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2009 October SECRET Motion of Contempt Against Mother Claudine Dom Brow Ski

2009 October SECRET Motion of Contempt Against Mother Claudine Dom Brow Ski

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Published by: SinDenied on Dec 11, 2009
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07/11/2013

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Robert E. Duncan
II
Attorney at Law212SW 8
th
Avenue, Suite 202Topeka, Kansas 66603
785-233-2265 FAU{:233-5659
To: Claudine DombrowskiFrom: R.E. "Tuck" DuncanDate: October 27, 2009Re: Your case
.
.&"/ 
Please find enclosed the Motion and an Order recently filed and issued inthis case for you to show cause (again) as to why you should not be held incontempt 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 therequest of Dad's Attorney.This Order copy was given to me today (Wednesday) by Hoffman for meto present to you. The question is, does this constitute disobedience of theCourt's Order and whether you actually posted these materials in violation of thatorder as alleged. They have set this for hearing at the same time as the hearingon the custody issues. The Judge has not ruled on the Motion, just set it forhearing.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
&
HOFFMANCoreFirst Bank & Trust Building100 E. 9
th
Street -
3'd
Floor EastTopeka, Kansas 66612Ph. (785) 233-5887Fax (785) 233-2173
IN THE DISTRICT COURT OF SHAWNEE COUNTY, KANSASandIn the Matter of HAL RICHARDSON,Petitioner,)))
))
)CLAUDINE DOMBROWSKI, )Respondent. )
---------_.)
SEALED
Case No. 96-0-217
D \\J - \)
MOTION FOR ORDER TO APPEAR
&
SHOW CAUSECOMES NOW the petitioner above named, by and through counsel Donald R.Hoffman, Hoffman
&
Hoffman, and moves the Court for an Order directing respondentto show cause why she should not be found in contempt of the Court's Orders oSeptember 27,2006 and April 6,2009. Further, petitioner prays the Court for an Orderfinding 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 thepreparation 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 withdrawany and all likenesses of the minor child over which she had control that maybe appearing on the internet or other public places or public access and furtherthat Respondent was ordered not to present child at public rallies,
 
demonstrations, newscast or otherwise publicize the child's name or likenessin 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 affidavitand the stipulations of the parties that Respondent had violated the Court'sorder by intentionally placing photographs of the minor child on Respondent'swebsite and to links accessible through the Respondent's website and towebsites that the Respondent was either maintaining or contributing to; 2) thatas 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 removingall photos, likenesses and name of minor child from the internet or any otherpublic place or public access on which she has control by April 15, 2009, at3:00 p.m. Respondent was also ordered to pay Petitioner's attorney fees o$600 for prosecuting the motion to show cause.4. On September 21,2009, counsel for petitioner became aware that respondentwas maintaining a Facebook page that contained multiple images of theparties' minor child. A screen-print of respondent's "Info" page onFacebook.com is attached hereto as Exhibit 1. The page is littered withreferences to "AngeIFury", a user name that is associated with respondent, as2

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