2009 October Motion to Show Cause Contempt against mother

Robert E. DuncanII

Attorney at Law

212 SW 8th Avenue, Suite 202

Topeka, Kansas 66603

785-233-2265 FAU{:233-5659

To:

Claudine Dombrowski

From: R.E. "Tuck" Duncan

Date: October 27, 2009

Re: Your case

Please find enclosed the Motion and an Order recently filed and issued in this case for you to show cause (again) as to why you should not be held in contempt for posting the items set out on the exhibits.

The material in the Motion was not to be placed in the Court's file per the

request of Dad's Attorney.

This Order copy was given to me today (Wednesday) by Hoffman for me to present to you. The question is, does this constitute disobedience of the Court's Order and whether you actually posted these materials in violation of that order as alleged. They have set this for hearing at the same time as the hearing on the custody issues. The Judge has not ruled on the Motion, just set it for hearing.

Please advise me as to your position regarding their allegations.

If you have any questions please to call.

Thank you for your attention to and consideration of this matter.

\~

Donald R. Hoffman (Ks.07332)

Jason P. Hoffman (Ks.17637)

HOFFMAN& HOFFMAN

CoreFirst Bank & Trust Building

100E. 9th Street - 3rdFloor East

Topeka, Kansas66612

Ph. (785) 233.5887

Fax (785) 233-2173.

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IN THE DISTRICT COURT- OF SHAWNEE COUNTY, KANSAS

and

In the Matter of

HAL RICHARDSON,

Petitioner,

CLAUDINE DOMBROWSKI,

Respondent.

Case No. 96-D-217

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SEALED

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STATE OF KANSAS

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COUNTY OF SHAWNEE

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AFFIDAVIT IN SUPPORT OF

MOTION FOR ORDER TO APPEAR& SHOW CAUSE

(Pursuant to K.S.A. 20-1204a)

I, Jason P. Hoffman, after first being duly sworn according to law, do hereby say

the following:

1. My name is Jason P. Hoffman.

I am one of the attorneys for the petitioner

herein. I am providing this Affidavit in support of petitioner's

Motion for Order to Appear and Show Cause filed herein. I have personal knowledge of all the facts stated in this Affidavit.

2. On April 6,2009, after hearing on petitioner's Motion for Order to Appear& Show Cause, the Court found that respondent had been ordered "to withdraw any and all likenesses of the minor child over which she had control that may be appearing on the internet or other public places or public access and further

that Respondent

was ordered not to present

child at public rallies,

demonstrations,

newscast or otherwise publicize the child's name or likeness

in furtherance of Respondent's efforts in the instant case" on September 27,

2006.

3. The Court further found that: 1) based on incidents detailed in the affidavit and the stipulations of the parties that Respondent had violated the Court's order by intentionally placing photographs of the minor child on Respondent's website and to links accessible through the Respondent's

website and to websites that the Respondent was either maintaining or contributing to; 2) that as of April 4, 2009, the photographs of the minor child were still accessible; 3) that as of April 6, 2009, the photographs were not accessible.

Accordingly,

respondent was found to be in Indirect Contempt.

4. The Court fined respondent $1,500 and ordered her to serve 30 days in jail. The Court allowed Respondent to purge herself of the contempt by removing all photos, likenesses and name of minor child from the internet or any other public place or public access on which she has control by April 15, 2009, at 3:00 p.m. Respondent was also ordered to pay Petitioner's attorney fees of $600 for prosecuting the motion to show cause.