2004 Sept. 17th --Reply to Swartz en Re Jill Dykes Lies

8/8/2019 2004 Sept. 17th --Reply to Swartz en Re Jill Dykes Lies

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Claudine DombrowskiP.o. Box 15212

Kansas City, MO. 64106

Phone (785) 845-3417

Fax (775) 806-37.10

September 17, 2004

Lloyd Swartz, Domestic Case Manager

800 SW Jackson, St. 900

Topeka, KS 6612

Mr. Swartz,

RE: Judge Bruns Letter Decision

Dated August 26, 2004

and GAL Letter, Dated

(Case No. 96 D 217)

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 wouldlike 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 Clerksoffice.

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 tothe 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 tovisitation, 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.



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 theseunsubstantiated 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 foryour 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 in fact 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 withRikki, after the Case Manager's recommendation was published on February 3, 2004.

3. Interviewed the mother, Ckmdine Dombrowski.



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 andMs. 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 justa 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.

P a g e 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 theGuardian 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 andbusiness 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



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 2004to 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 betrue 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 arecondemning 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'sunsupervised 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 intosaying.

P a g e 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 Manager800 SW Jackson, SI.900

fu ¥ e ~ d ,J K 1 a ff l\3 S ltlilf 1 Jtines 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 timeto 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 VisitProgram.

P a g e ( )



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 Dykes1243 S.W. Topeka Blvd., Suite B

Topeka, Kansas 66612

The Honorable David E. Bruns

Shawnee County Courthouse

Division 12

200 S.E. 7'h Street

Topeka, Kansas 66604

telephone: 785-266-8664

fax: 785-232-0600

e-mail: [email protected]

August 3),2004

----_. _ _ .- - --

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 abovccaptioned 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.

mailto:[email protected]

mailto:[email protected]



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 ~)

kIU 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. 1 1 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 Salleged 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 thenever.

Rikki has had visitation with her mother at the YMCA before. She is familiar with the \0facility 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 7my client, her Therapist, and hopefully, the staff at the Y.MCA. Safe Visit Program. In theevent that I determine that supervised visitation is no longer needed I will report the same to the

Court and parties immediately

1Thank you for appointing me to represent such a wonderful young lady. I sincerely hope ~

that this case can move forward and Rikki can once again have visitation with her mother. ~

2004 Sept. 17th --Reply to Swartz en Re Jill Dykes Lies

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