2009 October Secret Motion Of Contempt Against Mother Claudine Dom Brow Ski

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

COURT OF SHAWNEE

HAL RICHARDSON, Petitioner, and DOMBROWSKI, Respondent.

KANSAS

SEALED

) ) ) ) ) )

In the Matter of

CLAUDINE

COUNTY,

Case No. 96-0-217

D\\J -\)

) )

---------_.) MOTION COMES Hoffman,

to show cause September

NOW the petitioner

Hoffman

& Hoffman,

finding respondent

above named,

by and through

not be found

and April 6,2009. in contempt

in contempt

Further, petitioner

and directing

and prosecution

of the Court's

Donald R. respondent Orders

of

prays the Court for an Order

her to remove

minor child from the Web and for an Order assessing preparation

counsel

and moves the Court for an Order directing

why she should

27,2006

& SHOW CAUSE

FOR ORDER TO APPEAR

any images of the parties'

petitioner's

attorney fees for the

of the instant motion.

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

Respondent

was

ordered

not

to present

child

at public

rallies,

demonstrations, in furtherance

newscast

or otherwise

of Respondent's

publicize

the child's name or likeness

efforts in the instant case" on September

27,

2006. 2. The Court further found that: 1) based on incidents and the stipulations

of the parties that Respondent

order by intentionally website

placing photographs

and to links accessible

websites that the Respondent

through

had violated

the Court's

the Respondent's

website

or contributing

and to

to; 2) that

of the minor child were still accessible;

that as of April 6, 2009, the photographs respondent

in the affidavit

of the minor child on Respondent's

was either maintaining

as of April 4, 2009, the photographs

detailed

were not accessible.

3)

Accordingly,

was found to be in Indirect Contempt.

3. The Court fined respondent

$1,500 and ordered

The Court allowed Respondent all photos, likenesses

her to serve 30 days in jail.

to purge herself of the contempt

by removing

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

Facebook.com references

was also ordered

to pay Petitioner's

attorney

fees of

the motion to show cause.

21,2009,

counsel for petitioner

a Facebook child.

to "AngeIFury",

page that contained

A screen-print

is attached

became aware that respondent

hereto

multiple

of respondent's

as Exhibit

1.

"Info"

of the

page

The page is littered

a user name that is associated

2

images

with respondent,

on with as

well as links maintained 5.

to vanous

by respondent,

web-sites

that are supported,

i.e., AngelFury.org

The Photos tab takes the visitor to Claudine

pictures

is identified

as Claudine

Dombrowski's

Photos and lists

See Exhibit 2. The set of

Dombrowski's

Pictures and contains two images of the parties'

Photos

minor child.

of the parties (Exhibit

minor

3b) contains

Dombrowski's

minor child:

Photos - more stuff (Exhibit 3a) contains two images child;

Claudine

Dombrowski's

two images of the parties

Photos - stuff (Exhibit

minor child. Claudine

- Profile

(Exhibit 3) Of

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

and/or

and KS-FCRC.com.

six photo albums and one set of profile pictures!. profile

sponsored

Dombrowski's

Photos

- nutter

one

minor child; and Claudine

3c) contains

one image of the parties

Photos - nutter one (Exhibit

3b) also

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

bum. php?aid=44577

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

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 hup:/ /www.facebook.com/al

bum.php ?aicJ=44577 &i cJ=7 69640228#/al

3&id=769640228 the uri for Claudine Dombrowski's

Photos - Profile Pictures.

bUIl1.php?aid=-

6.

Claudine Dombrowski's between respondent

and a visitor to her Facebook

image of the parties' respondent's 7.

minor child that clearly identifies

it is absolutely

the Court's

Accordingly,

page that appears under the the image as being that

"little girl".

At this point, following

Photos - stuff (Exhibit 3c) also includes a discussion

clear that respondent

Orders of September

respondent

has no intention

of

27, 2006 and April 25, 2008.

should be ordered to appear and show cause why she

should not be held in contempt

of Court; she should

remove any images of the parties' be ordered to pay petitioner's

be ordered-

again -to

minor child from the Web and she should

attorney fees for the preparation

and prosecution

of the instant motion. WHEREFORE,

petitioner

prays the Court enter an Order directing

appear and show cause why she should not be held in contempt finding respondent

in contempt

and directing

her to remove

minor child from the Web; for an Order assessing preparation

and prosecution

respondent

to

of Court; for an Order

any images of the parties'

petitioner's

attorney

fees for the

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

the Court deems just and equitable under the circumstances.

11

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

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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9/21/09 4: 19 PM

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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9/21/095:29

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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

CLAUDINE DOMBROWSKI, Respondent.

) ) ) ) ) )

Case No. 96-0-217

) )

-----------)

MOTION FOR ORDER TO APPEAR & SHOW CAUSE

Exhibit 3

Claudine Dombrowski's

Photos - Profile Pictures

http://www.facebook.com/search/?

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

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

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?pid= 1788993 &i

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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9/21/09 4:59 PM

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

In the Matter of HAL RICHARDSON, Petitioner,

and CLA UDINE DOMBROWSKI, Respondent.

) ) ) ) ) ) ) )

COUNTY,

KANSAS

Case No. 96-D-217

-----------). MOTION

FOR ORDER TO APPEAR

Exhibit 3b

& SHOW CAUSE

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9/21/09 4:20 PM

Claudine Dombrowski's

Photos - nutter one

http://www.facebook.com/search!?

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

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

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

1691848&id=769640228

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=

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10fl

9/21/09 4:57 PM

that

Respondent

demonstrations, in furtherance

was

ordered

newscast

not

or otherwise

of Respondent's

to present publicize

child

at public

rallies,

the child's name or likeness

efforts in the instant

case" on September

27,

2006. 3. The Court further found that: 1) based on incidents and the stipulations

of the parties that Respondent

order by intentionally website

placing photographs

and to links accessible

websites that the Respondent

through

4.

had violated

the Court's

the Respondent's

website

or contributing

and to

to; 2) that

of the minor child were still accessible;

that as of April 6, 2009, the photographs respondent

in the affidavit

of the minor child on Respondent's

was either maintaining

as of April 4, 2009, the photographs

detailed

were not accessible.

Accordingly,

was found to be in Indirect Contempt.

The Court fined respondent

$1,500 and ordered

The Court allowed Respondent all photos, likenesses

her to serve 30 days in jail.

to purge herself of the contempt

by removing

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, 3:00 p.m. Respondent $600 for prosecuting 5.

On September was maintaining parties'

3)

minor

Facebook.com

was also ordered

to pay Petitioner's

attorney

at

fees of

the motion to show cause.

21, 2009, counsel for petitioner a Facebook child.

became aware that respondent

page that contained

A screen-print

multiple

of respondent's

images "Info"

of the

page

on

is attached to the Motion for Order to Appear and Show Cause

as Exhibit 1. The page is littered with references

2

to "AngeIFury",

a user name

that is associated supported,

with respondent,

sponsored

as well as links to various web-sites that are

and/or maintained

by respondent,

i.e., AngelFury.org

and KS-FCRC.com. 6. The "Photos"

tab on respondent's

Dombrowski's

Photos

Facebook page takes the visitor to Claudine

and lists six photo

albums

and one set of profile

picturesl.

(Exhibit 2, Motion for Order to Appear and Show Cause).

of profile

pictures

Pictures

is identified

and contains

as Claudine

two images

Dombrowski's

of the parties'

minor

The set

Photos - Profile child.

(Exhibit

3

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

bum.php?aid=44577

&id= 769640228#1 al bum.php?aicl=-

3&id=769640228 the urI for Claudine Dombrowski's

Photos - Profile Pictures.

contains one image of the parties minor child. Claudine Dombrowski's - nutter one (Exhibit contains

7.

an image

3b Motion for Order to Appear of the Court that was apparently

courtroom

in the Shawnee County Courthouse.

Claudine

Dombrowski's

Photos

- stuff (Exhibit

Appear and Show Cause) also includes a discussion visitor

to her Facebook

page that appears

minor child that clearly identifies

and Show Cause) also taken

from inside

3c Motion

between respondent

Further affiant sayeth naugth,

My commi

4

and a

under the image of the parties'

the image as being that respondent's

and sworn to before me this ~~ay

a

for Order to

girl ".

Subscribed

Photos

of September,

2009.

"little

~ i L.E U

I' .:'

;l\R[J

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

,

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

~

Z009 OCT I b P 4: 20

IN THE DISTRICT

COURT OF SHAWNEE

COUNTY,

) ) ) ) ) ) ) )

In the Matter of HAL RICHARDSON, Petitioner, and CLAUDINE

E3( C U: flri,

DOMBROWSKI, Respondent.

KANSAS

Case No. 96-D-217

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

-1-

day of

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

, 2009. Hoffman & Hoffman.

The Court, upon reviewing Cause and the Affidavit

2009 the above captioned

matter

Motion for Order to Appear and Show Cause filed

day of

counsel Donald R. Hoffman,

respondent

ad, 61/' ,

Petitioner

appears

by and through

There are no other appearances.

the file, the Motion

for Order to Appear

and Show

filed in support thereof, finds that it has been made to appear that

violated the terms of the Court's

Orders with respect to images of the parties'

minor child on the internet. IT IS THEREFORE hereby commanded before

ADJUDGED

and DECREED

to appear on the 13th day of November,

the Han. David

Courthouse,

ORDERED,

B. Debenham,

District

Judge,

that respondent

2009 at 11 :00 o'clock

Division

13, Shawnee

is

a.m.

County

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