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Claudine Dombrowski

PO Box 4974, Topeka, Kansas 66604
(785) 845-3417
Respondent, Pro Se

IN THE DISTRICT COURT OF SHAWNEE COUNTY, KANSAS
DIVISION THIRTEEN
In the Matter of the Marriage of;
HAL RICHARDSON
and;
Case No. 96-D-217
CLAUDINE DOMBROWSKI
___________________________
Pursuant to K.S.A. CHAPTER 60
MOTION FOR ORDERS OF JUSTICE
COMES NOW, Claudine Dombrowski, respondent, with out counsel, and respectfully moves

this Court for :
a)A written Order or journal entry restoring parenting time under Federal Law, Kansas
Statues Annotates and Shawnee County Guidelines, to ensure meaningful contact of mother
and child without further delay and with any reunification and or transition needed for mother
and child to allow healing to begin.
b) Mothers Social Security Disability Benefits be returned to her and
c) Recusal of the Guardian Ad Litem (GAL) from this case effective immediately.

SUPPORTING INFORMATION & FACTS OF THE CASE:

1. This case leads the suit titled Dombrowski v US, regarding human rights
violations to battered women and their children at the Inter-American
Commission on Human Rights (IACHR). IACHR is one of two bodies in the
inter-American system for the promotion and protection of human rights.

2. The respondent has been enrolled in the state\u2019s Address Confidentiality-Safe at
Home Program since April 2007 as a result of the violence by petitioner.

3. Mother and child have been denied any meaningful contact for the past 9 years and the child has been alienated by the petitioner with irreparable damage over the past 5 years.

4. The Respondent has never been accused nor alleged to be a harm to minor child,
contrary to that of the well-documented violence of Petitioner.
5. Mother is on SSADI (Social Security Administration's Disability Insurance)
because of the violence inflicted by the petitioner
6. The Petitioner receives Respondent\u2019s disability benefits for her dependent minor
child. These funds include funds for the mother\u2019s housing.
7. Petitioner also received back pay for 2003, as Petitioner was able to show that

Respondent has no contact with minor child.
8. Respondent will be left homeless again without these funds.
9. A formal complaint and investigation into the fraudulent misuse of disability

funds has been initiated for over-payment pending a court order specifically
returning the mother\u2019s benefits to the mother.

10. The purported reason to order supervised visitation was to keep secret from minor
child the history of violence. This is now moot. as the child knows the truth via
the Internet, and as such, minor child requested that supervised visitation stop as
of February 2008. She further requested through the GAL that she be allowed to
have a normal relationship with her mother, free of the constraints of supervision
monitors of any kind.

11. Odyssey was to implement and reintegrate minor child and parent into guideline
parenting time. (Hearing held April 25, 2008- yet to be journalized)
12. Only 5 visits have been permitted to occur since February 2008, at no fault of the
mother\u2019s.

13. The Respondent\u2019s visitation was set for 2 hours on Saturdays 2 months ago. At that time it was still arranged as supervised visits requiring the Respondent to pay to see her child via Odyssey.

14.On October 4, 2008 Respondent\u2019s parenting time was cut back again to 2 hours
every other week when it had been 2 hours every week, supervised only, stating
\u201c\u2026it is too much parenting time\u2019 and \u201c\u2026it interferes with Petitioner\u2019s schedule
and control\u201d as \u201c\u2026 our visits have always been supervised and will remain so.
It has always been this way and will stay supervised.\u201d

15. That absolutely no visits are occurring under the control of the Batterer since the December 16th, 2008 hearing again denying Justice, to which The Court was fully aware would happen.

16.The last assessment of September 2006 by Mary Ann Dugan indicated parental
alienation on the part of the Petitioner. (ATTACHED)

17. That in concert with GAL, Petitioner\u2019s mental health professionals and
Petitioner\u2019s counsel and Shawnee county court judges have ignored all motions
filed by respondent this past 5 years including but not limited to \u2018due process\u2019
equal protection under the law\u2019 access to justice and have failed to journalize the
last two hearings in this case specifically the last hearing April 2008 \u201cMOTION
FOR DEMAND RULING\u2019

WHEREFORE, The Respondent moves this court for an immediate order:
a) Re-instating parenting time in accordance with Federal, State and Shawnee
county guidelines,

b) Mother\u2019s SSA Disability benefits be restored to her in a Journal entry. c) Recusal the Guardian Ad Litem from this case effective immediately. And any or other relief that the court deems to be JUST, fair and humane.

Claudine Dombrowski date 3-13--2009

Mother/Respondent
Po box 4974, Topeka Ks ACP, SaH
C: 785.845.3417

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