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Subj:

Date:

From:

To:

Richardson v. Dombrowski # 960217 3/31/20049:40:45 AM Central Standard Time Civsol

d bruns@shawneecourtorg

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The Honorable David E. Bruns dbmns@shawneecourt.org

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RE: Richardson V. Dombrowski

96 D 217

Dear Judge Bruns:

I wanted to share some information on the above case that suggests the implementation of my prior recommendation, in full, may be appropriate for the court at this time.

1. Since the imposition of visitation to supervised visitation the mother has refused to

cooperate in any way to allow this to occur. She has advised Dr. Albott that she will not go to the North YMCA. She failed to cooperate with Dr. Albott and Dr. Rodehoffer in having a visit with Dr. Rodehoffer serving as the supervisor. Solely because of her actions the daughter has not seen her since the filing of my recommendation.

2. On March 24, 2004 Ms. Dombrowski caused the Circuit Court of Platte

County. Missouri to issue a P.F.A. Case # 04CV82861 against Hal Richardson. As best as I can read in the information the acts that are alleged occurred in Shawnee County, Kansas. The only reason for going to Missouri is to avoid the jurisdiction of this court and to cause the father to expend funds to defend himself against charges out of state. I note that this is a pattern that has been repeated from a similar attempt in Barton County, Kansas that resulted in some very stem action by Judge Anderson.

3. With thisP.F.A. and the restraining order that is included, Dr. Albott has advised me that he

does not see any reason to proceed with the attempted co-parenting counseling. He does not want to violate the restraining order, and I believe does not see any hope for change in the approach of Ms. Dombrowski.

4. I have spoken with both attorneys. I have also spoken with Mr. Richardson and Ms.

Dombrowski

5. When I spoke with Ms. Dombrowski I asked her to dismiss the action.in Missouri and bring

the same in Shawnee County Kansas. To be direct she was not willing to have a civil discussion and when reminded that she had a duty to keep this court and myself as Domestic Case Manager, advised of her current address suggested she had constitutional rights and

ended the conversation. .

At this time I do not see that anyone including her attorney, the psychologist or myself can influence Ms. Dombrowski. Her claims of pets being killed and other threats suggest that there is a significant possibility of danger for the daughter, the father and Ms. Dombrowski without significant intervention.

r

) Through the adoption of the Recommendation the court would be clearly indicating that a process must Z be followed to allow for the safety of all concerned. If Ms. Dombrowski is willing to go through that

']5focess·she may regain access to her daughter. If she is not then the recommendation will protect the daughter from the actions of her mother.

I want to also specifically state that since I have been appointed as the Domestic Case Manager I have always had good cooperation from Mr. Richardson. He may have had issues in the past, but has been

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cooperative with Dr. Albott and my office, as well as immediately taking his daughter to Dr. Rodehoffer when asked to do so.

I expect the Ms. Dombrowski will do something in the next few weeks to require some action on my part. The clear adoption of the prior recommendationwillsend a message that she needs to begin to

participate in the process.-- -

I also believe based on the prior orders of Judge Anderson it may be appropriate for an order to show cause be issued to require Ms. Dombrowski to come into your court and explain why she went to Missouri to bring actions that clearly are intended to have some affect on this court and it's jurisdiction.

I would be glad to discuss this matter with you.

Respectfully:

Lloyd C. Swartz

Thursday, April 01, 2004 America Online: Civsol

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Subj:

Date:

From:

To:

Re: Dombrowski/Richardson

4/1/2004 9:38:22 AM Central Standard Time ~ivsol

angelful)'@kansas.net

Ms. Dombrowski:

I will be forwarding a copy of your email and this response, to both attorneys along with the fax received at 12:17 pm March 31,2004, from you.

I believe they should be aware of your issues.

/

I would note that you are clearly(streSSed oudn this matter as you wrote that the hearing would be in Nebraska

when it is clearly in Missouri.

I also note that I indicated that I wanted you to bring your cause of action in Shawnee County Court as according to what you have shared the events occurred in Shawnee County Kansas and this court has a history of knowledge that would be helpful.

This court also has sale jurisdiction over the domestic issues including the parenting plan regarding the child.

I believe it can be argued that by not bringing any information to me or this court, or for that matter to the court ordered counselor before you went to the courts in Missouri, you have attempted to circumvent the courts prior orders creating Domestic Case Management.

I also note that my recommendation provided a path for resolution. I have always wanted you to be allowed the opportunity to restore your daughter's confidence in you and set forth a path for you to do so. I am sorry that you have .elected to go on another path.

Respectfully:

Lloyd C. Swartz

Thursday, April 01,2004 America Online: Civsol

Subj: OombrowskilRichardson

Date: 3/31/200412:35:16 PM Centra! Standard Time

From: angelfury@kansas-net

To: civsol@aoLcom

Lloyd,

This email is to confirm our telephone conversation of Wednesday morning. March 31, 2004 at approximately 9:30 A.M. For the record, I had you on speaker phone and our conversation was witnessed by Ralph Raposa, who I understand some weeks ago attempted to communicate with you regarding material information about this most recent court action and you refused to either speak with or accept any information from hirn, For the record. he is

a material witness to events cited in the most recent motion before the courts.

I wish the record to reflect the following salient points according to my recollection of this morning's phone conversation:

1) My lawyer and representative, Leonard Robinson, caned me to inform me that you wished to speak to me and that in his opinion I should call you. I

did so on his recommendation. DUring my conversation with Mr. Robinson, he stated that he gave you my "current address."

2) I called you, and you asked me my currrent "residence" address, which I gave to you and is the same address given to you by Leonard Robinson. Your response to me was, and I quote, "For some reason I don't believe you are telling me your actual address!' I consider that comment an indication of

your bias in this case. It clearly indicates you suspect my credibility, and

it underscores that in my opinion you have an a priori bias against me and my position. You also failed to inquire of Mr. Raposa the material information he has regarding this most recent action to restrict my visitation with my daughter. I consider that to be an indication of your

bias as well.

3) You demanded that I withdraw the ex parte order order of protection filed in the Circuit Court of Platte County, Missouri, Case Number 04CV82861, on March 23, 2004. You stated that if I don't dismiss the order within five

days you will file a contempt of court action with the Shawnee County Court

I consider your demand a threat to my personal safety, as the action was filed and signed by Judge Czamanske oftheCircuit Court, which protects me in Platte County, Missouri, where I currently "reside." That order was

signed upon the Judge's finding that there is a " ... .immedate and present danger of abuse, ... " to me by Hal Richardson. For the record. Hal Richardson directly assaulted me outside of Rikki's school as recently as January. 2004, and he threatened to" .. find and kilL." me as recently as

a couple of weeks ago outside of Dr. Albott's office after one of our mandated counseling sessions. Considerinq your statement regarding my credibility and your refusal to accept material witness evidence, I have no

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reason to trust your judgement, or to believe anything I say for that matter. Moreover, the order of protection is for MY benefit and personal safety. it has nothing to do with the instant case of removing my visitation with my daughter. As such, I don't believe you have any legal standing to make contempt of court threats.

4) The address I gave you is my "current" residence, which is a actually the address of Ralph Raposa, who has a 30 year history of assisting battered women in crisis. I am a guest in his home for my personal safety. I am also working with Battered Women resource and advocacy groups in the Kansas City area and have no intention of residing in Shawnee County. As such. I

believe the ex parte order filed in Platte County, MisSouri is both

necessary and in order. I am also under therapy with Dr. Henry Lee Forge, Ph.D, for post traumatic stress disorder based on some ten years of ongoing abuse and battery either directly or by proxy on behalf of Hal Richardson,

and I believe in part is being facilitated by such actions as your current demand to dismiss the ex parte order in Missouri. That evidence is well documented, and has continued for as long as~ have "returned" to Topeka and Shawnee County in the past. Neither you nor 'Dr. Albott has contacted Dr. Forge, although I have Signed releases and he has information also material

to this case and the.

Since neither you nor Dr. Albott have even accepted evidence material to

this instant case, nor have you investigated such evidence notwithstanding

it was brought to both of your attentions. I consider that my position is

and will be unfairly represented to the court by both you and Dr. AJbott. Moreover, I consider your demand to dismiss the ex parte protection order to be without merit and to do so would be to allow myself to be endangered both physically and mentally.

In anticipation of your threatened action before the Shawnee County Court to declare me "in contempf' I wish the record to reflect my recollection of our conversation, as weft as to inform the court of the material witness

testimony and evidence that you have refused to even accept. much less consider, that is favorable to my position.

I regret not having confidence in your judgement. I believe, however, any "reasonable and prudent" individual would look at this scenario and agree that there is at least neglect at issue here in your not looking at all the relevant evidence before threatening me with a contempt of court citation.

It is not my desire to be an adversary of the court system. or an adversary of any of the court's appointed "professionals." I do, however, believe J have a right to legally ensure my personal physical safety. A hearing on the matter is scheduled for April 6, 2004. at the Platte County Courthouse

in Platte City, Nebraska. The respondent is free to appear with counsel and any evidence he wishes the judge to consider. including request to void the ex parte order. I respectfully decline to accept your standing to demand I place myself in physical danger and continued psychological distress by voluntarily requesting the dismissal of the ex parte protective order.

Respectfully,

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Claudine Dombrowski

cc: Sandra L. Dowd, Clerk of the Circuit Court Platte County, Missouri

Find a broadband plan that fits. Great local deals on high-speed Internet access. https:/Jbroadband.msn.coml?pgmarket=en~us/g%nm00200360ave/directl011

---- End forwarded message --

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From: Claudine Dombrowski Fax: (775) 806-3730

Ph: (816) 587·1064

E-mail: angelfury@kansas.net

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Ralph Raposa

Room 225, Richard Bolling Federal Building 601 E. 12th Street

Kansu City, MitiOuri 64110

March 9. 2004

.------- '

The Honorable David E. Bruns Kangas District Court Shawnee County Courthouse Division No. Twelve

Topeka, Kansas 66603~3922

RE: Richardson v. Dombrowski: Case No. 960217

Dear Judge Brm,ts:

Respectfully, I wish to explain my "Btanding" in this case as a material witness yet 10 be beard, and also commend Hia Honor for the astute observations as articulated in the letter of March 2, 2004 to both counsel. For the (erst time in tbialong and protracted case, the court recognize. that the eight year history of legal motiom amountll10 a battleground for the personal agendas of one or rnore-parties under the prctens&-of parenting i.IUCI. Tho welfare of the child hu Ad)y. in my opinion. taken a back seat to 8 relentlesl and opportunistic barrage of legal motions by one party intended-to harm the other.

I pray His Honor will allow me- to--briefly explain why I take the precious time of the court at this moment with this letter. 1 believe the tkte of this nine year old child rests in the handa oftbis court. and the next few years are crucial to her developing a positive lIelf-image and contact with her biological mother is crucial to this positive development To ostraciu her mother in a continued marupulation of the Court only serves to perpetuate the very inappropriate UIC of the Court to intentionally harm one party by the other. as His Honor has 80 observed,

I am a material witness to several of the allegations being made in the motion at issue, and I wish to formally inform the court that neither the case manager, Lloyd Swartz, nor Dr.Witliam Albou1 upon whose recommendations this court shall make serious decisions in this matter. has contacted me to inquire of my direct and personal knowledge of the very facts material to the most recent motion to suspend Ms. Dombrowski' s unaupervised visitation. ' .

In fact. both Dr. Albott and the case manager have refused to even accept any material information from me. andthus--without weighing all the availabJe and credible evidence

supportive of the mother have decided to suspend her ripta to visitation. The original recommendation of Lloyd Swartz to impose supervised visitation ofRikki by her mother. upon which both Dr. AlOOtt and the Court now defer pending the recommendations of Dr. Albott, wu

1.

It would be my pleasure to provide the Court with my credentials to bring this matter to His Honor's attention, as well as provide material evidence and testimony to affirm my standing 81 a material witness. In short, I have degrees in Psychology and Public Administration, have been a FederaIRe81llator and adjudicator of fact in Federal cases for 27 yean, and have allong a hiltory helping battered and abused women, which I am convinced Ms. Dombrowaki has been for the last eight years and has just now recently Been that to continue the cycle ofvioJencc forced upon her serves no purpose but to provide a dangerous role model for the child, The answer to this dilemma is hardly to continue to portray MI, Dombrowski as "harmful" to her daughter and restrict her visitation, Claudine Dombrowski haa taken brave Itepl to positively improve her own life in order to be the best mother and role model she can be for RUcki, who at age nine now comes into the most important years of her life crucial to her becoming. healthy and productive adult woman.

I am not aiticizing the Court, Mr. Swartz, or Dr, Albott, nor any of the Coun', prior decisions. In fact, having studied the voluminous material this case involves, I am in fact heartened at His Honor's willingness to see truth and justice served in thl s case, including the stopping of the inappropriate use of the Court System to fight personal battles, especially one where ODe party has overwhelming resources at his disposal to continue this tragedy, and a trick rC<iOrd of doing exactly that.

Since it is I who has. helped Ms-. Dombrowski with a safe place to stay. resources to continue to fight this ongoing Machiavellian use of the courts to destroy her natural desire to be with her daughter as much as possibtc in B true mother/daughter relationship, and finally IfI'B.DJCCI for Ms. Dombrowaki to both enhance her Medicare benefits by moving into the service area of a Medicare HMO that provides far more than her current Medicare benefits available to ber in Topeka. and to start therapy- for what I am sure involve! over tea years of relentless abuse and anxiety disorder directly related to the same eight years of relentless assauhl of her penon. her pfYoho and her now timite(Uinances. I should think the inforrnat:iorr I 'have would be of at leallt

IIOme interest to those who hold the fate of this child in their hands, .. ,

It was I who introduced both mother and daughter to B.AC.A., who are a fully legitimate uu:t legally organized entity advocating for the rights of children, which Rildd haa a perlOnal interest in quite aside any battles between her parents. If the basia orany of these current motiona filed apinlt Ms. Dombrowski involve any of the things I have done quite legally to aSlist MI, Dombrowski break the chain of being battered, then it is I that the Court Bhould be focuacd on

. and sanction. not Ms, Dombrowski. Her only culpability in any of the issues at hand is that tho has entrusted her fate.to.me. to- help. her find peace in her (lwnlife,..and. a little help to survive financially under the constant assault on her income by the custodial parent. The reaction of those professionals to whom the- Court entrusts this young girl's fale" has been the recommendation of the complete suspension of vim tat ion with her mother. without even bearing much less weighing the avaifatite evidence that hu materia! and significant weight. It is with a heavy heart and the utmost reapsect of the Coun that I now make what ialikely I final effort to have this honorable court informed of material evidence that has yet to be heard.

3.

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made without any input of material evidence that I made aware to Mr. Swartz existed and was readily available. The result is a recommendation to the Court that 11 tantamount to imposing a decision quite harmful to the existing mother/daughter relationship pending the "investis:lltionn of the issues.

I'm sure His Honor understands the Btigma of supervised visitation, which I believe in this case such supervised visitation to be without merit and based on lesl than all of the readily available evidence. In short. Ms. Dombrowski now suffers what I believe has been the motivation of the very motion at issue by Mr. RichardlOn~ the ostracizing of her parental status, intentional damage to the mother/daughter relationship. and the continuance of harming Ms. DombrowlIki'.

physical and mental health by Hal Richardson, a convicted offender and admitted batterer with multiple convictioJls and tUTeets for violent crime, including assault on a police officer. The mind boggles at the notion that on balance he has custody at all, much lesl the absurdity of claiming Ms. Dombrowski should be forced into supervised and restricted visitation with no history of any criminal activity.

To force Ms. Dombrowski into supervised visitation. u Dr. Albott has determined without reviewing the available evidence and without even consulting Ms. Dombrowski~5 personal therapist is an issue I believe wonhy of the Court', knowledge. In the very least, one would expect Dr. AlOOtt to contact Ms. Dombrowski's personal therapist for his opinion as to her propensity to harm the child by allowing the pre-motion-statut quo parenting plan to oontinue pending the outcome of counseling that even His Honor observes is not elsential. or tlVen necessary. to the joint parenting of the child. It it also B monetary cost that Ms. Dombrowski, a disabled Medicare beneficiary with a fixed income, can hardly afford, much lei' the continued colt of counsel to fight this endless use of the courts to harm her in any way pOlSibJe.

Only this Court can take the step. it finds needed to end this opportunistic use of the court. to further one party's personal agenda of attacking the other, and to adjudicate jult which parent is reaUy in the best position to provide a healthy environment for the child. without the constant attempts to deprive reasonable visitation from the other parent.

I· have offered to provide material information to both Mr. Swartz and Dr. Albott. and my offer has been summarily rejected by both. In fact. both have stated to me personally they refuse to either accept any statements" by me Of make inquiry of me as to my direct knowledge of the inltant illucs. In short, they refuse to have any contact with me at all, which il their buainen. but I respcctfulJy submit is quite remiss in making informed recommendationa by them to this court. I am. the only one who has been privy to MI. Dombrowski's whereabouts, her striving for personal Bafety. and her desire to become a whole and healthy role model for her daulJhtcr.

2.

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His Honor can imagine my own feeling ofresponsibility, with the added frultration ofbcing rebuffed by both the case manager and Dr. AJOOn. in this horrible lou of visitation by MI. Dombrowski, and the subsequent reccmmendations made to alter the preooexiating parenting plan to one of supervised visitation. which in this case I believe His Honor, upon beins fully informed. will agree is radical and very unnecesslUY.

It is my understanding that Dr. Albatt has already informed Ms. Dombrowski that she i. being "uncooperative" by not instantly agreeing to supervised viaitatio~ and is also jeopardizing her position with the Coun by moving from Topeka to Kansas City. She has sussested and requested leIS restrictive temporary mealure •• such 88 supervised visitation by any of a number of faith based or other Court approved venues that are lell stigmatic than what Dr. Albott has essentially demanded. I, personally, am willing to submit my entire 28 year Federal reputation and willingness to polt whatever bond or other guarantees the Court sees fit. to allow her. modicum of reapectfuland meaningful visitation with her daughter.

I mean no disrespect to the supervised parenting program of the State. I limply observe that the very need for such supervised parenting is at iUue, and material fKt and information are being refused to even be heard by thOle upon whom the Court rclics to make informed, thouJhtfbl rocommendations and who refuse to accept material evidence or make inquiry of material information before imposing wfiat itselfi, potentially hannfuIto the well being of both mother and daughter, i.e., the restriction of visitation between mother and daughter in the way the State reserves for truly dangerous interaction between a child and an abusive parent ..

May it please the Court. I should like to briefly summarise and explain a couple of salient issues which Dr. Albett baa already-informed Ms. Dombrowski-ate- "problematic" for her position. and willlikeJy be factored as part of his myopic recommendation process to the Court. I belieVe the Court should know on whir-ham-Dr. Albott makes hin'ccommendation and what evidence he has DQtconsidered by refusing to even talk to me, even with the full permission of Ms. Dombrowski and a signecfreleaae to that effect. Moreover, lie has not even consulted MI. Dombrowski', own therapist. who ccnainly can provide valuable information B& to her state of

mind. .,".,

1) Moving out of Topeka - Ms. Dombrowski is II Medicare beneficiary with a limited and fixed income. By moving to Kansas City, at my suggestion, ahe is able to enroll into a Medicare HMO which will provide her with needed services above and beyond what is available to her in Topeka, which has no such Medicare HMOs. It ill a Federal requirement that all Medicare beneficiaries Jive in the contracted seMCC area of the Medicare HMO. Moreover, Ms.Dombrowski has been assaulted multiple timet while living in Topeka, with at least one such assault on the official court record that the perpetrator bas admitted under oath that she was paid by Hal Richardson to assault Ms. Dombrowski in her awn- borne in Topeka in order ro.4emonsttate that the daughter would be "endangered" by living or otherwise being in that residence.

4.

It is worthy of note that this most recent motion at issue to suspend Ms. Dombrowski's visitation came about only after Ms. Dombrowski left her home after allegedly being directly assaulted by Hal Richardson as recently 91anuary. 2004. Since that time. she baa been a guest in my horne for ber own protection and well being. She bas also started therapy under Dr. Henry Lee Forge, Ph.D, for the stren and trauma associated with Battered Woman Syndrome. None of this hat been even looked at by DL Albott or Mr. Swartz before making this potentially very harmful alteration in the pre-existing visitation schedule.

2) Reluctance to instantly accept State sponsored visitation .. MI. Dombrowski believeJ the stigma associ.ted with supervised visitation and the associated restrictions ofintoractiOD such supervised visitation demands is unwarranted and only lierves to further portray her as the "bad guy" before the Coun in this melodrama, which has been a constant theme of the myriad motions filed in this cue by Mr. Richardson. It is inherently unjust to alter the parenting plan by Dr. Albott. pending investigation anet-validatlon of the very issues surrounding this latest motion in a series of such filings over the last eight yean.

Dr. Albott has suggested to Ms. Dombrowski that the most serious charge, the overhearing of the mother making arrangements to hann the fi.ther. now did not happen II recorded by the cue . manager as having occurred in Kansas City, and to which I am a material witness in 1he rebuttal of that allegation.

It now seems that the alleged converJation (since my Jetter included in the rebuttal waif revealed) occurred "somewhere else." This twist of event. should give the Court as much pause as it does me, sinee the very motion at iSlUe clearly articulates what was alJegedly said whore. when ind by whom.

In addition, my own seven week observatiofil of the mother. and two unsupervised visit. of mother and daughter in my home- affirm my own view that this is a case of continued and. and unfortunately, court sanctioned abuse and intentional psychological and financial harm to the mother by the custodiat parent.

It is no coincidence in my view that this very motion to suspend visitation was filed only after Ms. Dombrowski physicaUy removed herself from Topeka. It is. also no coincidence in my view that Mr. Richar~howed no interest in custody until he determined that Stx:ial SCIClIrity

Administration benefIts would go along with the custody ofRik1ci based on Claudine .

Dombrowski's Social Security Disability. That move is consistent with the ongojJ18 attempt to deprive Ms. Dombrowski of both her daughter and any income that is to be used for the care and support of the child.

I have helped battered and. abused women for no remuneration for over 25 years. I have never seen a case like this one, and I observe His Honor recognizes this case is far from the norm. As the joint custodial pamlt. of a. ten-year-old IOn wbo is blessed with copious visitation bued on an amicable relationship with his mother. I am virtually torn to see this display of ongoing physical and pliyohological viotMce being perpetreted against Ms. Dombrowski for eight yean now. His Honor in the aforementioned letter to both Counsel has acknowledged the use of the Courts as a battleground for eight yeaB;

s.

· . '

I respectfully beg the Coun to consider either introducing a fresh set of professionals who are mutually agreed to by the parties, or to allow the just hearing of issues in this matter before the Cowt. It is on1y now that Ms. Dombrowski comes from behind the certain of denial ofbeill8 a battered woman, and seeks professional help to umlt her to move forward to be the strong and positive role model she believes she must be for Rikki. His HonorhimlelfremarkJ that the child haa done "remarkably well" under the circumstances. May I submit that in part such fortitude has been shared by the child from her mother. In my experience, many have succumbed to fir lell than what MI. Dombrowski has endured these past eight years and longe!'.

May it please the Court to consider that the child bas done 80 remarkably well by the equally remarkable personal sacrifice oCher mother to suffer abuse and documented assault and battery as the only way to continue any relationship at all with her daughter due to the myriad Court Orders and rulings over the past eight years that have only served one party'. agenda to manipulate the Court system for personal ressons that only in the end harm the child. I pray the Court do now what is crucial to the successful growth of a child who may love both parents, but has been thrust against her will into this battleground where there are no winnera, only victims, unless one considers unduly ostracizing a mother from her child as a "victory."

There is nothing "unfit" about Ms. Dombrowski~ in my opinion, and I am confident the objective evidence will show exactly that, Please allow that evideRGe to-be considered by this ",anby and Honorable Coun. preferably either by direct Hearing by His Honor or by relying on newly appointed professionals not'already demonstrably biased by their own past experience in IOIDO eight year. of legal wranglings, and who refuse to entertain new and material evidence. ~: a professional adjudicator oitiet and"evfdtmce in Federal cases for over 27 years. never have I refused to even hear or see possible evidence material to the instant cue IUch information •• offered. For an adjudicator offact to rebuke or not believe evidence and testimony is one thins. to refuse to even be ma~aware-of IftlCb probative-evidenee-before making serious recommendatioDl is quite remiss in my view.

1 stand ready to help the Court in any way to ace this tragic tale come to a fruitful conclusion; one that allows the child to not suffer the removal of Ms. Dombrowski's full parental righta to visitation and even custody, without a full and unbiased review of the available evidence in ~bi8' esse ..

Ralph G. Raposa

Member. Federal Domestic Violence Workgroup CMS. Department of Health and Human Services Richard Bolling Federal Building

601 East 12tb Street, Room 225

Kansu City, MO ..... 64110

6.

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