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’s 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’s disability benefits for her dependent minor
child. These funds include funds for the mother’s 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’s 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’s.

13. The Respondent’s 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’s parenting time was cut back again to 2 hours
every other week when it had been 2 hours every week, supervised only, stating
“…it is too much parenting time’ and “…it interferes with Petitioner’s schedule
and control” as “… our visits have always been supervised and will remain so.
It has always been this way and will stay supervised.”

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’s mental health professionals and
Petitioner’s counsel and Shawnee county court judges have ignored all motions
filed by respondent this past 5 years including but not limited to ‘due process’
equal protection under the law’ access to justice and have failed to journalize the
last two hearings in this case specifically the last hearing April 2008 “MOTION
FOR DEMAND RULING’

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’s 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
 CERTIFICATE OF SERVICE

MOTION FOR ORDERS OF JUSTICE

I the undersigned hereby certify that on the 13TH day of March, 2009, served a true and
correct copy of the above and foregoing pleading;, with the Clerk of the District Court,
Judge Debenham, and Domestic Filings, 200 SE 7th Street, Topeka, Kansas 66603, by
facsimile in accordance with Supreme Court Rule 119(b)(3) and sent a copy of the
forgoing document, by U.S. Mail, postage prepaid to:

Don Hoffman
100 E. 9th Street
Topeka, KS 66612

Jill Dykes
1243 SW Topeka Blvd.
Topeka, KS 66612

Claudine Dombrowski date 3-13-2009

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

VERIFIED AFFIDAVIT FOLLOWS

VERIFIED AFFIDAVIT IN SUPPORT OF

MOTION FOR JUSTICE

CASE NO. 96D000217

IN THE MATTER OF THE MARRIAGE OF;

HALLLECK RICHARDSON

AND;

CLAUDINE DOMBROWSKI

AFFIDAVIT

THE STATE OF KANSAS

COUNTY OF SHAWNEE

BEFORE ME, the undersigned authority, on this day personally appeared; Claudine
Dombrowski, who swore or affirmed to tell truth, and stated as follows:

My name is Claudine Dombrowski. I am of sound mind and capable of making this

sworn statement. I have personal knowledge of the facts written in this statement. I
understand that if I lie in this statement I may be held criminally responsible. This
statement is true.

I, Claudine Dombrowski under penalty of perjury do herby state as follows:

That the above Motion “MOTION FOR JUSTICE” was written by myself as pro se,
and that I verify that the contents are true to the best of my knowledge.

_______________________________________ (Date)

Claudine Dombrowski
State of KANSAS.

County of SHAWNEE___.

SWORN to and SUBSCRIBED before me, the undersigned authority, on

the _______ day of __March___, _2009______ year,

by ________________________________________________.

[PRINT the first and last names of the person who is signing this affidavit.]

________________________________________

Notary Public, State of Kansas [Notary’s signature.]

[Notary’s seal must be included.]