls [Judiciary Cmtee]Family Court Reform Coalition, StopFamilyViolence.org,
Jackie Williams, Battered Mothers Custody Conference,