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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
100 E. 9th Street -3'd Floor East
Topeka, Kansas 66612
Ph. (785) 233-5887
Fax (785) 233-2173
IN THE DISTRICT COURT OF SHAWNEE COUNTY, KANSAS
and
In the Matter of
HAL RICHARDSON,
Petitioner,
))))))
CLAUDINE DOMBROWSKI,
)
Respondent.
)
---------_.)
SEALED
Case No. 96-0-217
D\\J -\)
MOTION FOR ORDER TO APPEAR& SHOW CAUSE

COMES NOW the petitioner above named, by and through counsel Donald R. Hoffman, Hoffman& Hoffman, and moves the Court for an Order directing respondent to show cause why she should not be found in contempt of the Court's Orders of September 27,2006 and April 6,2009.

Further, petitioner prays the Court for an Order finding respondent in contempt and directing her to remove any images of the parties' minor child from the Web and for an Order assessing petitioner's

attorney fees for the
preparation and prosecution of the instant motion.
In support thereof, the Court is shown:

1. 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.

2. 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.

3. 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.

4. On September 21,2009, counsel for petitioner became aware that respondent
was maintaining
a Facebook page that contained multiple images of the
parties'
minor child.
A screen-print
of respondent's
"Info" page on
Facebook.com
is attached hereto as Exhibit 1. The page is littered with
references to "AngeIFury", a user name that is associated with respondent, as
2

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