LEONARD M, ROBINSON, #8313 a Ds Attorney at Law 201 NW Hwy. 24, Ste. 140 P.O. Box 8138 Topeka, Kansas 66608-0138 (785) 233-7001 IN THE DISTRICT COURT OF SHAWNEE COUNTY, KANSAS DIVISION THO In the Matter of the Marriage of HAL RICHARDSON, and Case No. 96-D-217 CLAUDINE DOMBROWSKI, Respondent. ) ) Petitioner, , ) ) ) MOTION COMES NOW Claudine Dombrowski, pursuant to the Court's Order Suspending Parenting Time of December 29, 2000, wherein the Court on its own motion suspended all parenting time for Claudine Dombrowski with the minor child Rikki Dombrowski until further order of the Court, and in the same order filed December 29, 2000, ordered "Ms. Dombrowski shall be required to file a motion with this Court to determine what, if any, parenting time should be scheduled," and moves the Court to reinstate parenting time for her and the minor child. It is respectfully submitted that it is in the best interests of the child to forthwith allow visitation of the minor child, Rikki Dombrowski, with her mother, Claudine Dombrowski, and to insure that the Court, the case manager, opposing counsel, and the petitioner are given some assurance and protection, it isrequested at this time that the visitation commence forthwith with the Safe Visit program. In support of this motion a copy of the case manager's correspondence to attorneys for the respondent and petitioner is attached hereto and marked Exhibit A. There are other issues dealing with child custody and parenting time that should be dealt with in the future; however, at this time and pursuant to the Court's order filed herein December 29, 2000, respondent respectfully indicates to the Court that it is vitally important and in the best interests of the minor child, Rikki Dombrowski, that the visitation commence forthwith under the Safe Visit program, and respondent shal comply totally with the Court's orders in regard to Safe Visit if the Court would on its own motion lift the suspension of its order and order Safe Visit parenting time pursuant to the standard provisions, and also pay the costs of the Safe Visit as pointed out as appropriate in Mr. Harry Moore's letter of 16 January 2001. The respondent Claudine Dombrowski gives assurance to Court, counsel and petitioner that she will not make any attempt to take the child upon her visits under the Safe Visit program if the Court so allows. Respectfully submitted: : ON Attorney for RespondentCERTIFICATE OF SERVICE I, Leonard M. Robinson, hereby certify that I served above and foregoing document on this 18th day of January, 2 to the following and in the following manner: by hand-delivering: ORIGINAL 1 Office of Mrs. Joyce D. Reeves, Clerk Shawnee County District Court Shawnee County Courthouse, Room 209 200 Southeast Seventh Street Topeka, Kansas 66603-3969 COPY TO Office of Mr. Harry Moore Court Services Shawnee County Courthouse 200 SE 7 Street Topeka, KS 66603 CHAMBER COPY Office of The Honorable Richard D. Anderson District Court Judge - Division 2 Shawnee County Courthouse 200 SE 7" Street Topeka, KS 66603 and by faxing: copy To Mr. Donald Hoffman 112 sw 7 street, Garden Suite Topeka, KS 66603 Attorney for Petitioner FAX 233-2173 Ms. Claudine Dombroski FAX 775 402-5209 LEONARD ¥. DIVORCEIDOMBROWSKiclaudineMotResVistKANSAS DISTRICT COURT Shawace County Courthouse 200 SE Tt, Suse 104 Assistant Directors eee ee ee Cathy Leonhar, Dvector (785) 233-8200, Ex. 4004 Harry Moote, Special Series Fax (185) 291 29380910 sarah D Mayn Rovale Series 16 January 2001 R, eo, "9 My 'Y, Donald Hoffman Leonard Robinson Wy _ 0 112 SW 7th St 201 NW HiWay 24 Uy, Garden Suite Topeka, Ks 66608 y Topeka, Ks 66603 Dear Messrs Hoffman and Robinson: ‘This past Friday, I received a telephone message from Mr. Robinson inquiring as to what my position concerning visitation between Ms. Dombrowski and her daughter, Rikki, would be. At this point, I would suggest to you the only viable option would be the Safe Visit program. This would require the parents to complete an intake process with that agency. I would also suggest that the costs for Safe Visit be borne by Ms. Dombrowski since it has been by her actions that this case has reached this point. This would be my recommendation to the Court under the Case Management statute, although my role as a case manager has been skewered out of all reality for the past several months due to the rather unusual nature of this case. Should either of you have any questions, please do not hesitate to contact me at 23-8200, ext 4300, Respectfully yours, Swill pee Harry Mopre’ Assistant Director