Claudine Dombrowski

P.o. Box 15212

Kansas City, MO. 64106
Phone (785) 845-3417
Fax (775) 806-37.10

September 17, 2004

Lloyd Swartz, Domestic Case Manager RE: Judge Bruns Letter Decision
800 SW Jackson, St. 900 Dated August 26, 2004
Topeka, KS 6612 and GAL Letter, Dated
(Case No. 96 D 217)

Mr. Swartz,

I am responding to the Order of Judge Bruns dated August 26, 2004 and the GAL's
letter to the Courts dated August 31, 2004. There are a few issues and topics that I would
like to address and clarify tor you the Case Manager and ti,r the Court's Records.

I. of all as the Domestic Case Manager, I can appreciate the Courts rules and
Guidelines in the fact that everything needs to be presented to you, before and/Or a copy
served to all parties concerned, including a copy to the Court of Venue and the Clerks
office.

As per the Case Management Guidelines and Judge Bruns Order stating that the GAL
is to submit to you, the Case Manager, a report and that as the Case Manager assigned to
the case, your responsibility is to make a recommendation to the Courts based on all
information you have received including but not limited to the report from the GAL.

With these rules and guidelines in place, I, the respondent have been waiting for your
formal recommendation to the Court in which I would respond. However, as certain events
have come into play, the process of beginning supervised visitation at the Y.M.C.A. and the
Judges Order to begin the visitation dated August 27, 2004 and later the GAL letter to
Judge Bruns dated August 31, 2004.

It is with these above stated documents that I now write to you in reference to
visitation, and to seek clarification and closing on certain issues that have been addressed,
by the GAL, the petitioner, the petitioners attorney, Don Hoffinan, the process server
George Martin for the petitioner and to you the Case Manager assigned to this Case.

Page 1
 There have been a significant number of accusations towards the mother/respondent in
these past few months by all the parties mentioned above. All of which have no substantive
basis and I do believe that yet again the time has come for these baseless allegations to
remain mute, or to charge respondent, with the so-called allegations ..... to charge or
release, as per the Habeas Corpus, or even a Motion in Limnie to set aside these
unsubstantiated allegations.

I will try to make this as short as possible, it is however, a challenge to write a response
to the vague and open-ended statements in the GAL, Jill Dykes letter I will start with page
one of the Gal's letter and work through the letter as factually as possible. I thank you for
your patience.

Of the GAL, Jill Dykes letter dated August 31, 2004, Page I, Items numbered 1,3,4,
6,7,8,and 10.

I. Reviewed the Court's Social File.

4. ('olJversed with Dr. Rodeheffer.
3. Interviewed the mother, Claudine Dombrowski.
6. Conversed with the father, Hal Richardson.
7. Conversed with Rene Netherton, former GAL
8. Conversed with Scott McKenzie, j()rmer G-dl
10. CorlVersed with Don IIoffinan, Mr. Richardson's Counsel.

I. Reviewed the Courts Social File.

As stated above, most all of the information I am about to mention would NOT have
to be addressed at all if a thorough review of the file and Courts records had infact been
reviewed, given that the GAL had more than plenty of time from the date of appointment
to the case on June 24,2004 to the date of her summation letter dated August 31, 2004.

2. Conversed with Dr. Rodeheffer

,--:-'
Dr. Rodehefter was removed from the Court's service's on June 24,2004, in the same
Court Order that the GAL was appointed. Dr. Rodeheffer had not had any contact with
Rikki, after the Case Manager's recommendation was published on February 3, 2004.

3. Interviewed the mother, Ckmdine Dombrowski.

Page 2
 Claudine Dombrowski did in fact meet with Jill Dykes in her office on August 26, 2004, at
I :30 P.M .. Please take note of the above as it is written, why was the mother
Interviewed and not 'conversed' with as everyone else? Intentional, or is this a
psychological statement of the GAL's attitude toward the mother in this case?

6. Conversed with the ja/her, Hal RichardwJTI.

Here the GAL 'conversed' with the father, Hal Richardson, but did not interview
him? Again I find it somewhat suspicious as to why.a Court appointed GAL, would not
"interview" both parents in a decision as important as this one, rather 'converse' with
everyone but the mother. The writing it's self shows de-4fty that the mother is 'singled'
out.

7, Conversed with Rene Ne/her/or/Jonner GAL

Rene Netherton, was NEVER appointed to this case in ANY way or form as a GAL
. or other, however, there was a 'conflict of interest' relating to her and the GAL Scott
McKenzie a former and discredited GAL from 1997, with whom Rene Netherton shared
an office with, more disturbing is that Jill Dykes herself was in the same office with Rene
Netherton and Scott McKenzie, right up until the appointment of herself to act as GAL on
behalf of the minor child Rikki Dombrowski. Clearly this is a conflict of interest.

Not only did Rene Netherton not have any bearing what so ever to the case. But, on
March J I, 2002, Renee Netherton came with Iloffinan and petitioner to an informal
hearing. Ms. Netherton sat with Mr. Hollinan and petitioner during the proceedings and
Ms. Netherton left with Mr. Hoffinan and the petitioner after the proceedings. It was
evident that the relationship betwcen Mr. Hoffman and Ms. Netherton was more than just
a professional courtesy.

After Ms. Netherton's request to be the GAL for the parties minor child was
DENIED, and a Forensic Psychologist was appointed instead, Ms. Netherton then felt
justified in interfering with this case again, to which she had no standing in other than the
fact that she was allied with Don Hoffinan, and maybe she was a bit discouraged in not
being allowed to position herself as the GAL in this case.

A worthy note here, is that the Mother had already been in supervised visitation @ the
Y.M.c.A. for a period of more thin a year and a baIf after the mother had reported
being raped and beaten, by the petitioner, father, Hal Richardson, in December of
2000, thus receiving emergency medical care and as a result of the reported abuse,
parenting time was rescinded and changed to supervised upon a Motion filed by
Hoffman. The mother did NOT have legal representation at that time.

Page 3
 Rene Netherton then submitted a memo to the presiding Judge (attached) dated March
20, 2002, which ultimately caused yet another obstacle in the mother's attempt to see her
daughter other than in a "supervised" environment, of a Court Orderd Forensic
Psychologist who had already been paid a $5000.00 retainer fee by the mother and was
more than halfway finished with his evaluation, of the mother. An Evaluation that was
Ordered because Hoffinan and petitioner ascertained that the mother was
homicidal/suicidal to her minor child Rikki. Requesting this hardship and expense to the
mother in hopes off ailing the requirements to lift the "supervised" visitation.

The purpose was solely to benefit Don Hollinan and petitioner, as it was more than
clear at the March II, 2002 hearing that Hoffinan and Netherton were avidly seeking her
appointment in one way or another to this case. Fortunately the presiding Judge did allow
the Court appointed Psychologist to finish his evaluation and submit a report. (attached)

8. Conversed with Scott McKenzie, former GAL.

As more than noted above, in addition to Scott McKenzie's failure to follow the
Guardian Ad Litem Rule 100, which was demonstrated at the original trial in 1997.
Not only did Scott McKenzie fail to speak with the minor child, her day care provider and
her physician, but, he also failed to speak with the mother and or the mothers' employer.
Further while acting as GAL for Rikki Dombrowski, even with documents from the
Battered Women's Task Force, and a printout of Hal Richardson's Criminal record, in
addition to the Court Ordered Alternatives to Battering program that Hal Richarson was
Court Ordered to attend as a condition of his probation related to a conviction of Domestic
Violence towards the mother (95CR 00836) attached. But that Hal Richardson was kicked
out of ASP program related to his sexist comments and combative stance. "Terminated
with cause, will not be accepted back, as he is causing to many problems with his mouth."
(see attached ABP records)

Scott McKenzie not only failed the rule 100 but denied having any knowledge of ANY
conviction other than" ... maybe a DUI of sorts ... " Scott McKenzie DID however meet
with the ex wife Kathy Richardson and with Hal's three grown children. Out of his
investigation he did not see that even though all of the above was in the Courts record, but
instead stated that" ... 1 believe Mr. Richardson is a fine and upstanding citizen and
business owner."

The Courts transcripts of the two day trial is in the Courts records. Further as Jill Dykes
felt the compensatory need to dig up a GAL from over eight years ago, to converse with.
Why did she not talk with any of Hal Richardson's P.O. officers in particular MaryKelly
who is still a very respected member of the Court System. The Courts records are replete
with FACTS!! Including the attached memorandum from Mary Kelly in 1995 related to
Hal Richardson's 95CR00836 conviction in that "Mr. Richardson is NOT a good candidate

Page 4
for probation ..... " The Courts r~cords more than show Mr. Richardson as a criminal and a
Convicted and self admitted batterer.

or the GAL, Jill Dykes letter dated August 31, 2004:

Page 2, Paraf(raph 1, lines 1,2, and 3.

GAL submits that the Court issued an Order for Supervised visitation in February 2004
to take place through the Y.M.CA Safe visit program

FACT: The Order stated "supervised parenting time", but the Court did not state back
in February 2004, that the visits were to be through the Safe visit Program. A simple
revieW of the documents and Orders will clearly show this.

Paf(e 2, paragraph 2, lines 1, 2, 3. 4. 5,and 6.

Here again the GAL, Jill Dykes is commenting on allegations and accepting them to be
true as if the mother had been charged, tried, convicted and sentenced in violations of
Courts Orders. Again, here Respondent requests that she be charged and given 'due
process' hefore she is found to be guilty o[ANY crimes that have been purported through
many of the Courts OtJicers by manipulation of the petitioner and his counsel.

Page 2, paragraph 3, lines, 1.2, and 3.

Utilizing the Farm in Lawrence was a suggestion of the Court, and in the same Order
that appointed Jill Dykes to be GAL for Rikki Dombrowski. The Gal's remarks are
condemning and •caddy' to the mother in that she refuses to see her d{lIIf(hter, however,
there was no mention made by the GAL, that the mother Dll) in fa!;t contact the GAL, Jill
Dykes, within a week of her appointment to the case, to facilitate the process of utilizing
the Farm. Nor, does the GAL state that she was finite in that "No arrangements are to he
made without a review of the file ..• by Jill Dykes her self.

Paf(e 2, paragraph 4, lines I thm 6,

Again, allegations withow due process, and the original reasons as to why the mother's
unsupervised parenting time was recinded. I think we all know by now that these are
completely unfounded allegations, for many reasons, the most important being the safety
and the fear that Rikki was under, to say these as the abuser has intimidated her into
saying.

Page 5
 This little girl is doing exactly what her mother told her to do, to remain safe! Even if
it means making IIntme statements, to remain safe.

Page 2, paragraph 6, lines 1 thm 5,

Of course Rikki would have no objection to the Y.M.C.A Sale visit program. It is not
like she would know that there would even exist an alternative way lor this little girl to see
e.'b~artz-Case Manager
800 SW Jackson, SI.900
fu¥e~d,JK1affl\3Sltlilf1Jtines 1 thm 4, GAL Leiter, Dated
AuFtust 31, 2004
' when the GAL decides it is no 101lgerneeded it was my understanding that
Jill Dykes is a GAL, with input into the case manager who then in turn makes HIS
reccomendation to the Court, NOT the GAL. This statement reads as though the GAL, Jill
Dykes has assumed all Judicial Discretion in issues related to this matter.
Quoting ..

"In the event that 1 determine that ~7lpervised visitation is r/O longer needed 1will report
the same to the COllrt alld parties immediately ...

My understanding is that there IS a process called Case Management, and even though
I have issues with the case manager, the Courts Orders were loud and clear to me. I
suggest that the GAL lollow the same rules and guidelines as set foth by the Court and
present to the Case manager as she is supposed to. Ms. Dykes also needs to re-review her
own notes and the Courts File as she has missed some very important information to which
I have attempted to somewhat add to in this letter.

In Judge Bruns Leiter Decision dated August 26, 2004, page 2, paragraph I, lines, I,
2, 3, and 4,

"It should be noted once again that the Court rarely views sunervised parenting time
to be a long-term solution."

And

"As such, for the purposes of this divorce action, the Court continues to presume that
both parents are capable of caring for their child."

Currently, I have already gone through the application process at the Y.M.C.A, this I
did after receiving the Courts last Order to begin the supervised visits at the Safe Visit
Program.

Page ()
As of September 18, 2004, there still are no available time slots to schedule in one (I) 50
minute visit, each week. Rikki and I have been placed on the waiting list There is no
indication as to how long that list is

I eagerly await your response and or recommendation.

Cc: Judge Bruns

Clerk's Olike
Don Hoffman
Jill Dikes
 The Law Office of
M Jill Dykes
1243 S.W. Topeka Blvd., Suite B telephone: 785-266-8664
Topeka, Kansas 66612 fax: 785-232-0600
e-mail: faithjull_@hotmail.com

August 3),2004
-- - -_. __ . - - --"- ---

The Honorable David E. Bruns

Shawnee County Courthouse
Division 12
200 S.E. 7'h Street
Topeka, Kansas 66604

Re: Richardson v. Dombrowski

Case No.: 96.0.217

Dear Judge Bruns,

Pursuant to my appointment as Guardian ad Litem for the minor child in the abovc
captioned case I have conducted the following:

I. Reviewed the Court's social file.

2. Interviewed the minor child, Rikki .
..---- _.J ~.-.--Interviewed the.mother;Claudine Dombrowski.
4. Conversed with Dr. Rodeheffer, Rikki's Therapist.
5. Conversed with Amanda Smith, Court Services.
6. Conversed with the father, Hal Richardson.
7. Conversed with Rene Netherton, former G.A.L.
8. Conversed with Scott McKenzie, former G.A.L.
9. Conversed with Lloyd Swartz, Case Manager.
10. Conversed with Don Hoflinan, Mr. Richardson's counsel.
II. Reviewed on going Letter Decisions and Documents filed with the Court.

As the Court is aware, Ms. Dombrowski has requested the Court set aside the order Jor
supervised visitation between Ms. Dombroski and her daughter Rikki. With regard to this issue,
I received a letter from the case manager, Lloyd Swartz, on or about August 5, 2004, requesting
that I provide the Court and parties with written argument concerning the visitation.
 My review of the social file disclosed that the order for supervised visitation issued
around February of 2004. The order allowed Ms. Dombrowski to have visits with her daughter,
Rikki, through the YM.C.A. Safe Visit Program.

Since the Order issued there have been two reported violations of the Order by Ms. <.::--
Dombrowski. One involved an incident at the school where Ms. Dombrowski allegedly stood in
a neighbor's yard near the school and tried to communicate with Rikki. The other involved Ms.
Dombroski dressing in disguise and hiding in a bathroom stall at the school during a girl scout
meeting. Ms. Dombrowski allegedly tried to pull Rikki into the stall so she could talk with her.
Ms. Dombrowski denies both of these allegations.
.,
Since the order for supervised Visitation issued Ms. Dombrowski has not visited with ~)
-'~ikIU attliC Yl;;r.CA. . M~ombrowski statedll1atSl1eoia-riot walino' use'iheYM.-CA:-aiia'
would prefer to use the Farm in l.a\HenCe, Kansas.

At this time, I believe that supervised visits are still appropriate. In addition, I do not see L{
a reason to change the location from the Y.M.C.A. to the Farm. 11 is my understanding that the
visits were originally changed to supervised because Rikki had overhead comments on a visit
with her mother that led her to believe her father was in danger. Based upon this fear, Rikki's
therapist, Dr. Rodeheffer, felt that it would be in Rikki's best interest to have supervised visits
with her mother.

Since the order was entered, Rikki has had no contact with her mother other then the S
alleged reported violations. Therefore, nothing has changed materially which would indicated
that unsupervised visits would be appropriate at this time. In fact, given the allegations and
Rikki's responses to them it appears that supervised visitation is more appropriate now then
ever.

Rikki has had visitation with her mother at the YMCA before. She is familiar with the \0
facility and VOiced no objection to meeting with her mother there in fact quite the opposite.
Rikki stated to me she just wished her mother would fill out the paperwork so she could see her.
___ RY3'hangingtheJocl\!wn.of.1hc v'.5it1tion.l(uh~. farm, all wc .would .bc.Bccomplishing.would.he
to place Rikki in another unfamiliar environment which would not be in her best interest.

I intend to continue to monitor the case and it's progress through ongoing contact with 7
my client, her Therapist, and hopefully, the staff at the Y.MCA. Safe Visit Program. In the
event that I determine that supervised visitation is no longer needed I will report the same to the
Court and parties immediately
1
Thank you for appointing me to represent such a wonderful young lady. I sincerely hope ~j
that this case can move forward and Rikki can once again have visitation with her mother. ~