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LEONARD M. ROBINSON Attorneyat Law
1/;05 5W 37"' Street Topeka. KS 66611-2810
UCENSEDlN KANSAS AND COLORADO

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Business FAX Residence

(785) 267-5063 (785) 267-2652 (785) 862-2475

October 18, 200 I Mr. Hany Moore Assistant Director, Court Services Shawnee County Courthouse 200 SE 1', Suite 104 Topeka, Kansas 66603-3961

RE:

Yourlettersono August200I and II October200I
960217

,

DearHany: The first thing I want to do is answer your question in regard to Claudine when she picked up Rikki back in December of 2000 and their whereabouts. My client informs me that Rikki and her were in Kansas other than an ov.emight stay on December 24,2000 at her Mother's in Texas. I also checked with my client in regards to the pictures showing her bloodied and beaten. She indicates that the Pottawatomie County Sheriffs Department has pictures and the negatives of those pictures that show her physical condition and that it would be obvious that they were not altered. I have tried to get away from arguing about whether Hal Richardson raped Claudine or not in that the pictures obviously show that violence was done toward her whether there was a rape or simply battery makes linIe difference in regard to whether he is violent or not. . It appears at this time that we will not be able to get a change of custody, however, it would seem appropriate that Claudine and Rikki have unsupervised visitation and that the visitation be consistent with the Shawnee County Guidelines. Claudine, back in December of 2000, did not bring Rikki back and it was due to her fears which there was physical evidence of abuse to both herself and to Rikki. We don't want to argue that issue at this point However, it should be taken into consideration in regard to at least the visitation issue. Claudine could have taken Rikki at any time during the last many months of visitation and has not done so nor does she intend to do so. She should not be punished nor should Rikki be punished

Mr. Harry Moore October 18, 200 1 Page Two

along with her by continuing such a restriction on the visitation and thus I am asking both you and Mr. Hoffinan on behalf of his client to at the very least agree to commencing unsupervised guideline visitation. Please make note of my new address and telephone number. Sincerely,

LMR:cls Cc: Ms. Claudine Dombrowski Donald Hoffinan

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