IN THE DISTRICT COURT THIRD JUDICIAL DISTICT, SHAWNEE COUNTY, KANSAS DIVISION FOUR

IN THE MATTER OF HALLECK G. RICHARDSON, AND; CLAUDINE DOMBROWSKI ___________________________ Pursuant to K.S.A. CHAPTER 60

Case No. 96-D-217

MOTION FOR IMMEDIATE ORDER RESTORING AND REINSTATING WITHOUT RESTRICTION CHILD AND PARENT ACCESS. A VIOLATION OF THE CIVIL AND CONSTITUIONAL RIGHTS OF BOTH CHILD AND PARENT

February 4, 2008 COMES NOW, Claudine Dombrowski, Mother/Respondent, without counsel, and demands that this court enter an Order IMMEDIATELY restoring the rights of child and parent to equal access, as has been denied under the K.S.A, and CONSTITION, and that a restoration of those FUNDAMENTAL RIGHTS be RESTORED with out any further delay. IN SUPPORT; 1. It has been four years and one day since the above February 3, 2004 ‘EX-PARTE’ Order was forced upon mother and her child denying both of their civil rights. 2. To date of this filing, February 4, 2008, four years later, there still has yet to be an evidentiary hearing, to deny or restrict those rights, although has been requested since the admission of ‘ex-parte’ order February 3, 2004.

3. Mother has complied with every instruction of this and past courts, requests. 4. There exists NO FINDING of FACT anywhere, not even in the courts own ‘social’ file to deny or restrict nor to continue to deny or restrict the rights of the minor child’s access to her mother. 5. It is a denial of BOTH child and mothers rights under the constitution and bill of rights and violates the fundamental rights and liberties of both child and parent.

WHEREFORE, Mother/Respondent requests that an ORDER be entered IMMEDIATELY NUNC PRO TUNC [as it was before] the February 3, 2003 ‘ex-parte’ order that unethically and unconstitutionally imposed upon mother and daughter, and as a matter justice, human and civil liberties, a restoration of those rights without restriction must be acted upon without any further delays.

Submitted,

CERTIFICATE OF SERVICE FOLLOWS

CERTIFICATE OF SERVICE

MOTION FOR IMMEDIATE ORDER RESTORING AND REINSTATING WITHOUT RESTRICTION CHILD AND PARENT EQUAL ACCESS. A VIOLATION OF THE CIVIL AND CONSTITUIONAL RIGHTS OF BOTH CHILD AND PARENT I the undersigned hereby certify that on the 4th day of February, 2008, served a true and correct copy of the above and foregoing pleading;, with the Clerk of the District Court, Judge Johnson, 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

Cc: Roger Scurlock- BSRB; Governor [grants], Dorthy Halley [executor of grants] Attorney Generals Office, Jacquie Spradling [KS Domestic Violence task Force], Battered Women’s Justice Project, Kansas Coalition Against Sexual Assault Domestic Violence; Shawnee County District Attorneys Office’s, Battered Women’s Task Force, KOVA, Sen. Vicki Schmidt, Rep: Jim Morrison, Sen. Derek Schmidt, Sen. Jan Pauls [Judiciary Cmtee]Family Court Reform Coalition, StopFamilyViolence.org, Jackie Williams, Battered Mothers Custody Conference,