Robert E.

Duncan II 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 In the Matter of HAL RICHARDSON, Petitioner, and CLAUDINE

COURT OF SHAWNEE ) ) ) ) ) ) ) )

COUNTY,

KANSAS

SEALED

Case No. 96-0-217

DOMBROWSKI, Respondent.

D\\J -\)
& SHOW CAUSE by and through counsel Donald R. respondent Orders of

---------_.) MOTION COMES Hoffman, FOR ORDER TO APPEAR above named,

NOW the petitioner & Hoffman,

Hoffman

and moves the Court for an Order directing not be found in contempt of the Court's

to show cause September

why she should

27,2006

and April 6,2009. in contempt

Further, petitioner

prays the Court for an Order any images of the parties' attorney fees for the

finding respondent

and directing

her to remove

minor child from the Web and for an Order assessing preparation and prosecution of the instant motion.

petitioner's

In support thereof, the Court is shown: 1. On April 6, 2009, after hearing on petitioner's Show Cause, the Court found that respondent any and all likenesses be appearing that Motion for Order to Appear & had been ordered "to withdraw

of the minor child over which she had control that may

on the internet or other public places or public access and further was ordered not to present child at public rallies,

Respondent

demonstrations, in furtherance 2006.

newscast

or otherwise

publicize

the child's name or likeness 27,

of Respondent's

efforts in the instant case" on September

2. The Court further found that: 1) based on incidents and the stipulations order by intentionally website of the parties that Respondent placing photographs through

detailed

in the affidavit the Court's

had violated

of the minor child on Respondent's the Respondent's website and to

and to links accessible

websites that the Respondent

was either maintaining

or contributing

to; 2) that 3)

as of April 4, 2009, the photographs

of the minor child were still accessible; were not accessible. Accordingly,

that as of April 6, 2009, the photographs respondent

was found to be in Indirect Contempt. $1,500 and ordered her to serve 30 days in jail. by removing

3. The Court fined respondent

The Court allowed Respondent all photos, likenesses

to purge herself of the contempt

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 $600 for prosecuting 4. On September was maintaining parties' minor was also ordered to pay Petitioner's attorney fees of

the motion to show cause. counsel for petitioner became aware that respondent multiple images "Info" of the on with as

21,2009,

a Facebook child.

page that contained

A screen-print hereto

of respondent's 1.

page

Facebook.com references

is attached

as Exhibit

The page is littered with respondent,

to "AngeIFury",

a user name that is associated

2

well as links maintained 5.

to vanous

web-sites

that are supported,

sponsored

and/or

by respondent,

i.e., AngelFury.org

and KS-FCRC.com. Dombrowski's Photos and lists

The Photos tab takes the visitor to Claudine

six photo albums and one set of profile pictures!. profile pictures is identified as Claudine

See Exhibit 2. The set of Photos - Profile

Dombrowski's

Pictures and contains two images of the parties'

minor child.

(Exhibit 3) Of minor child:

the six photo albums, three of them contain images of the parties' Claudine Dombrowski's of the parties (Exhibit minor

Photos - more stuff (Exhibit 3a) contains two images child; Claudine Dombrowski's Photos - nutter one

3b) contains

two images of the parties

minor child; and Claudine one image of the parties 3b) also

Dombrowski's

Photos - stuff (Exhibit Dombrowski's

3c) contains

minor child. Claudine

Photos - nutter one (Exhibit

contains an image of the Court that was clearly taken from inside a courtroom in the Shawnee County District courthouse.

1 The screen print obtained of Claudine Dombrowski's Photos only lists five albums as reflected in Exhibit 2. The album Claudine Dombrowski's Photos - stuff does not appear on the screen-print. However, there are six albums located at:

http://wwwJacebook.com/al 0228

bum. php?aid=44577

&id=769640228#/photos.php?id=

76964

the uri for Claudine Dombrowski's Photos page. Further, the screen print does not reflect Claudine Dombrowski's Photos - Profile Pictures. However, the album is located at hup:/ /www.facebook.com/al 3&id=769640228 the uri for Claudine Dombrowski's Photos - Profile Pictures. bum.php ?aicJ=44577 &i cJ=7 69640228#/al bUIl1.php?aid=-

6.

Claudine Dombrowski's between respondent image of the parties' respondent's

Photos - stuff (Exhibit 3c) also includes a discussion page that appears under the the image as being that

and a visitor to her Facebook

minor child that clearly identifies

"little girl". it is absolutely clear that respondent has no intention of

7.

At this point, following Accordingly,

the Court's respondent

Orders of September

27, 2006 and April 25, 2008.

should be ordered to appear and show cause why she of Court; she should be orderedagain -to

should not be held in contempt remove any images of the parties' be ordered to pay petitioner's of the instant motion. WHEREFORE, petitioner

minor child from the Web and she should and prosecution

attorney fees for the preparation

prays the Court enter an Order directing

respondent

to

appear and show cause why she should not be held in contempt finding respondent in contempt and directing her to remove

of Court; for an Order

any images of the parties' attorney fees for the

minor child from the Web; for an Order assessing preparation and prosecution

petitioner's

of the instant motion and for such and other further relief as

the Court deems just and equitable under the circumstances.

J:)onald R. Hoffman HOFFMAN & HOFFM ' Attorneys for Hal Richards n

11

4

Donald R. Hoffman (Ks. 07332) Jason P. Hoffman (Ks. 17637) HOFFMAN & HOFFMAN CoreFirst Bank & Trust Building 100 E. 9th Street - 3rd Floor East Topeka, Kansas 66612 Ph. (785) 233-5887 Fax (785) 233-2173

IN THE DISTRICT COURT OF SHA WNEE COUNTY, KANSAS In the Matter of HAL RICHARDSON, Petitioner, and CLAUDINE DOMBROWSKI, Respondent.
-----------) ) ) ) ) ) ) ) )

Case No. 96-D-217

MOTION FOR ORDER TO APPEAR & SHOW CA USE

Exhibit 1

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Sex: Hometown: Political Religious VIews: Views: Female Topeka, Comfort Give light, KS the disturbed; disturb the comfortable. of itself. Get MMA

and the darkness

will disappear

Personal Information View Photos View Videos of Claudine of Claudine (4) Activities: (2) We must children, strength say to every member of our society: If you violate your they may not speak today. but as we gather our and stand beside them, they will, one day, speak your Get MMA ripped with this

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name. They will speak every name. (Marilyn Van Derbur)

Interests:
When I despair, I remember that all through history the way of

An error does not become truth by reason of multiplied propagation, nor does truth become error because nobody sees it."-Gandhi Music: TV Shows: Movies: Power Corrupts "Strength does an indomitable and Absolute Power Corrupts Absolutely. It comes from

truth and love has always won.
There have been tyrants and murderers and for a time they

Favorite Favorite Favorite

Class

of 1989

not come from physical capacity. will." - Mahatma Gandhi

seem invincible, but in the end,
they always fall--think it-always.Gandhi www.AngeIFury.org of

"You can chain me, you can torture me, you can even destroy this body, but you will never imprison my mind."Mahatma Gandhi (1869-1948) Do not go where the path may lead. no path; and leave a traH .. [emerson] Go instead where there is

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Current City: Topeka, KS

DOD
When I despair, I remember that all through truth and love has always won. There have they always fall-think of it-always. history the way of been tyrants and Gandhi

Look Up high school profiles from the Class old friends from of 1989 today. Uke

I
Classic Reunion

of

1989 now. Reconnect with
the Class

murderers and for a time they seem invindble, but in the end,
--Mahatma

Hometown: Topeka, KS About Me:

DOD
disturb

Rock - KC

Political Views: Comfort the disturbed; the comfortable. Religious Give light, Views:

When you invite thinking, you invite revolution.
We must 'be the change'we 'wish to see' in the world.'-

and the darkness

will

Contact Information
Email: Mobile Current Windows Windows Number: Address: Live: Uve: ang elfury@angelfur'l_arg 17858453417 po box 4974 Topeka, KS 66604 AngelFury Foghat/Shooting Star/Brian Howe fonmerly of Bad Company! 9/25 at Starlight Theatre in KCMO. Get tix for just S9 - password: -reunionUke

disappear of itself. Website:
http:/ http:j jwww.AngeIFury.org jwww.KS-FCRC.com http://INWW.Jus ticeForMothers.cor http://www.KansansForJudiciaIAe<

JusticeForMothers
http://\NWVV.AngeIFury.org http:! jwww.KS-FCRC.com http:,I J\NWVV.JusticeForMothers.com http://W'NIN.KansansForJudiciaIAcco

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Donald R. Hoffman (Ks. 07332) Jason P. Hoffman (Ks. 17637) HOFFMAN & HOFFMAN CoreFirst Bank & Trust Building 100 E. 9th Street - 3rd Roar East Topeka, Kansas 66612 Ph. (785) 233-5887 Fax (785) 233.2173

IN THE DISTRICT COURT OF SHA WNEE COUNTY, KANSAS In the Matter of HAL RICHARDSON, Petitioner,
) ) ) ) ) )

and
CLAUDINE DOMBROWSKI, Respondent.
-----------)

Case No. 96-D-217

) )

MOTION FOR ORDER TO APPEAR & SHOW CAUSE

Exhibit 2

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Donald R. Hoffman (Ks. 07332) Jason P. Hoffman (Ks. 17637) HOFFMAN & HOFFMAN CoreFirst Bank & Trust Building 100 E. 9th Street - 3'd Roar East Topeka, Kansas 66612 Ph. (785) 233-5887 Fax (785) 233-2173

IN THE DISTRICT COURT OF SHAWNEE COUNTY, KANSAS
In the Matter of ) ) ) ) ) )

HAL RICHARDSON,
Petitioner, and

Case No. 96-0-217

CLAUDINE DOMBROWSKI,
Respondent. -----------)

)
)

MOTION FOR ORDER TO APPEAR & SHOW CAUSE

Exhibit 3

Claudine Dombrowski's

Photos - Profile Pictures q=claudin e+dom brow ski &ini t=qui ck#1 al bum.php ?ai d

http://www.facebook.com/search/? =-3&id=769640228 links to: http://www.facebook.com/search/? 1739379&id=769640228

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http://www.facebook.com/AngeIFury?v=photos&ref=search#/photo.php d=769640228

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Donald R. Hoffman (Ks. 07332) Jason P. Hoffman (Ks. 17637) HOFFMAN & HOFFMAN CoreFirst Bank & Trust Building 100 E. 9th Street - 3rd Floor East Topeka, Kansas 66612 Ph. (785) 233-5887 Fax (785) 233-2173

IN THE DISTRICT COURT OF SHAWNEE COUNTY, KANSAS In the Matter of HAL RICHARDSON, Petitioner, and CLAUDINE DOMBROWSKI, Respondent.
-----------) ) ) ) ) ) )

Case No. 96-D-217

) )

MOTION FOR ORDER TO APPEAR & SHOW CAUSE

Exhibit 3a

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Donald R. Hoffman (Ks. 07332) Jason P. Hoffman (Ks. 17637) HOFFMAN & HOFFMAN CoreFirst Bank & Trust Building 100 E. 9th Street - 3rd Roor East Topeka, Kansas 66612 Ph. (785) 233-5887 Fax (785) 233-2173

IN THE DISTRICT

COURT OF SHAWNEE ) ) ) ) ) ) ) )

COUNTY,

KANSAS

In the Matter of
HAL RICHARDSON, Petitioner,

and
CLA UDINE DOMBROWSKI, Respondent. -----------). MOTION

Case No. 96-D-217

FOR ORDER TO APPEAR

& SHOW CAUSE

Exhibit 3b

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9/21/09 4:20 PM

Claudine Dombrowski's

Photos - nutter one q=cl audine+dom brow ski&ini t=qui ck#1 al bum. php? ai d

http://www.facebook.com/search!? =72372&id=769640228 links to: http://www.facebook.com/search!?q=cl 1691848&id=769640228

audine+dom brow ski&ini t=q ui ck#/photo. php ?pid=

http://www.facebook.com/search!? 1691847 &id=769640228

q=cl audine+dombrow

ski &i ni t=q ui ck# Iphoto.php ?pid=

hUp: II www.facebook.com/search!? 1691852&id=769640228

q=claudi ne+dom brow ski&ini t=qui ck# Iphoto. php ?pi d=

Facebook I Claudine Dombrowski's Photos - more stuff

http://www.facebook.comlAngeIFury?v=photos

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10fl

9/21/09 4:57 PM

that

Respondent

was newscast

ordered

not

to present publicize

child

at public

rallies,

demonstrations, in furtherance 2006.

or otherwise

the child's name or likeness case" on September 27,

of Respondent's

efforts in the instant

3. The Court further found that: 1) based on incidents and the stipulations order by intentionally website of the parties that Respondent placing photographs through

detailed

in the affidavit the Court's

had violated

of the minor child on Respondent's the Respondent's website and to

and to links accessible

websites that the Respondent

was either maintaining

or contributing

to; 2) that 3)

as of April 4, 2009, the photographs

of the minor child were still accessible; were not accessible. Accordingly,

that as of April 6, 2009, the photographs respondent 4.

was found to be in Indirect Contempt. $1,500 and ordered her to serve 30 days in jail. by removing

The Court fined respondent

The Court allowed Respondent all photos, likenesses

to purge herself of the contempt

and name of minor child from the internet or any other at

public place or public access on which she has control by April 15,2009, 3:00 p.m. Respondent $600 for prosecuting 5. On September was maintaining parties' minor was also ordered to pay Petitioner's attorney

fees of

the motion to show cause. became aware that respondent multiple images "Info" of the on

21, 2009, counsel for petitioner a Facebook child.

page that contained

A screen-print

of respondent's

page

Facebook.com

is attached to the Motion for Order to Appear and Show Cause to "AngeIFury", a user name

as Exhibit 1. The page is littered with references

2

that is associated supported,

with respondent,

as well as links to various web-sites that are by respondent, i.e., AngelFury.org

sponsored

and/or maintained

and KS-FCRC.com. 6. The "Photos" Dombrowski's picturesl. of profile Pictures tab on respondent's Photos Facebook page takes the visitor to Claudine albums and one set of profile The set

and lists six photo

(Exhibit 2, Motion for Order to Appear and Show Cause). pictures is identified as Claudine Dombrowski's minor

Photos - Profile child. (Exhibit 3

and contains

two images

of the parties'

Motion for Order to Appear and Show Cause) Of the six photo albums, three of them contain images of the parties' minor child: Claudine Dombrowski's

Photos - more stuff (Exhibit 3a Motion for Order to Appear and Show Cause) contains two images of the parties minor child; Claudine Dombrowski's

Photos - nutter one (Exhibit 3b Motion for Order to Appear and Show Cause) contains Photos two images of the parties minor child; and Claudine - stuff (Exhibit 3c Motion for Order to Appear Dombrowski's

and Show Cause)

The screen print obtained of Claudine Dombrowski's Photos only lists five albums as reflected in Exhibit 2. The album Claudine Dombrowski's Photos - stuff does not appear on the screen-print. However, there are six albums located at:
1

hup:!/www.facebook.com/a

]bum. php?ai d=44577 &i d= 769640228#1 photos.php?i d= 76964

0228
the urI for Claudine Dombrowski's Photos page. Further, the screen print does not reflect Claudine Dombrowski's Photos - Profile Pictures. However, the album is located at http://www.facebook.com/al 3&id=769640228 the urI for Claudine Dombrowski's Photos - Profile Pictures. bum.php?aid=44577 &id= 769640228#1 al bum.php?aicl=-

contains one image of the parties minor child. Claudine Dombrowski's - nutter one (Exhibit contains courtroom 7. Claudine an image 3b Motion for Order to Appear of the Court that was apparently

Photos

and Show Cause) also taken from inside a

in the Shawnee County Courthouse. Dombrowski's Photos - stuff (Exhibit 3c Motion for Order to and a

Appear and Show Cause) also includes a discussion visitor to her Facebook page that appears

between respondent

under the image of the parties' "little

minor child that clearly identifies

the image as being that respondent's

girl ".
Further affiant sayeth naugth,

Subscribed

and sworn to before me this ~~ay

of September,

2009.

My commi

4

~ i L.E U

E3( C U: flri,

I' .:'

Donald R. Hoffman (Ks. 07332) Jason P. Hoffman (Ks. 17637) HOFFMAN & HOFFMAN CoreFirst Bank & Trust Building 100 E. 9th Street - 3rd Floor East Topeka, Kansas 66612 Ph. (785) 233-5887 Fax (785) 233-2173

;l\R[J

,
~

DIS T R : eTC 0 UR T JUDICiAL oiST. TOPEKA, KS.

Z009 OCT I b P 4: 20

IN THE DISTRICT In the Matter of HAL RICHARDSON, Petitioner, and CLAUDINE

COURT OF SHAWNEE ) ) ) ) ) ) ) )

COUNTY,

KANSAS

Case No. 96-D-217

DOMBROWSKI, Respondent.

-----------) ORDER TO APPEAR AND SHOW CAUSE NOW on this

-1-

day of

ad, 61/' ,
, 2009.

2009 the above captioned

matter

comes on for hearing on petitioner's herein on the _'_ day of

Motion for Order to Appear and Show Cause filed Petitioner appears by and through

counsel Donald R. Hoffman,

Hoffman & Hoffman.

There are no other appearances. for Order to Appear and Show

The Court, upon reviewing Cause and the Affidavit respondent

the file, the Motion

filed in support thereof, finds that it has been made to appear that Orders with respect to images of the parties'

violated the terms of the Court's

minor child on the internet. IT IS THEREFORE hereby commanded before ORDERED, ADJUDGED and DECREED that respondent is

to appear on the 13th day of November, B. Debenham, District Judge,

2009 at 11 :00 o'clock 13, Shawnee

a.m.

the Han. David

Division

County

Courthouse,

Shawnee County, Kansas to answer on the instant Order to Show Cause

IT IS SO ORDERED.

Prepared by:

onald R. Hoffman HOFFMAN & HOFFMAN Attorneys for Petitioner

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